Privacy Policy

1. Who We Are

GemuZen is a mobile puzzle game developed and operated by Taleh Sadıqov, an individual developer based in the Republic of Azerbaijan, who trades under the name GemuZen Studio ("GemuZen Studio", "GemuZen", "we", "us" or "our"). GemuZen Studio is a trading name and not a separately registered company.

For the purposes of the EU and UK General Data Protection Regulation ("GDPR") and similar laws, GemuZen Studio (Taleh Sadıqov) is the controller of the personal data described in this Privacy Policy, except where a third party (such as Google or Apple) acts as an independent controller under its own privacy policy, as explained below.

You can contact us about any privacy matter at info@gemuzen.com.

2. Definitions

In this Privacy Policy:

• "Personal data" or "personal information" means any information relating to an identified or identifiable natural person, including information linked to an online identifier such as an anonymous game ID or advertising ID.
• "Processing" means any operation performed on personal data, such as collection, storage, use, disclosure or deletion.
• "Controller" means the person or organization that decides why and how personal data is processed; "processor" or "service provider" means a party that processes personal data on the controller's behalf.
• "Anonymous game ID" means the random identifier created by Firebase Anonymous Authentication for your installation of the Game.
• "Device" means the smartphone, tablet or other device on which you use the Game.
• "Including" means "including without limitation". Headings are for convenience only.

3. Our Privacy Principles

• Minimization: the Game works without registration, and we collect only what is needed to operate, secure, fund and improve it.
• Transparency: this Privacy Policy describes what the Game actually does. If the Game changes in a way that affects your data, we will update this Privacy Policy first.
• Control: you can change your nickname and flag, manage ad preferences and delete your data at any time.
• Security: we protect data with encryption in transit and strict access rules.
• No sale for money: we do not sell your personal information for money.

4. Scope of This Policy

This Privacy Policy applies to:

• the GemuZen mobile game and its updates, as distributed through Google Play and any other official app store where we make it available (the "Game");
• our website at gemuzen.com (the "Website"); and
• communications you send to us, such as support emails.

Together, these are the "Services". This Privacy Policy should be read together with our Terms of Use and our Cookie Policy. It does not apply to third-party websites, apps or services that may be linked from the Services; those are governed by their own policies.

5. Relationship with Our Terms of Use

This Privacy Policy should be read together with our Terms of Use, but it does not form part of that contract. If there is any conflict between the Terms of Use and this Privacy Policy regarding the processing of personal data, this Privacy Policy prevails. This Privacy Policy is a notice explaining how we process personal data; it is not a contract and does not replace any rights you have under mandatory law. Where we rely on your consent, we ask for it separately (for example through the consent message described in the section "Advertising and Your Choices"), and simply using the Services does not count as consent where the law requires a specific consent.

6. Information We Collect

We aim to collect only what is necessary to run the Game, keep it secure, support it financially through ads and optional purchases, and improve it.

6.1 Data stored on your device

The Game stores your progress and settings locally on your device, for example: your game board, scores, coins, jokers, unlocked avatars, themes and collection cards, quests, sound and vibration settings, chosen language, nickname and flag, and technical values needed for features such as daily bonuses and ad limits. This data stays on your device unless it is synchronized to the cloud as described below. You can remove it by using Delete Account & Data, clearing the app's storage, or uninstalling the Game.

6.2 Anonymous game ID

When you first open the Game, we use Firebase Anonymous Authentication (a Google service) to create a random, anonymous user identifier. It does not contain your name or contact details. We use it to link your cloud save and leaderboard entry to your installation of the Game. When the anonymous game ID is created or used, Firebase Authentication also processes technical connection data, such as your IP address and your device's user agent, to secure the service and prevent abuse; Google keeps these logs for a few weeks. If you use Google Play Games, this ID can also be linked to your Play Games profile so that your progress can be restored (see Section 6.14).

6.3 Cloud save data

To back up your progress and run features such as leaderboards, the Game stores the following information in Google Cloud Firestore, linked to your anonymous game ID:

• nickname, chosen flag, active avatar and theme;
• best score and highest color level reached;
• coin balance, jokers, unlocked avatars, themes and collection cards, claimed collection rewards;
• quest progress, league week, reward counters (for example the treasure pity counter and the chest balance);
• technical timestamps (for example the date of last update and last play).

Access to this data is restricted by security rules so that only your installation of the Game can read or change your private save data.

6.4 Public leaderboard profile

A limited copy of your profile is stored separately for the global leaderboard: nickname, chosen flag, avatar, best score and highest color level. This information is visible to other players. See Section 12.

6.5 Analytics data

We use Firebase Analytics (Google Analytics for Firebase) to understand how the Game is used and to improve it. It automatically collects information such as: an app-instance or client identifier, sessions and engagement time, screens and events, app version, device model and type, operating system version, language, the source from which the Game was installed (for example Google Play), and approximate location (country or region) derived from your IP address. The events we record include, for example, starting and finishing a game (with the score, colour level reached, board size and duration), completing the tutorial, unlocking colours, opening packs, claiming rewards, watching rewarded ads and using rescue features. Firebase Analytics is configured not to collect your device's advertising identifier and is not used for advertising. We use this information in aggregated form and do not use it to identify you personally. Analytics is switched off until you allow it: the Game asks for your permission once, and you can change your choice at any time in Settings → Privacy & notifications → Usage & crash data. If you do not allow it, no analytics data is sent.

6.6 Advertising data

The Game shows ads, including optional rewarded ads that you choose to watch in exchange for an in-game reward. Ads are provided by Google AdMob. To deliver, measure and (where permitted) personalize ads and to prevent fraud, Google may collect: your device's advertising identifier (Android Advertising ID or, on iOS, the IDFA if you allow tracking), IP address, device and app information, ad interactions (for example ad views and taps), and your consent choices. On Android devices where they are available, Google may also use the Android Privacy Sandbox advertising features (such as Topics and Attribution Reporting), which you can manage in your device's ad privacy settings. See Section 11.

6.7 Purchase data

The Game offers optional in-app purchases (for example coin packs). Payments are processed entirely by the app store, which for the Android version is Google Play Billing. We never receive or store your payment card details. When you make a purchase, we receive transaction information from Google Play: the product purchased, the order ID, a purchase token, the purchase time and status, the country or region of the purchase and whether it is a test purchase. Before your item is delivered, our server (Cloud Functions, see Section 18) checks the purchase directly with Google Play and stores a purchase record in Cloud Firestore containing this information (the purchase token is stored only in hashed form) together with your anonymous game ID. We use it to deliver your purchase, prevent duplicate delivery and fraud, answer support requests, handle refunds and meet legal, tax and accounting obligations. Purchase records cannot be read or changed by the Game or by other players.

6.8 Support communications

If you contact us, we receive your email address and the content of your message, and any information you choose to include (for example your in-game nickname or screenshots). We use this only to respond to you and to maintain records of the request.

6.9 Diagnostic data from app stores

App stores may provide us with crash reports and technical performance data (for example, Google Play Console "Android vitals"). This data is generally aggregated or pseudonymized and is used to find and fix technical problems.

6.10 Age signals

Where required by law (for example, under certain U.S. state app store accountability laws), app stores may provide us with an age range, age status or parental-approval status for a user. If we receive such signals, we use them only to comply with the law and to provide an age-appropriate experience, and never for advertising or profiling.

6.11 Sharing the Game

If you use the "Share" feature, your device's own sharing menu is opened. We do not receive the list of your contacts, the recipients of your message or the content of your conversations. We only record, on your device, that a share was completed, so that the one-time sharing gift can be granted.

6.12 Crash reports

If the Game crashes or encounters a serious error, Firebase Crashlytics (a Google service) collects a crash report: the error and stack trace, the app version, the device model and operating system version, the state of the device at the time of the crash (for example available memory and storage, orientation and whether the Game was in the foreground), a random Crashlytics installation identifier and the time of the crash. We use crash reports only to find and fix problems in the Game. Crash reports are sent only if you have allowed usage and crash data (see Section 6.5); otherwise they are not sent and are deleted from your device.

6.13 Reminder notifications

If you allow notifications, the Game schedules local reminders on your device, for example to tell you that your daily bonus is ready when you have not played for 1, 3 or 7 days. These reminders are created and stored on your device only; no personal data is sent to us or to a push-notification service for this purpose. You can turn reminders off at any time in the Game's Settings or in your device's notification settings.

6.14 Google Play Games and progress restore

On Android, if you are signed in to Google Play Games on your device, the Game uses Google Play Games Services to link your anonymous game ID to your Play Games profile, so that your progress can be restored automatically if you reinstall the Game or move to a new device. For this, the Game sends a temporary session identifier from Google Play Games to our server, and our server uses Google's Play Games Recall service to save or look up the link. The link uses a pseudonymous identifier derived from your anonymous game ID; we do not receive your Play Games name, email address or Play Games player ID. Google Play Games itself is provided by Google under Google's own terms and privacy policy, and your Play Games account and settings are managed by Google. When you delete your account and data, we remove this link (see Section 20).

7. Information We Do Not Collect

The Game does not ask for or collect: your real name; email address (unless you email us); phone number; postal address; contacts or address book; precise (GPS) location; photos, videos or files; microphone or camera access; biometric data; health data; or payment card details. We do not intentionally collect any special categories of personal data (such as data about health, religion, political opinions or sexual orientation). Please do not use personal information, such as your real name, as your nickname.

8. Device Permissions

On Android, the Game uses the following permissions:

• Internet and network state: for cloud save, leaderboards and ads;
• Vibration: for haptic feedback, which you can turn off in Settings;
• Notifications: only if you allow them, for the optional reminders described in Section 6.13, together with the standard system permissions that allow scheduled reminders to be delivered on time and to be kept after your device restarts;
• Advertising ID and the related Android advertising services permissions (Privacy Sandbox): used by Google AdMob. You can reset or delete your advertising ID and manage ad privacy in your device settings;
• standard technical permissions added automatically by the Google and Android libraries used by the Game, for example to complete short background tasks, to keep the device awake briefly while doing so, or to read the Google Play install referrer.

None of these permissions gives us access to your location, contacts, camera, microphone, photos or files. On iOS, the Game will ask for your permission before any tracking under Apple's App Tracking Transparency framework, where applicable.

9. How We Use Information

We use the information described above to:

• provide the Game and its features, including saving and restoring your progress, daily rewards, quests, collections and leaderboards;
• deliver rewards you have earned, including rewards for watching optional ads;
• deliver and restore in-app purchases and handle refunds;
• restore your progress after reinstalling the Game or on a new device through Google Play Games (Section 6.14);
• show ads and measure their performance, including personalized ads only where you have given consent or where it is otherwise permitted;
• understand how the Game is used, fix bugs and improve performance, balance and design;
• protect the Game and its players, detect and prevent cheating, fraud and abuse, and enforce our Terms of Use;
• respond to your requests and support messages; and
• comply with legal obligations, including tax, consumer protection, age-assurance and data protection laws.

10. Legal Bases (EEA, UK and Switzerland)

If you are in the European Economic Area, the United Kingdom or Switzerland, we process your personal data on the following legal bases:

• Performance of a contract: to provide the Game and its features as described in our Terms of Use, including cloud save, progress restore through Google Play Games, leaderboards, rewards and purchases.
• Consent: for analytics and crash reports, for personalized advertising and, where required by law, for storing or accessing information on your device that is not strictly necessary. You can withdraw your consent at any time (see Section 11), without affecting the lawfulness of processing before withdrawal.
• Legitimate interests: to keep the Game secure, prevent cheating and fraud, show non-personalized ads that fund the free Game, improve the Game, and operate and protect our Website, where these interests are not overridden by your rights. You can object to this processing (see Section 22).
• Legal obligation: to comply with applicable laws, such as tax, accounting and consumer protection rules, and to respond to lawful requests from authorities.

11. Advertising and Your Choices

Consent in the EEA, UK and Switzerland. When required by law, the Game shows a consent message provided by Google's User Messaging Platform before ads are personalized. You can choose whether to allow personalized ads. If you do not consent, you may still see non-personalized or limited ads. Where available, you can review or change your choice at any time in Settings → Privacy & notifications → Ad privacy.

Rewarded ads are optional. You are never required to watch an ad to play the Game. Rewarded ads are only shown when you choose to watch them in exchange for an in-game reward.

Device settings. You can limit ad personalization at any time:

• Android: open your device's Settings, go to Google → Ads (or Privacy → Ads), and delete or reset your advertising ID.
• iOS: go to Settings → Privacy & Security → Tracking and turn off tracking for the Game.

To learn how Google uses information from apps that use its services, visit policies.google.com/technologies/partner-sites. Google's own privacy policy applies to its processing as an independent controller.

12. Public Leaderboards and Nicknames

The global leaderboard shows your nickname, chosen flag, avatar, best score and highest color level to other players around the world. Please choose a nickname that does not reveal your real name or other personal information, and that complies with our Terms of Use. Nicknames are checked automatically against a list of prohibited words when you choose them. We may remove or change nicknames that are offensive, misleading or that appear to contain personal information.

Some entries shown in the global rankings and in the weekly league are computer-controlled (simulated) players, which are labeled in the Game (for example as "AI" or "CPU"). They do not represent real people and no personal data is associated with them.

You can remove your leaderboard entry at any time by deleting your account and data (see Section 20).

13. Offline Use, Synchronization and Loss of Progress

You can play most of the Game without an internet connection. Progress made offline is stored on your device and synchronized to the cloud the next time a connection is available, for example when you return to the home screen, finish a game or leave the Game.

Because the Game uses an anonymous game ID and not a personal account, your progress is linked to your installation of the Game. If you uninstall the Game, clear its data, reset or lose your device, or delete your account and data, your anonymous game ID may be lost and we may not be able to identify or restore your progress. If you were signed in to Google Play Games, the Game can restore your progress automatically when you reinstall it or use a new device signed in to the same Play Games profile (see Section 6.14); otherwise, we do not have a way to transfer progress between devices. If you have turned on your device's own backup to your Google account, Android may include the Game's local data in that backup and restore it when you set up a new device; this backup is managed by Google and your device settings, and we have no access to it.

14. Game Integrity and Fraud Prevention

To keep the Game fair and to protect in-game purchases and rewards, the Game performs automated checks, for example on unusual coin changes, reward claims, ad reward limits and the data that can be written to our database. Suspicious changes may be blocked or reverted automatically. We process the minimum data needed for these checks (such as your anonymous game ID, balances and timestamps) on the basis of our legitimate interests in security and fraud prevention and, where applicable, to perform our contract with you.

15. Communications

We do not send marketing emails, and the Game does not use remote push notifications. If you allow notifications, the Game shows the optional local reminders described in Section 6.13, which you can turn off at any time. If you email us, we will use your email address only to reply and keep a record of the request.

16. How We Share Information

We do not sell your personal information for money. We share information only as follows:

• Service providers that process data on our behalf to operate the Services, such as Google (Firebase Authentication, Cloud Firestore, Cloud Functions, Firebase Analytics and Firebase Crashlytics); and, for our Website, Cloudflare (hosting and security) and, only with your consent, Google Analytics. They may only use the data to provide their services to us.
• Advertising partners: Google AdMob and, through AdMob, its certified ad partners, which receive the advertising data described in Section 6.6 to deliver, measure and, where permitted, personalize ads. Under some U.S. state laws, this may be considered "sharing" for targeted or cross-context behavioral advertising; see Section 23 for how to opt out.
• App stores (Google, Apple) in connection with downloads, purchases, purchase verification, refunds, reviews and age signals, and Google Play Games in connection with progress restore (Section 6.14), under their own terms and privacy policies.
• Other players: your public leaderboard profile (Section 12).
• Legal and safety reasons: where required by law, court order or lawful request, or where necessary to protect the rights, property or safety of GemuZen, our players or others, including to prevent fraud and abuse.
• Business transfers: if the Game or GemuZen Studio is involved in a merger, acquisition, sale of assets or similar transaction, your information may be transferred as part of that transaction, subject to this Privacy Policy or a notice to you.
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

17. Third-Party Services

The Game relies on the following third-party services. Each provider processes data under its own terms and privacy policy:

• Google Firebase (Anonymous Authentication, Cloud Firestore, Cloud Functions, Analytics, Crashlytics): firebase.google.com/support/privacy
• Google AdMob and Google's User Messaging Platform: policies.google.com/technologies/partner-sites
• Cloudflare (hosting and security of our Website): cloudflare.com/privacypolicy
• Google Privacy Policy (including Google Play, Google Play Billing and Google Play Games): policies.google.com/privacy
• Apple (App Store, if available): apple.com/legal/privacy

Links to our website and social media pages open in your browser. When you visit third-party websites or social networks, their own privacy policies apply.

18. International Data Transfers

We are based in the Republic of Azerbaijan, and our service providers, in particular Google, process data on servers located in the United States and other countries. Our cloud database (Cloud Firestore) is hosted in Google's United States multi-region, and our server functions (Cloud Functions) run in Google's European Union region in Belgium. This means your personal data may be transferred to and processed in countries whose data protection laws may differ from those in your country.

Where required, we rely on appropriate safeguards for such transfers, such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum), adequacy decisions, and, where applicable, the EU–U.S. Data Privacy Framework (and its UK and Swiss extensions) under which Google LLC is certified. You can contact us to learn more about these safeguards.

Recipient	Country	Data	Purpose	Retention
Google LLC (Firebase)	United States and other countries where Google operates	Anonymous game ID, cloud save data, leaderboard profile, purchase records, analytics data, crash reports	Cloud save, leaderboards, authentication, purchase verification, analytics, crash reporting	See Section 19
Google LLC (Google Play Billing, Google Play Games Services)	United States and other countries where Google operates	Purchase and transaction information; a pseudonymous identifier used to link your game ID to your Play Games profile	Processing payments, verifying purchases, restoring progress	According to Google's policies (our own purchase records: see Section 19)
Google LLC (AdMob)	United States and other countries where Google operates	Advertising ID, IP address, device and ad interaction data, consent status	Delivering and measuring ads, fraud prevention	According to Google's policies
Google LLC (Google Analytics, Website only, with your consent)	United States and other countries where Google operates	Pages visited, browser and device information, approximate location, cookie identifiers	Counting visits to the Website	14 months
Cloudflare, Inc. (Website)	United States and other countries in Cloudflare's global network	IP address and technical request data	Delivering the Website and protecting it against attacks and abuse	According to Cloudflare's policies (generally a short period)

Recipients' contact details: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (privacy contact: Google privacy help center); Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA (contact details in its privacy policy).

Transfers happen electronically when you use the Game while connected to the internet. You can stop these transfers by deleting your account and data and uninstalling the Game.

19. Data Retention

We keep personal data only as long as necessary for the purposes described in this Privacy Policy:

• Data on your device: until you delete your account and data, clear the app's storage or uninstall the Game.
• Cloud save data and leaderboard profile: for as long as you use the Game, and until you delete your account and data. We may delete cloud data associated with anonymous game IDs that have been inactive for more than 24 months.
• Analytics data: event-level analytics data is kept for up to 14 months and then deleted or aggregated.
• Crash reports: up to 90 days.
• Google Play Games link (Section 6.14): until you delete your account and data, or until we delete inactive cloud data as described above.
• Authentication logs (IP address and user agent): kept by Google for a few weeks.
• Website: Google Analytics data (only with your consent) for up to 14 months; your cookie choice for 12 months; Cloudflare security logs according to Cloudflare's policies.
• Advertising data: retained by Google according to Google's policies.
• Purchase records (Section 6.7): for as long as required by tax, accounting and consumer protection laws and as needed to handle refunds, disputes and fraud prevention. They are kept even if you delete your account and data.
• Support communications: up to 24 months after your request has been resolved, unless a longer period is required by law.

After data is deleted, Google removes it from its live and backup systems within up to 180 days. We may retain information for longer where required by law or to establish, exercise or defend legal claims. Aggregated or de-identified information may be kept indefinitely.

20. Deleting Your Account and Data

You can delete your data at any time, free of charge:

• In the Game: open Settings → Delete Account & Data and confirm. This immediately deletes your cloud save data and your leaderboard entry, removes the link to your Google Play Games profile (if any), deletes your anonymous game ID (or, if that cannot be completed at that moment, disconnects it from your device so that it is no longer linked to any game data), resets the analytics and crash-reporting identifiers on your device, and clears the Game's data on your device. An internet connection is required so that the cloud data can be deleted.
• Without the Game: visit gemuzen.com/delete-account or email info@gemuzen.com with the subject "Delete my data" and include your in-game nickname and, if possible, your approximate last play date and device model. Because accounts are anonymous, we may need this information to locate your data. We will complete verified requests within 30 days.

Please note that deletion is permanent: your progress, coins, items and cards cannot be restored afterwards. Purchase records (those held by app stores and our own purchase records described in Section 6.7), data held by Google as an independent controller (for example for advertising), usage and crash data that was already sent (which is deleted when the retention periods in Section 19 expire and is no longer linked to your new installation), and information we must keep by law are not deleted by this process. Residual copies may remain in Google's backup systems for up to 180 days before they are overwritten. If you reinstall the Game after deletion, a new anonymous game ID will be created.

21. Data Security

We use reasonable technical and organizational measures to protect your information, including encrypted connections (HTTPS/TLS), access controls and security rules that allow only your installation of the Game to access your private cloud save, validation of the data that can be written to our database, and collecting as little data as possible. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a personal data breach that affects you, we will notify you and the competent authorities where required by law.

22. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your personal data:

• Access: to know whether we process your data and to receive a copy of it;
• Correction: to correct inaccurate data (you can change your nickname and flag directly in the Game);
• Deletion: to have your data deleted (see Section 20);
• Portability: to receive your data in a structured, commonly used format;
• Restriction and objection: to limit or object to certain processing, including processing based on legitimate interests;
• Withdrawal of consent: to withdraw consent at any time, for example for usage and crash data (in the Game's Settings) or for personalized ads (see Section 11);
• Opt-out: to opt out of targeted advertising, "sale" or "sharing" of personal information (see Section 23); and
• Complaint: to lodge a complaint with a data protection authority in your country of residence, place of work or where an alleged infringement occurred.

How to exercise your rights. Email info@gemuzen.com. Because the Game does not use accounts with names or emails, we may ask you for information that helps us locate your data (such as your nickname, approximate last play date and device model) and to verify that the request comes from you. If we cannot reasonably verify a request or locate the data, we will explain why. We will respond within the time required by applicable law (generally within one month in the EEA and UK, and within 45 days under U.S. state laws, which may be extended where permitted). We will not discriminate against you for exercising your rights.

Authorized agents and appeals. Where permitted by law, you may use an authorized agent to make a request on your behalf; we may ask for proof of the agent's authority. If we decline your request, you may appeal by replying to our response with the subject "Appeal". If you are not satisfied with the outcome of your appeal, you may contact the attorney general or data protection authority of your state or country.

23. Additional Information for U.S. Residents

This section supplements this Privacy Policy for residents of U.S. states with comprehensive privacy laws, including California (CCPA/CPRA), Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Nebraska, Indiana, Kentucky and Rhode Island, to the extent those laws apply to us.

Categories of personal information collected in the last 12 months (sources: you, your device and our service providers):

Category	Examples	Disclosed for a business purpose to	Sold or shared
Identifiers	Anonymous game ID, app-instance ID, Crashlytics installation ID, advertising ID, IP address	Google (service provider)	Advertising ID and IP address may be shared with Google AdMob for targeted advertising, where permitted
Commercial information	In-app purchase records	App stores; Google	No
Internet or other electronic network activity	Gameplay and app usage events, ad interactions	Google (service provider)	Ad interaction data may be shared with Google AdMob
Approximate geolocation	Country or region derived from IP address (not precise location)	Google (service provider)	May be used by Google AdMob for ad delivery
Profile information you choose to make public	Nickname, flag, avatar, best score	Other players (leaderboard)	No
Sensitive personal information	None collected	—	No

Purposes. We collect and use these categories for the purposes described in Section 9. We do not use or disclose sensitive personal information, and we do not create inferences to profile you.

"Sale" and "sharing". We do not sell personal information for money. However, allowing Google AdMob to use advertising identifiers and related data for personalized advertising may be considered a "sale" or "sharing" for "targeted" or "cross-context behavioral" advertising under some state laws. To opt out, reset or delete your advertising ID (Android) or turn off tracking (iOS) as described in Section 11, use the privacy options in the Game's settings where available, or email us with the subject "Do not sell or share my personal information". We do not knowingly sell or share the personal information of consumers under 16 years of age, and we do not knowingly use the personal information of users under 18 for targeted advertising (see Section 25).

Retention. See Section 19.

California "Shine the Light". We do not disclose personal information to third parties for their own direct marketing purposes as defined by California Civil Code § 1798.83.

California minors. If you are under 18 and live in California, you may remove content you have made public in the Game (such as your nickname on the leaderboard) by deleting your account and data or by contacting us. Removal does not ensure complete or comprehensive removal of content that others may have copied.

Nevada. We do not sell "covered information" for monetary consideration as defined under Nevada law. Nevada residents may nevertheless submit an opt-out request to info@gemuzen.com.

Financial incentives. Optional in-game rewards (for example for watching a rewarded ad or sharing the Game) are not offered in exchange for personal information, and you can enjoy the Game without taking part in them.

24. Additional Information for Other Regions

• Brazil (LGPD): you may exercise the rights provided in Article 18 of the LGPD, including confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing and revocation of consent, by contacting us. You may also file a complaint with the ANPD.
• Canada: you may request access to and correction of your personal information and withdraw consent, subject to legal limitations, and you may contact the Office of the Privacy Commissioner of Canada.
• Republic of Korea: details of overseas transfers (items, destination countries, time and method of transfer, recipients and their contact details, purposes, retention periods and how to refuse) are provided in Section 18. You may request access, correction, deletion or suspension of processing by contacting us. The person responsible for privacy matters is Taleh Sadıqov (info@gemuzen.com).
• Japan: personal data may be provided to recipients in foreign countries as described in Section 18. You may request disclosure, correction or cessation of use under the Act on the Protection of Personal Information.
• Türkiye: you may exercise the rights set out in Article 11 of the Law on the Protection of Personal Data No. 6698 (KVKK) by contacting us, and you may lodge a complaint with the Personal Data Protection Authority (KVKK).
• India: to the extent the Digital Personal Data Protection Act, 2023 applies, you may request access, correction, completion and erasure of your personal data, use our grievance channel at info@gemuzen.com, nominate another person to exercise your rights, and complain to the Data Protection Board of India.
• Republic of Azerbaijan: you have the rights provided by the Law "On Personal Data", including the right to know whether your data is processed, to access it, and to have it corrected, blocked or deleted.
• Other countries: we respect the rights granted by applicable local data protection laws. Please contact us to exercise them.

25. Children and Age Requirements

GemuZen is a puzzle game designed for a general audience. However, the Game is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (or under the higher age of digital consent that applies in some countries, such as up to 16 in parts of the EEA) without verifiable parental consent where required.

If you are a parent or guardian and believe that your child has provided personal information to us, please contact us at info@gemuzen.com or use the in-game deletion option. If we learn that we have collected personal information from a child in violation of applicable law, including the U.S. Children's Online Privacy Protection Act (COPPA), we will delete it promptly and may limit the child's use of personalized features such as personalized ads.

If we know that a user is under 18 (for example through an app store age signal or a message from a parent), we will not use that user's personal information for personalized advertising and will request only non-personalized ads for that user, to the extent technically possible.

Where laws require app stores to share age or parental-approval information with developers, we will use that information only as described in Section 6.10.

26. Automated Decision-Making

We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you. Game mechanics that use randomness (for example free mystic packs earned during gameplay or through optional rewarded ads, or computer-controlled opponents) apply equally to all players and are not based on profiling. The card offered for direct purchase in the treasure is selected by the Game without regard to who you are, and you always see exactly which card you are buying, at a fixed price, before you spend anything. Fraud and cheat prevention checks may automatically block suspicious in-game changes; you can contact us if you believe this has affected you in error.

27. Do Not Track and Similar Signals

The Game does not track you across other companies' apps or websites for our own purposes. Because there is no common industry standard for "Do Not Track" browser signals, the Services may not respond to them. You can manage advertising preferences as described in Section 11.

28. Our Website and Cookies

Our Website is hosted and protected by Cloudflare, which processes your IP address and technical request data to deliver the Website and protect it against attacks and abuse, and may set strictly necessary security cookies. Only if you accept analytics cookies, Google Analytics collects information such as pages visited, browser and device type, referring website and approximate location. Fonts are served from our own server, so no information is sent to a font provider. For details and choices, please see our Cookie Policy. Non-essential cookies are used only with your consent, and you can change your choice at any time via "Cookie Settings" at the bottom of every page.

29. Your Responsibilities

• Do not use your real name, contact details or any other personal information of yourself or others as your nickname.
• Keep your device secure and up to date; anyone with access to your device may be able to use the Game and its data.
• If you share the Game or screenshots with others, you are responsible for the content you choose to share.
• Parents and guardians should supervise the use of devices and app stores by minors, including purchase and ad settings provided by the device and app store.

30. New Features

We may add new features in the future, such as sign-in with an app store account, remote push notifications or new social features. If a new feature involves new categories of personal data or new purposes, we will update this Privacy Policy before the feature is released and, where required by law, ask for your consent. Until then, those features are not active and the related processing does not take place.

31. App Store Requirements

We aim to comply with the policies of the app stores through which the Game is distributed, including the Google Play Developer Program Policies (such as the User Data policy and Data safety requirements) and, where applicable, the Apple App Store Review Guidelines and App Privacy requirements. The information in our app store privacy labels and Data safety section is intended to be consistent with this Privacy Policy. App stores process data about your downloads, purchases, reviews and account under their own privacy policies, for which they are responsible.

32. Changes to This Policy

We may update this Privacy Policy from time to time, for example when we add features or when laws change. We will post the updated version on this page and update the "Last updated" date. If changes are material, we will provide additional notice, for example in the Game or on our Website, and where required by law we will ask for your consent. We encourage you to review this page periodically.

33. Data Protection Officer

We have not appointed a Data Protection Officer because we are not required to do so under applicable law. All privacy questions and requests are handled directly by us at info@gemuzen.com.

34. Contact Us

If you have questions, requests or complaints about this Privacy Policy or our privacy practices, please contact the controller:

GemuZen Studio — the trading name of Taleh Sadıqov, an individual developer
Republic of Azerbaijan
Email: info@gemuzen.com
Website: gemuzen.com

If you need our full postal address for a formal legal request, please write to the email address above and we will provide it.

This Privacy Policy is written in English. If it is translated into other languages and there is any conflict between versions, the English version will prevail to the extent permitted by applicable law.