PRIVACY POLICY

Effective day: September 8, 2025

At UpGrade, we respect the privacy rights and data protection rights of our users and recognize the importance of protecting the personal information we collect about you. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information.

This Privacy Policy applies to Websites, Apps, Games and other Services operated by UpGrade. For simplicity, we refer to all of these as our “us”, “we”, “publisher”, “services” or “apps” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services, including apps and games.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.

INTRODUCTION

This Privacy Policy applies when you use any of the Apps of UpGrade Publisher and should be read together with Terms of Use. By using a our Apps, you are consenting to our processing of your information in ways set out in this Privacy Policy. If you do not agree with it, please do not use any our Apps. In certain cases, for example, if geolocation data is processed by the relevant App, the App will prompt you to give additional consent. In such case, you can choose not to give consent to us processing data related to your location but you can still use the Publisher’s App. From time to time, Publisher may modify this Privacy Policy so you should review it regularly.

INFORMATION WE COLLECT

When you use Apps, Publisher may collect data, including information which directly or indirectly identifies you. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. The information we collect about you includes:

We will collect information about you when you interact with us such as when you report a problem, contact or communicate with us.

To use certain features in our services, you may allow us to access your camera or the microphone. Depending on your device, Apple and Android system will ask for your permission before allowing us to access these features.

If an Publisher’s App offers you the option to register, we will collect the information you provide to us in the registration form. This may include identification data such as your name, email address or other account or registration information.

Features that allow you to share content about your use of our services with your connections or through your social network.

We will also collect your information when you use publisher’s Apps such as when you post or share material, upload data, request further services or make selections using the publisher’s Apps, if such functionality is available in the Publisher’s App.

We may collect certain device information and electronic identifiers such as your mobile device identifier provided by your mobile device operating system, your mobile operating system details and the name of your mobile carrier, hardware and software information such as app version, app crashes, device type, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser. For example, if you use the iOS platform then Advertiser IDs (also known as “IDFAs”) may be collected. Other identifiers collected may include IP addresses, OpenUDID, Session ID, ODIn1, iOS Vendor IDs, MAC addresses, IMEI, Android ID for Android platform, and ODIN1 for OS X (together with the IDFAs, the “App Identifiers”).

Information about how and when you use the Publisher’s App. This includes the amount of times you used the Publisher’s App, which parts of it you viewed and other technical data such as country settings and timestamps.

Geolocation data, which is any information which indicates the geographical position of your device and which may include the time the location was recorded. Before processing any precise GPS geolocation data, the Publisher’s App will require you to give your consent, which you can revoke by changing the privacy settings of your device.

Information on your wireless and mobile network connection, like your service provider and signal strength.

Any of your information you provide or permit to be provided to us via a social network or public forum provider like Facebook when you link the Publisher’s App to your social network or public forum account. This data may include your use of the Publisher’s App on such public forums and/or social networks, including with whom you share the Publisher’s App. For further information how and for what purpose the social network provider collects etc. your data see their privacy policy.

We automatically collect certain information from your device when you use the Publisher’s App including information about your device, carrier and other technical data. If you opt-in, some services may collect movement data from your device. We may collect the facial feature data separately from your photos only to provide you remove background functionality (our AI works only with photos with people). Please note, we collect the facial feature data that is not biometric data. This facial data does not contain your identity and is not uploaded to or otherwise stored on our servers, and we never access (nor are we able to access) those photos/images from your device. In addition to the information you provide us directly, we receive information about you from other services, including:

You may be able to use your Facebook account to login to create an account. When you use this feature, we may receive any of your information you provide or permit to be provided to us via a social network or public forum provider like Facebook. This data may include your use of our app on such public forums and/or social networks, including with whom you share our app. For further information as to how and for what purpose the social network or public forum provider collects, uses and shares your data, as well as how you can set your privacy preferences on their site or apps, please see their privacy policy. We may receive information about you from our partners, for instance where our ads are published on a partner’s website or platform (in which case they may pass along details on a campaign’s success). If you purchase a subscription in our apps, neither Google nor Apple provide us with any personal information of the subscription purchaser (like name, email or payment information). Only anonymized data gets passed to us.

HOW DO WE USE UPLOADED IMAGES?

Your images are secure and will be treated confidentially. We transfer them SSL/TLS-encrypted and use them only to remove the background and then offer you the result for download. We do not share them with third parties, do not publish them and do nothing else with them. At the latest about one hour after the upload we delete both the uploaded image and the result image. Apart from that, we keep usage statistics (without images) and if you contact us e.g. by email, we also receive personal data from you, which we use to reply to you. If we have a customer/supplier relationship, we also use your data for bookkeeping and similar purposes.

ONLINE TRACKING AND OPT-OUT

We are committed to providing you with meaningful choices about the information collected from you on our publisher’s Apps for third party purposes, and that is why we provide the links below to the NAI “Consumer Opt-out,” DAA opt-out, and Google and other opt-outs that are only applicable to participating third parties, which does not include Publisher. As stated below you may also block certain App Identifiers by changing the settings of your device. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is still working on Do Not Track standards, implementations and solutions. https://support.google.com/ads/answer/2662922?hl=en, [suspicious link removed], http://www.aboutads.info/choices/, https://info.yahoo.com/privacy/us/yahoo/, http://www.flurry.com/legal-privacy/end-user-opt-out, https://www.adjust.com/terms/privacy-policy, http://www.google.com/intl/en/policies/privacy, https://policies.google.com/privacy,

COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use Google Analytics tool Firebase in order to carry out analysis on Information which is gathered by publisher’s Apps. App Identifiers and other Information which Publisher’s gather are provided to Google in order to enable them to carry out data analysis. Any Information (including App Identifiers) which are provided to Google will become subject to Google’s privacy policy which is located here: www.google.com/privacy.html. For further information on how Google’s Firebase analytics tool uses data, please see the site “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).

Separately to the publisher’s Apps, the Publisher’s website itself uses cookies. Certain information about you, (including personal information), may be collected through the use of cookies when you visit and interact with our website. Some of these cookies are essential for the Publisher’s website to operate and ensure that we provide the services you requested. By using our services you agree to the use of certain non-essential cookies unless you set your browser to reject them. A cookie is a small text file that

is stored on your web browser when you visit a website. Cookies are widely used in order to make websites work, or to work more efficiently, as well as to provide information to the owners of the website. We use cookies to enhance user experience and to collect information that helps us improve our website.

HOW WE USE YOUR INFORMATION

We will use your information for the following purposes:
  • To provide you with the services, such as creating an account, granting access to features, displaying content.
  • To personalize your experience, improve our website and develop new products and services.
  • To communicate with you about your account or our services.
  • To conduct research and analysis to better understand our users and improve our services.
  • To ensure the security of our services, prevent fraud, and protect our rights and interests.
  • To comply with legal obligations and regulatory requirements.
WHEN WE DISCLOSE YOUR INFORMATION

We may disclose your information to third parties in the following circumstances:
  • With Service Providers: We may share your information with service providers who help us with our services, such as hosting, data analysis, customer service, and marketing.
  • With Affiliates: We may share your information with our affiliated companies, who may also use your information to provide services and for marketing purposes.
  • For Legal Purposes: We may disclose your information if required by law, such as in response to a subpoena or court order, or to comply with other legal obligations.
  • To Protect Our Rights: We may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as evidence in litigation in which UpGrade is involved.
  • In Case of Merger or Acquisition: If UpGrade is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be sold or transferred as part of that transaction.
YOUR RIGHTS

You have certain rights regarding your personal information, depending on applicable law:
  • Right to Access: You have the right to request access to the personal information we hold about you.
  • Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal information.
  • Right to Erasure: You have the right to request the deletion of your personal information in certain circumstances.
  • Right to Restriction of Processing: You have the right to request the restriction of processing your personal information in certain circumstances.
  • Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit those data to another controller.
  • Right to Object to Processing: You have the right to object to the processing of your personal information in certain circumstances, such as for direct marketing.
  • Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us using the contact information provided below.

DATA SECURITY

We take reasonable measures to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

CONTACT US

If you have any questions or concerns about our Privacy Policy or our data practices, please contact us at:

support@up-grade.app

Last updated: September 8, 2025.