PRIVACY POLICY
What this site collects, why, for how long, and what you can demand from us. Written against what the code actually does, not from a template.
Last updated: 17 August 2026
Controller
- Upper Int Games LTDA, ME, registered in Brazil under CNPJ 68.146.077/0001-08, state of São Paulo.
- Channel for any privacy request or question: hello@upperintgames.com.
- We do not appoint a data protection officer. Resolução CD/ANPD 2/2022 exempts companies of our size from that duty, provided a communication channel is published, which is the address above.
No cookies, no tracking, no forms
- This site sets no cookies at all.
- There is no Google Analytics, no advertising pixel, no social media tracker and no third-party script of any kind. The pages load nothing from outside our own domain, not even fonts.
- There are no forms, no accounts, no passwords and no payments. Every contact link opens your own email client.
- We do not sell, rent or trade personal data. There is nothing to sell.
Language preference, stored on your device
- When you switch between English and Portuguese we save the choice in your browser under the key uig-lang, with the value "en" or "pt".
- It never leaves your device, it carries no identifier and it cannot be used to recognise you. The ANPD's own guidance on cookies gives language preference as its example of functional storage that requires no consent banner.
- Clearing your browser storage removes it.
Access records: date, time and IP
- For every request to this site we record the date and time, the IP address, the browser user agent, the page requested and the response status.
- Legal basis: compliance with a legal obligation, LGPD Art. 7, II. Marco Civil da Internet Art. 15 requires an internet application provider organised as a company to keep these records for six months, under confidentiality, in a controlled and secure environment.
- Retention: exactly six months, after which they are deleted automatically. We do not keep them longer and we do not use them for advertising, profiling or any commercial purpose.
- The IP address is stored encrypted. The key is held separately and the record cannot be read without it.
- These records are released only under judicial authorisation, as Marco Civil Art. 15, §3 requires. Every access to them is itself logged, with who accessed, when, for how long and which file, as Decreto 8.771/2016 Art. 13, III requires.
When you write to us
- If you email careers@, hello@ or business@, we receive whatever you chose to send: your address, your name if you sign, your portfolio links and the content of your message.
- Legal basis: our legitimate interest in answering you and, for commissions, the steps leading to a contract, LGPD Art. 7, V and IX.
- We keep this correspondence while the conversation is useful and while we may need it as proof of what was agreed. You can ask us to delete it.
Our processors
- Vercel Inc. hosts the site and serves every page.
- Cloudflare Inc. stores the access records described above and runs the code that writes them.
- Zoho Corporation provides the email on our domain.
- All three are outside Brazil, so this involves an international transfer of personal data under LGPD Art. 33. We use them because they are the operational providers of the site and the mailbox, and they act on our instructions.
What you can demand, LGPD Art. 18
- Confirmation that we process data about you, and access to it.
- Correction of data that is incomplete, inaccurate or out of date.
- Anonymisation, blocking or deletion of data that is unnecessary, excessive or processed unlawfully.
- Portability, and information about who we shared data with.
- To withdraw consent, and to be told what happens if you refuse.
One honest limit: access records kept under Marco Civil Art. 15 cannot be deleted on request during the six months, because keeping them is itself the legal obligation. They are deleted automatically when the period ends.
To exercise any of these, write to hello@upperintgames.com. We answer within a reasonable period and may ask you to confirm your identity before releasing data.
No app has been published yet
- Upper Int Games has not released any game. This policy currently describes the website only.
- When a game ships, this page gains a dated section for that specific title describing exactly what it collects. We will not let the wording above quietly cover an app with different practices.
Changes to this policy
- If what we collect changes, this page changes with it and the date at the top changes too.
- Questions, complaints or requests: hello@upperintgames.com. You may also complain to the ANPD, the Brazilian data protection authority.