Privacy Policy
This Privacy Policy explains how GravityGames Limited (Company No. 16556090, 85 Great Portland Street, First Floor, London, England, W1W 7LT) collects, uses, stores, and shares your personal information when you visit or use up-gift.com (the “Platform”). We handle your data in accordance with applicable data protection laws, including the UK GDPR and, where relevant, the EU GDPR.
If you have questions or wish to exercise your data rights, contact assist@up-gift.com.
We apply appropriate technical and organisational measures and follow these principles:
- We collect personal data only where we have a lawful basis.
- We use data for specified, explicit purposes and not in a manner incompatible with those purposes.
- We retain data only as long as necessary for those purposes or legal obligations.
- We keep data accurate where reasonably possible.
- We secure data against unauthorised access, misuse, alteration, or loss.
- Access is limited to authorised staff and trusted service providers where needed.
We process personal data to operate the Platform safely, fulfil orders, support you, and meet legal obligations.
Categories and typical purposes (lawful basis):
- Technical data (IP address, device/browser info, pages viewed, logs) — secure the Platform, prevent fraud, improve performance.
- Account data (name, email, password hash, country/region, contact details) — create/manage your Account, provide the Service, communicate with you (contract; legitimate interests).
- Payment & transaction data (amounts, timestamps, masked payment details, identifiers from payment processors) — process payments, handle chargebacks, keep records (contract; legal obligation).
- KYC/AML data (identity documents, verification outcomes, sanctions/PEP screening results where required) — comply with law and prevent fraud/abuse (legal obligation; legitimate interests).
- Support data (messages, attachments, metadata) — resolve issues and improve service quality (contract; legitimate interests).
- Marketing preferences (opt-in status, communication choices) — send updates/offers if you consent (consent; you can withdraw at any time).
- Legal/compliance data (requests from authorities, dispute files) — handle claims and comply with legal requirements (legal obligation; legitimate interests).
We do not sell your personal data. We do not use automated decision-making, including profiling, that produces legal or similarly significant effects on you.
We share personal data only where necessary and under appropriate safeguards:
- Payment processors — to process payments and manage refunds/chargebacks.
- Verification, fraud-prevention and sanctions-screening providers — to conduct KYC/AML checks where required.
- Hosting, security, analytics, email and customer-support providers — to operate and secure the Platform.
- Professional advisers, insurers, auditors — for compliance and risk management.
- Law enforcement or regulators — where required by law or to protect rights, users, or property.
International transfers. Some recipients may be outside the UK/EEA. Where this occurs, we use lawful transfer mechanisms (e.g., UK IDTA/EU Standard Contractual Clauses and supplementary safeguards) to protect your data.
We keep data only as long as needed for the purposes above or as required by law. Typical periods:
- Account data: up to 5 years after last activity (or earlier deletion unless retention is required by law).
- Transactions/financial records: up to 10 years from the transaction date (tax/accounting).
- KYC/AML records: retained as required by applicable law and guidance.
- Fraud/security logs: as long as needed to protect the Platform and users.
- Support tickets: typically a few months after resolution, unless needed longer for legal/compliance reasons.
- Marketing data: until you withdraw consent or close your Account.
Where necessary, we may retain data longer to establish, exercise, or defend legal claims or comply with legal obligations.
If you opt in, we may send you news, offers, or tips about GravityGames. You can opt out at any time by:
- Clicking unsubscribe in our emails;
- Updating preferences in your Account; or
- Emailing assist@up-gift.com.
You will still receive essential service messages (e.g., order confirmations, security alerts).
Depending on your location and subject to legal conditions, you may have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate or incomplete data;
- Erase data (right to be forgotten);
- Restrict certain processing;
- Object to processing based on legitimate interests or to direct marketing;
- Data portability for data you provided;
- Withdraw consent where processing is based on consent.
We respond to rights requests within one month (extendable where permitted). We may request proof of identity to protect your Account. If you are unhappy with our response, you can complain to your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO).
We use cookies and similar technologies on the Platform. Strictly necessary cookies are used on the basis of our legitimate interests; analytics/marketing cookies are used only with your consent. Management of your preferences (granting, changing, or withdrawing consent), cookie categories, retention periods, third-party providers, and international transfers are described in our Cookies Policy. You can adjust preferences via the cookie banner or your browser settings.
The Platform is not intended for individuals under 18 (or the legal age in your jurisdiction). If we learn we have collected personal data from a child without verified parental consent, we will delete it promptly.
We may update this Privacy Policy from time to time (for example, due to changes in law or how we operate). If changes are significant, we will notify you via email and/or your Account. Please review this Policy periodically and keep your contact details up to date.
Contact: assist@up-gift.com.
GravityGames Limited
Company No. 16556090
85 Great Portland Street, First Floor, London, England W1W 7LT