The Policy, also known as the Privacy Policy, details how ThrillUP (referred to as "we," "us," or "our" in this document), the creator of the mobile application (referred to as the "App"), collects data. This Policy explains the process of Information gathering during the use of the App, along with how we handle and share this data, while also outlining your rights regarding the collected Information.

1. Acceptance

Prior to using or accessing our Services, we urge you to carefully review this policy. By agreeing to this Privacy Policy, you consent to our practices of collecting, storing, utilizing, and disclosing your Information as outlined in the subsequent sections. It is important to note that if you do not agree with any part of this Privacy Policy, you should refrain from using the Service.

2. Amendments to this Policy

We will notify you of changes to this Privacy Policy by posting the amended terms on the Service or via the email address we have on file. By continuing to use the Service after those changes are posted, you agree to be bound by the revised Policy. To find out when we last updated this Policy, please refer to the date listed after “Last Modified” at the top of this Policy. If you do not agree to the changes, you should discontinue your use of the Service immediately.

In addition, we may provide you with “just-in-time” disclosures or additional Information about the data collection, use and sharing practices of specific parts of our Service. These notices may provide additional information about our privacy practices, or additional choices about how we process your information.

3.Collection of Data

A. Tracking Technologies and Cookies: To gather insights into your usage of the Service, we employ "cookies" and similar tracking technologies. This includes monitoring how you engage with features within our App, the duration spent on specific pages, and any error messages encountered during your use of the Service. For further details, please refer to the privacy policy associated with the relevant services.

B. Device Details: Information regarding the device utilized to access our Service is collected. This encompasses details such as the device type (e.g., mobile, automotive, smart home device, etc.), your advertising Identifier (such as "IDFA" or "AdID"), network connectivity type (e.g., Bluetooth, WiFi, 3G, 4G, LTE, etc.), operating system and version (e.g., iOS, Android, Windows), language settings on your mobile device, and your mobile service provider.

Detailed information concerning each category of personal data gathered is available in the specific sections of this privacy policy or through explanatory texts presented prior to data collection.

4.Utilization of Collected Data

The data acquired through the Service aids us in comprehending the utilization of our products, applications, and services. Your personal information will solely be used in accordance with this Policy or as communicated to you prior to such processing.

If you believe that the purposes for which we are processing your information do not align with the original intent for gathering your data or with your consent, you have the option to restrict the use of your personal information for such purposes. However, limiting the processing of your information may result in certain features or the entirety of the Service being unavailable to you.

Outlined below are the ways in which we employ your personal information:

A. Advertising: This service allows the use of user data for advertising purposes, including the display of banners and other advertisements within the Application, potentially based on user interests. Not all Personal Data is utilized for this objective. Specific information and terms of usage are detailed below. Some services mentioned may utilize Cookies for user identification or employ behavioral re-targeting methods, tailoring ads to match user interests and behavior, even those observed outside the Application. For further insights, please refer to the privacy policies of the relevant services. Apart from any opt-out choices provided by these services, users can opt out of third-party cookie usage by visiting the Network Advertising Initiative opt-out page.

B. Service Provider:

MoPub (MoPub Inc.) MoPub is an advertising service provided by MoPub Inc.

Admob (Google LLC) Admob is an advertising service provided by Google LLC.

Meta Audience Network is an advertising service provided by Meta, Inc.

Personal Data collected: Cookies; Usage Data.

B. Analytics. The services contained in this section enable us to monitor and analyze web traffic and can be used to keep track of User behavior.

Analytics collected directly (this Application)

This Application uses an internal analytics system that does not involve third parties.

Personal Data collected: Cookies; Usage Data.

Google Analytics for Firebase (Google LLC)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC..

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users have the option to disable specific functionalities of Firebase by adjusting relevant settings on their devices, such as mobile phone advertising preferences, or by following the guidelines provided in other sections of this privacy policy related to Firebase, if accessible.

Information Gathered: Instances of Application access; Application upgrades; details regarding the device; initial app launches; location/region data; session counts; user counts; types of operating systems used; session durations; and Usage Data.

C. System Surveillance: This form of service enables the Application to oversee and analyze the performance, functionality, maintenance, and issue resolution of its components, enhancing overall efficiency. The processing of Personal Data is determined by the attributes and implementation methods of these services, which are designed to monitor the activities within the Application.

Service Provider: Crashlytics (Google LLC). Crashlytics is a monitoring service provided by Google LLC.

Personal Data collected: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

D. Hosting and backend infrastructure. This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Service Provider: Amazon Web Services (AWS) (Amazon Web Services, Inc.). Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Also, the user’s personal data may be used for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

5.Protection Measures

We employ security measures that align with industry standards to safeguard the information within our control against loss, misuse, and unauthorized alterations. However, it is important to note that no data transmission over the Internet can guarantee complete security. As a result, we cannot assure or warrant the security of any information you transmit through the Service, and you do so at your own discretion.

6.Information Transfers

In the event that you choose to utilize the Service or provide us with your information, please be aware that your data may be transferred to, processed, and stored on servers or databases located outside of your country or jurisdiction, including the United States. Such countries may have different data protection laws compared to your country of residence, and may offer less stringent protection. If you prefer that your information not be transferred, processed, or stored outside of your country or jurisdiction, we advise you to refrain from using the Site or Service.

For individuals residing in the European Economic Area ("EEA"), United Kingdom ("UK"), or Switzerland, please refer to Section 16 provided below.

7. Third Party Links

Our Service may include links to third party websites or social media services. We do not control how such third parties collect, use, share or secure your personal information. Please read the privacy policies and settings on the third-party websites and social media services to ensure you are adequately informed how your personal information is handled.

8. Do Not Track

A “Do Not Track” signal is a preference you may set on your browser, but we do not respond to Do Not Track signals.

9. Retention

Personal data shall be processed and stored as long as required by the purpose they have been collected for.

Therefore:

Personal data collected for purposes related to the performance of a contract between us and the user shall be retained until such a contract has been fully performed.

Personal Data gathered for the fulfillment of our legitimate interests will be stored for the duration necessary to accomplish said purposes. Users can obtain specific details regarding the pursued legitimate interests by referring to the corresponding sections of this document or by reaching out to us directly.

We may be allowed to retain personal data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obligated to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

10. Special Information for California Residents

Under California law, California residents who utilize the Site or Service are authorized to obtain a notice from us, free of charge and once a year, describing the categories of personal information (if any) that we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If you are a California resident and wish to receive this notice, kindly contact us by referring to the instructions provided in the "How to Contact Us" section. When making your request, please specify that you are requesting a "California Privacy Rights Notice." Please allow for a minimum of thirty (30) days to receive a response.

Please note that we are not required to erase or otherwise eliminate content or information if:

other state or federal laws require us or a third party to maintain the content or information;

the content or information was posed, stored, or republished by another user;

the content or information is anonymized so that the minor cannot be individually identified;

the minor does not follow the instructions posted in this Privacy Policy on how to request removal of such content or information; and the minor has received compensation or other consideration for providing the content.

Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

11. Special Notification for Users in the European Economic Area, Switzerland and/or the United Kingdom This segment pertains exclusively to individuals who access or engage with our Service while situated within the European Economic Area, Switzerland, and/or the United Kingdom (collectively referred to as the "Designated Countries") at the time of data acquisition. During your utilization of certain Services, we may request you to specify your current country location, or we may utilize your IP address to ascertain your location. In cases where we rely on your IP address, the regulations outlined in this section will not be applicable to any individual who conceals or alters their location details to avoid appearing within the Designated Countries. Should any clauses within this section contradict other provisions in this Policy, the terms specified herein will prevail for users located in the Designated Countries.

A. Our Relationship with You. ThrillUP acts as a data controller for any personal information received from individuals who access or use our Service. A "data controller" is an entity responsible for determining the objectives and methods through which personal information is processed. Any third parties that serve as our service providers, or are otherwise operating on our behalf, are categorized as "data processors" and handle your personal information according to our instructions.

B. Legal Bases for Processing Your Personal Information. We describe our legal bases for processing throughout this Policy. Below is a list of the purposes described in our policy with the corresponding legal bases for processing:

Users have given their consent for one or more specific purposes;

provision of Data is necessary for the performance of an Agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

C. Your Individual Rights. We provide you with the rights described below when you use our Service. If you would like to exercise your rights under applicable law, please contact us at lei123611@163.com. Please note, we may seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.

Right to Withdraw Your Consent. If we ever asked for your consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

Right of Access. At your request, we will furnish you with a complimentary copy of your personal data maintained in our records promptly and without undue delay, unless permitted by law to impose a fee. However, your access may be limited to the extent that it would adversely affect the rights and freedoms of other individuals.

Right to Rectify (or "Correct"). You have the choice to request the rectification or update of any personal information stored within our databases. We may provide you with the ability to directly modify certain or all of your personal data through our Services.

Right to Erasure (or the "Right to be Forgotten"). Upon your request, we will eradicate any personal information from our records that meets the following criteria: it is no longer necessary for the original purposes of collection or processing, it was obtained based on your previous consent which you have since revoked, or it was collected for processing activities to which you object, provided there are no overriding legitimate grounds for our processing.

Right to Restrict Processing. Under specific circumstances, you possess the right to restrict the processing of your personal information. During the restricted processing period, we will only process your limited personal data with your consent, for the establishment, exercise, or defense of legal claims, for the protection of the rights of another individual or legal entity, or for reasons of paramount public interest. If applicable, we will notify you when the restriction is lifted.

Right to Object. If we process your personal information based on your consent, contract, or legitimate interests, you retain the right to object to such processing at any time, as permitted by applicable legislation. However, we may continue processing your personal information if it is necessary for legal defenses or falls under other exceptions allowed by the law.

Right to Data Portability. If we process your personal information based on a contract with you, your consent, or automated means, you have the right to request your personal information in a structured, commonly used, and machine-readable format. You may also request us to transfer your personal information directly to another "controller" where technically feasible, unless this right adversely affects the rights and freedoms of others. This right only applies to personal information provided by you to us.

Notification to Third Parties. When we fulfill your individual rights requests for rectification, erasure, or restriction of processing, we will make reasonable efforts to notify any third parties who also handle the relevant personal information, unless it is impossible or requires disproportionate effort. Upon your request, we will identify such third parties.

Automated Individual Decision-Making, Including Profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

Limitations to Individual Rights Requests. We may limit your individual rights requests in the following ways:

Where denial of access is required or authorized by law;

When granting access would have a negative impact on other's privacy;

To protect our rights and properties; and

Where the request is frivolous or burdensome.

Transfer of Personal Data. We guarantee the safe transfer of your personal data in compliance with the relevant data protection laws. When we transfer your personal information from the Designated Countries, we have implemented appropriate contractual arrangements with the third parties involved to facilitate this process. To accomplish this, we rely on authorized legal mechanisms for transfer, such as Standard Contractual Clauses. Alternatively, we engage with U.S.-based third parties who hold certification under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

Right to File Complaints. If you suspect that we have breached your privacy rights under the applicable laws or this Policy, please reach out to us at lei123611@163.com so that we can collaborate with you to address your concerns. You also maintain the right to lodge a complaint with a competent supervisory authority located in a Member State where you habitually reside, work, or where the alleged violation occurred.

12. How to Contact Us

Please also feel free to contact us at lei123611@163.com. if you have any questions about this Privacy Policy.