Privacy Policy

This Privacy Policy of (the “Policy”) is hereby made effective as of February 26th, 2023, by UPGAMES PTE. LTD.

Privacy Policy of


This Privacy Policy of (the “Policy”) is hereby made effective as of February 26th, 2023, by UPGAMES PTE. LTD. (“Upgames”, “Giveaway”or “We”), and, without waiving or otherwise releasing any right or obligation under any prior privacy policy or similar document or agreement of (“Giveaway”), hereby amend and restate any such prior privacy policy.

By using or accessing Giveaway, you thereby (i) agree and acknowledge that you have read and understood this Policy, and (ii) acknowledge and consent to the learning, collection and use of your Personal Information (as hereinafter defined) as described in this Policy. If you do not agree with any portion of this Policy, you are prohibited from using or accessing Giveaway.

When you open an account with Giveaway and use the Giveaway application, you will provide certain information to Giveaway and, during your use of Giveaway, Giveaway will learn, collect and use certain additional information about you for various purposes, as more fully set forth in this Policy. Even though Giveaway will learn, collect and use information about you, Giveaway will not lease, sell, share or otherwise provide your Personal Information (as hereinafter defined) to any third party without your consent, except as provided herein.

What Information We Learn, Collect and Use

Beginning when you register for Giveaway, Upgames will learn, collect and use certain personal data and information about you and, as you use Giveaway will continue to learn, collect and use additional personal data and information (all such personal data and information is collectively referred to herein as, “Personal Information”). By providing Upgames with this information, you consent to this information being collected, used, disclosed, transferred to the United States and stored by Upgames, as described in our Terms and Conditions and in this Policy.

Information Collected Upon Registration.

In order to become a user of Giveaway, you must provide us with Personal Information, including, without limitation, email address, and, for any social media account information. Without providing these Information, you cannot create a Giveaway account. At the time of registration or when you choose to use certain Giveaway services, Upgames may collect certain other Personal Information from you including, without limitation, demographic information, such as location. Upgames may request or collect Personal Information from you during any registration process which Upgames may use to provide or improve Giveaway or may use as is otherwise provided herein. Upgames may store Personal Information, and it may be included in databases owned and maintained by Upgames’s affiliates, agents or service providers.

Social Logins

Giveaway also allows Campaign Users to connect social accounts to your profile. Companies that have social logins enabled on their Campaigns will be able to see basic information related to accounts that you connect. This includes but is not limited to your name, email address, social profile URL's and associated profile photos. Giveaway will never use or post to these accounts without your permission and will always require your interaction with the widget to execute any specific actions. Giveaway will only ever use information that you have made public or specifically allowed us to access when you accept permissions. Giveaway does not know or store any passwords associated with your social accounts. If you wish to remove the link between Giveaway and any social network, you can either remove the Giveaway Competitions app inside that specific social network or unlink it from the Edit tab inside the Campaign

Persistent Logins

If a camapign user has previously logged in Giveaway tasks, they will continue to stay logged in via third party Cookies across other Campaigns owned by other Companies until they specifically log out. This is designed to make it easy for users to enter more than one campaign without having to re-enter their details again.

Visitors of Giveaway Site

We may collect your personal data in a variety of ways, including, but not limited to, when you visit our Site, register on the Site, subscribe to our newsletter, fill out a form, or in connection with other activities, services, features or resources we make available.

Third Party Platforms and Social Medias

We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as Twitter Likes, profile information gathered from social networking sites during signup or the fact that you viewed or interacted with our content.

Technical, Usage and Location Information

We automatically collect information on how you interact with the Site, such as the IP address from which you access the Site, date and time, information about your browser, operating system and computer or device, pages viewed and items clicked. We may also collect location information, including location information automatically provided by your computer or device. We use cookies and similar technologies to collect some of this information and persist your login to our Site.

Information Collected by Giveaway’s Use of “Cookies”

A cookie is a piece of information that Giveaway gives to your computer when you access Giveaway. Cookies are used by Upgames to track your usage of Giveaway, trends on the usage of Giveaway and to improve Giveaway and analyze and assess changes to, successes and failures of Giveaway and portions thereof.

For security purposes and to ensure the availability of Giveaway, Upgames also uses software programs to monitor network traffic, to identify unauthorized attempts to upload or change information, or otherwise cause damage to Giveaway or Upgames.

Based on how the internet operates, when you visit Giveaway, we automatically receive the uniform resource locator of the prior webpage that you were on and of the webpage where you go after Giveaway. Upgames also receives the internet protocol address of your computer, the type of operating system and web browser you are using, your location, date and time of your access, pages viewed on Giveaway and other information related to your visit to Giveaway.

Other Information

We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by you.

Information Provided Voluntarily When Interacting with Support

Upgames also collects information when you interact with Giveaway's customer service in order to assist you and to improve the operation of Giveaway. This includes any interactions with our team via our support site, chat support, email, our support documentation, and our blog. Information shared with support may include personal information, such as your email address and social media account information, an entrant or subscriber’s name/email address, etc.

Information You Collect and Display in Giveaway Campaigns

Data collected after you create and complete your giveaway campaign, Upgames has access to the data on those lists, emails, and campaigns.

Campaign and Email Analytics Information

When you use Giveaway to send emails, we track information about who has opened the emails and clicked the links. This is done through the use of a tracking pixel that is automatically inserted into the emails that are sent. Specifically, we collect what email addresses have opened the email, when they opened it, how many times they opened it, what link(s) they clicked on, when they clicked on the link, and how many times they clicked the links. This information is used to allow you (the Giveaway user) to evaluate performance of the emails you send.

How We Use Your Personal Information

Upgames uses your Personal Information in connection with the operation, development and improvement of Giveaway, the operation and billing of your Giveaway account, and for other uses consistent with this Policy. Upgames may use your Personal Information for any internal purpose, including, without limitation the development and operation of Giveaway and the development of additional services and products by Upgames or its affiliates, and to communicate with you regarding Giveaway, your account, updates to our services (such as temporary outages or permanent changes), product releases, or other services or products offered by Upgames. Regarding billing and payment, Personal Information you provide to Upgames will be used to send billing-related notices via email. When contacting Upgames for customer support, in order to answer your questions, Upgames may use your personal information, such as email address; and other account-related data. Please be aware that you are responsible for the payment of any fees or costs incurred by you in connection with receipt of communications from Upgames, including data, internet, cellular carrier or other similar fees.

Upgames recognizes the importance of the privacy of its users and does not share or otherwise provide Personal Information to third parties, except as provided herein. Upgames will not disclose or provide your Personal Information to any third party except:

  • as otherwise described in this Policy;

  • as otherwise required by law or to comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures;

  • as reasonably necessary to respond to claims of a violation of the rights of third parties, whether or not the third party is a user, individual, entity or government agency;

  • for any internal purpose of Upgames, including, without limitation, to manage your Giveaway account, subscription and other billing purposes, to respond to your inquiries, to allow outside vendors to perform services required by Giveaway, and to otherwise manage and operate Giveaway and develop new services and products;

  • as reasonably necessary to enforce the Terms and Conditions of Service and Use of (the “Terms and Conditions”);

  • as reasonably necessary to detect, prevent and address fraud and other illegal activity and to prevent death or imminent bodily harm; or as reasonably necessary to protect the rights and property of Upgames or its officers, directors, shareholders, employees or agents.

  • Upgames may provide aggregated anonymous data about the usage of Giveaway to third parties for purposes that we deem, in our sole discretion, to be appropriate, including, without limitation, to prospective advertisers or investors.

Upgames may provide aggregated anonymous data about the usage of Giveaway to third parties for purposes that we deem, in our sole discretion, to be appropriate, including, without limitation, to prospective advertisers or investors.

You acknowledge that any information that you provide to Giveaway to develop your social media page will be publicly displayed on your social media page when you elect to post and display such information there.

Upgames may post, email and use any testimonials that you have provided about Giveaway, and Upgames may post and email examples of content you have created through Giveaway, in connection with the marketing and promotion of Giveaway. Testimonials and other marketing, promotions and advertisements may include obfuscated Personal Information (such as first name and general location) that you have provided to Upgames. Furthermore, Personal Information you provide to Upgames may be used to send you information, advertisements and promotional material via email. You are able the unsubscribe from these emails via the “unsubscribe” link at the bottom of each email communication.

Upgames does not sell your Personal Information or the information you collect when using our platform. Upgames may disclose your Personal Information to a third party as part of a sale of the assets of Upgames, as the result of a change in control of the company, or in connection with an investment in Upgames by a third party. Any third party to which Upgames transfers or sells Upgames‘s assets will have the right to continue to use your Personal Information.

Under the General Data Protection Regulation (GDPR), Giveaway is required to provide notifications when updating our subprocessors to those who indicate they would like to receive notifications. Sign up here to receive subprocessor notifications.

User Collected Information

Giveaway may collect and use user information and campaign data in the following ways and for the following purposes:

Giveaway Website Users

To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

To write or display content such as case studies or customer testimonials on our Site;

To improve Giveaway to ensure that content is presented in the most effective manner for you and for your Device;

To allow you to participate in interactive features of our service, when you choose to do so;

To send periodic emails: We may use the email address to send User information and updates pertaining to their subscription. As well as answering their inquiries, questions, and/or requests, it may also be used to contact them.

Giveaway Campaign Users

Giveaway does not own or use any identifiable data provided by Campaign Users for any reason other than to:

Assign your specific request to the right campaign that you gave your campaign to

To identify and detect fraudulent behavior and Campaign Users who are violating our Terms of Service. Assist Customers with specific Campaign User questions

Campaign User Data Collection

Among other functions of Giveaway, you may create a project profile that collects certain information from customers and other persons that visit your project profile. Should you create any project profile and create giveaway that collects personal email or social media information or other information related to any person or party visiting that page (“User Collected Information”). you represent and warrant to Upgames that any and all User Collected Information has been collected in accordance with any applicable laws, rules or regulation and not in violation of any privacy or similar rights of such persons or parties. As a part of Giveaway, Upgames may store such User Collected Information, but asserts, and you hereby agree and acknowledge, that Upgames has no right, title or interest in or to such information, has not participated or been involved in any such collection, and has no responsibility or obligation with respect to the legal compliance of your collection practices with respect to such information. Upgames will retain User Collected Information we process for our users until the Giveaway user deletes the User Collected Information, deletes their account, as long as necessary to execute Giveaway-related services. However, Upgames may disclose any User Collected Information in the same manner, and under the same circumstances, as any Personal Information may be disclosed. You hereby indemnify and hold harmless Upgames, and all of its officers, directors, shareholders, employees and agents, with respect to any claim, suit or liability (including attorney’s fees and related costs), arising from your User Collected Information.

Your Personal Information Rights

Accuracy And Access of Your Personal Information. You have a right to access, modify, correct and request that Upgames internally delete any Personal Information provided to or obtained by giveaway or Upgames. If you update, modify or correct any Personal Information, we may keep copies of your Personal Information prior to such update, modification or correction for uses provided for in this Policy. You may update, modify or correct your Personal Information via your account Preferences.

Data Protection and Security

Protection of Your Personal Information. Any Personal Information that you provide to Giveaway will be protected in a commercially reasonable manner. We do not access, sell, trade, or rent Users personal identification information to others. Once you provide access to specific data it belongs to the Customer running that specific Campaign and only that Customer. We do not access, sell, trade, or rent Users personal identification information to others. Once you provide access to specific data it belongs to the Customer running that specific Campaign and only that Customer.

Sensitive and private data exchange between the Site and its Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. All user data is encrypted at rest using industry standard SHA-256 encryption. We use appropriate technical and organizational security measures to protect any personal information we process about visitors to our Website against unauthorized access, disclosure, alteration, and destruction. However, please note that no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, secure e-mail and similar technologies to protect yourself online.

Notice of Breach of Security

In the event of a security breach that affects you or the individuals on your Giveaway lists, Giveaway will notify you as soon as possible on both the nature of the breach and the actions taken to address it.

This Agreement is Subject to Your Acceptance

By using Giveaway website, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at

This document was last updated on Feb 26th, 2023

Last updated