1. Data controller and contact details
The data controller responsible for the App is:
- Legal name: Giovanni Auzas
- Trading name: Kaosfx Games
- Business status: Independent developer
- Location: Sassari, Italy
- Privacy email: privacy@kaosfxgames.com
- Support email: support@kaosfxgames.com
- Website: https://www.kaosfxgames.com
Questions and privacy-rights requests should be sent to the privacy email above. We have not appointed a data protection officer or a United Kingdom representative. If this changes, we will update this Policy.
2. Scope and summary
This Policy applies to the iOS version of Gems GO! made available through the Apple App Store in all selected territories except Mainland China. Gems GO! is intended for users aged 13 and older, carries the corresponding App Store age rating, and is not listed in Apple's Kids Category. A younger user may still obtain access through an Apple parental exception or an inaccurate age declaration; the App therefore keeps the under-13 protections described below.
- You do not need to create an account to play.
- The App does not use Game Center, cloud save, leaderboards, social features, chat, user-generated content, or marketing email.
- We do not ask for your name, email address, phone number, contacts, photos, camera, microphone, health data, or precise GPS location in order to play.
- Game progress, settings, and the privacy profile described below are stored locally on your device.
- Before third-party advertising or analytics SDKs may start, the App asks Apple whether age assurance is required for the current region and account. It does not ask us to collect your exact age or date of birth.
- If Apple reports that age assurance is not required, the App does not ask the user to select an age range. Optional analytics still requires a separate choice, and optional rewarded ads remain non-personalized and subject to Google UMP.
- For known users under 13 and users whose age remains unresolved when age assurance is required, Google AdMob, Google User Messaging Platform ("UMP"), GameAnalytics, and all ad offers remain disabled.
- Users aged 13–17 may be offered optional contextual rewarded ads capped at Google's Teen (T) content rating, where legally permitted. Personalized ads and GameAnalytics remain disabled for them.
- Adults may be offered optional non-personalized rewarded ads after the applicable Google UMP consent and privacy choices. The App does not request Apple tracking permission, access IDFA, or enable cross-app tracking.
- GameAnalytics is available only after a separate, explicit analytics choice, and remains disabled for known users under 18.
- The App does not offer in-app purchases or subscriptions at launch.
Third-party providers may treat technical identifiers, device information, approximate location, and activity records as personal data even when neither we nor they receive your real name.
3. Information processed
3.1 Information stored locally on your device
The App stores information needed to operate and restore the game, including:
- game progress, completed levels, stars, experience points, unlocked locations, inventory, virtual items, and rewards;
- the current game session, route, level state, tutorial state, and discovery status;
- audio, music, haptic, accessibility, and gameplay settings;
- a normalized age-related privacy profile: Under 13, 13–17, Adult, Age assurance not required, or Most private;
- whether the age profile came from Apple's age-range service, Apple's eligibility check, or a local selection, without retaining the raw Apple response;
- the optional analytics choice where it is available; and
- advertising-consent and privacy-choice status, where advertising is permitted.
This information is stored in the App's local iOS storage, including Application Support files and UserDefaults. We do not operate an account or cloud-save system for it. Resetting the game, deleting the App, or erasing its data may permanently remove it, subject to backup and restore functions controlled by Apple.
3.2 Age assurance and privacy profile
On iOS 26.2 and later, the App first asks Apple's age-assurance service whether an age-range request is required. If Apple reports that age assurance is not required for the current region and account, the App records only that age assurance was not required and does not request an age range or infer the user's age. If age assurance is required, the App asks Apple for a Declared Age Range using the thresholds 13 and 18. Apple controls the system request and may provide a self-declared, parent/guardian-provided, or otherwise confirmed range according to Apple's service. The App immediately reduces a shared result to Under 13, 13–17, or Adult.
We do not retain Apple's raw lower or upper age bounds, the declaration method, Apple Account information, identity documents, exact age, or date of birth. If the Apple service is unavailable, including on older supported iOS versions, or if sharing is declined, the App offers the same local age bands and a Prefer not to answer option.
If the Apple check takes longer than expected, the App offers a choice to continue with the most-private settings. Choosing it records an undisclosed age profile and keeps advertising and analytics disabled. A late Apple response does not override that choice. You can review the profile later in Settings.
The resulting privacy profile controls whether optional SDKs may start:
| Privacy profile | Analytics | Advertising |
|---|---|---|
| Under 13 | GameAnalytics remains disabled | AdMob, UMP, and ad offers remain disabled |
| Age 13–17 | GameAnalytics remains disabled | Optional contextual rewarded ads only where legally permitted; no personalization or publisher first-party ad identifier |
| Adult | Available only after separate explicit analytics opt-in | Optional non-personalized rewarded ads after applicable UMP choices; no IDFA, publisher first-party ad identifier, or cross-app tracking |
| Apple reports age assurance is not required | Available only after separate explicit analytics opt-in | Optional non-personalized rewarded ads after applicable UMP choices; no IDFA, publisher first-party ad identifier, or cross-app tracking |
| Prefer not to answer / unresolved | GameAnalytics remains disabled | AdMob, UMP, and ad offers remain disabled |
An Apple response that age assurance is not required is not a confirmation that the user is an adult. The App keeps it as a separate profile, offers a separate analytics choice, and applies the non-personalized advertising controls described here.
We do not send the selected age band or its source to GameAnalytics. Google receives only the age-related treatment signals needed to enforce the teen advertising configuration when an eligible teen requests an ad. Choosing not to provide an age range does not restrict the core game.
3.3 GameAnalytics data
GameAnalytics is initialized only after a user has been classified as an adult, or Apple has reported that age assurance is not required, and the user separately selects Share Analytics. When enabled, the GameAnalytics SDK may process:
- pseudonymous identifiers: a random identifier generated for this App installation after opt-in, together with identifiers generated by the SDK as necessary to provide the service; the App does not configure GameAnalytics with advertising identifiers;
- device and connection information: IP address, approximate country or region inferred from it, device type and model, operating-system version, device language or locale, App version, build number, SDK version, network, and platform information;
- session and interaction information: App launches, session start, end and duration, screens viewed, menu actions, tutorial activity, and returning or new-session indicators;
- gameplay information: level starts, failures and completions, scores, stars, moves, progression, locations, retries, chain or combo statistics, power-up use, virtual-currency and inventory flows, and reward activity;
- advertising events: rewarded-ad request, load, display, click, failure, dismissal, reward, placement, and approximate display duration;
- diagnostic and performance information: error categories and short technical error messages, SDK initialization information, crash or diagnostic data made available by the SDK, frames-per-second statistics, memory statistics, and related technical health information; and
- bounded privacy state: a limited consent or availability state used to understand whether optional analytics or advertising functions were available, without the user's age range.
We do not intentionally send GameAnalytics a name, email address, phone number, precise location, Apple Account, account username, exact age, or date of birth. GameAnalytics may nevertheless associate gameplay and technical records with a pseudonymous installation or SDK identifier.
GameAnalytics acts as an analytics service provider or processor for us. Users for whom analytics is available can stop future collection immediately in Settings > Privacy & Age. The App then disables event submission and local SDK caching.
3.4 Google AdMob and UMP data
The App offers optional rewarded ads supplied through Google AdMob after the applicable privacy setup. Known users under 13 and users with an unresolved or undisclosed age profile receive no AdMob or UMP initialization and no ad offers.
When enabled for an eligible teen, adult, or profile for which Apple reports age assurance is not required, Google Mobile Ads and UMP may process:
- IP address and approximate location inferred from the IP address;
- device, application, operating-system, language, network, and SDK information;
- app- or device-related identifiers used to deliver, measure, secure, and prevent fraud in non-personalized advertising; the App disables Google's publisher first-party ad identifier and does not request permission to access IDFA;
- advertising data, such as ads requested, available, shown, viewed, clicked, completed, dismissed, or rewarded;
- App and product interactions, including App launches, taps, ad placement, and video views;
- crash logs, diagnostic information, App launch time, hang rate, energy usage, performance information, and fraud or invalid-traffic signals; and
- consent choices, regulatory-region signals, IAB consent strings, and privacy-message interactions.
Google may use this information to deliver and measure non-personalized, contextual, or limited ads, limit repetition, detect fraud and abuse, maintain security, analyze performance, and improve its services. Ad selection may be automated.
For users aged 13–17, the App applies Google's under-age/teen treatment before an ad request, caps ads at Google's Teen (T) content rating, and disables ad personalization and the publisher first-party identifier. Only contextual rewarded ads are offered, where local law and Google's services permit them.
For adults and profiles for which Apple reports age assurance is not required, the App uses Google UMP to present applicable consent and privacy choices before requesting ads. All rewarded-ad requests remain non-personalized, the publisher first-party ad identifier remains disabled, and the App does not request Apple tracking permission, access IDFA, or enable cross-app tracking. If an ad cannot lawfully or technically be provided, the rewarded-ad offer is hidden.
We do not configure third-party AdMob mediation networks or mediation adapters. Google may still use companies within its own advertising ecosystem, service providers, or authorized buyers as described in Google's policies. Even contextual or limited ads require some technical processing, such as transmitting an IP address to deliver an ad and using security signals to prevent fraud.
Advertising choices and gameplay analytics consent are independent. Declining or withdrawing gameplay analytics does not by itself disable eligible rewarded ads, and completing Google's privacy choices does not opt you into GameAnalytics. Google determines whether an ad request is permitted from the applicable privacy choices; declining personalization does not necessarily prevent contextual or limited ads. The App keeps personalization disabled even if a Google message offers broader consent choices.
If advertising privacy choices take longer than expected to load, you may continue without ads for that session. This does not change your age profile or analytics choice, and it does not save a permanent withdrawal of your Google privacy choices. On a later launch, the App checks advertising availability again.
To select whether rewarded advertising is available and whether to use test or live ads, the App may fetch a small configuration file from our website. This request exposes ordinary connection information, such as the IP address, to the website hosting provider. The App does not add your age profile or analytics installation identifier to this request. Test ads still involve Google's services and do not remove the privacy controls described in this Policy.
Where required, Settings > Privacy & Age provides access to Google's UMP privacy choices.
3.5 Apple platform and App Store data
Apple processes the Declared Age Range request, App Store downloads and updates, device or Apple Account activity, and other Apple platform services under Apple's own privacy policy. We receive only the age-range result Apple makes available to the App and immediately normalize it as described above.
The App does not offer in-app purchases or subscriptions at launch, and we do not receive payment-card details from Apple.
3.6 Information you provide to us
If you contact us for support or submit a privacy request, we may receive your name, email address, message, attachments, device or App information you choose to provide, and the history of our correspondence. Please do not send sensitive information that is not needed to handle your request.
4. Purposes and legal bases
Where the GDPR, UK GDPR, or similar laws apply, the typical purposes and legal bases are:
| Processing purpose | Typical legal basis |
|---|---|
| Operate the App, restore local progress, provide rewards, and maintain settings | Performance of a contract or steps requested by you; legitimate interests in providing a functional App |
| Determine and enforce an age-appropriate privacy profile | Compliance with legal obligations; substantial interests in protecting minors and providing an age-appropriate service; performance of the service requested |
| Provide contextual or limited rewarded ads to eligible teens and adults, measure delivery, prevent fraud, and maintain security | Consent where device access or local law requires it; otherwise legitimate interests in funding, securing, and measuring the App |
| Analyze gameplay, retention, balance, feature use, errors, crashes, memory, and performance through GameAnalytics | Separate, explicit consent where the analytics option is available |
| Respond to support and privacy requests | Performance of a contract, legitimate interests in responding, and compliance with legal obligations |
| Prevent abuse and establish, exercise, or defend legal claims | Legitimate interests; compliance with legal obligations |
Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal. Where we rely on legitimate interests, you may object as described below.
5. How information is disclosed
We may disclose information to:
- Google (AdMob and UMP) — for eligible teen or adult profiles, or when Apple reports that age assurance is not required, to deliver rewarded ads, manage privacy choices, measure advertising, maintain security, and prevent fraud. See Google's Privacy Policy and How Google uses information from sites or apps that use its services.
- GameAnalytics — only after an explicit analytics opt-in where the analytics option is available, to provide game analytics, session measurement, gameplay and advertising-event reporting, diagnostics, and performance analysis. See the GameAnalytics Privacy Notice and GameAnalytics Developer Policy.
- Apple — to distribute and update the App and operate the age-range and other Apple platform services. See Apple's Privacy Policy.
- Professional advisers and operational vendors — such as legal, accounting, security, website hosting, email, or support providers, only where needed and subject to appropriate obligations.
- Authorities or other parties required by law — when necessary to comply with law, protect rights and safety, investigate abuse, or establish or defend legal claims.
- A successor in a business transaction — in connection with a merger, acquisition, reorganization, asset transfer, or similar transaction, subject to applicable law and notice requirements.
We do not sell personal information for money, and we do not configure the App to use personal information for personalized or cross-context behavioral advertising. Technical disclosure to Google for non-personalized ad delivery may nevertheless fall within a regulated category under some U.S. state laws. Where applicable, users may exercise available choices through the App's Google UMP privacy controls or by contacting us.
6. Tracking, profiling, and automated decisions
The App does not request Apple App Tracking Transparency permission, access IDFA, enable Google's publisher first-party ad identifier, or permit cross-app tracking for any age profile.
GameAnalytics uses a random App-installation identifier supplied only after explicit analytics opt-in, rather than an advertising identifier.
Google may use automated systems to select and measure non-personalized ads and detect fraud. We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you.
7. Your choices and controls
- Age-related privacy: Open Settings > Privacy & Age to review or change the normalized privacy profile. Changing it does not reset gameplay or progress.
- Gameplay analytics: Users for whom the analytics option is available can enable or stop GameAnalytics in Settings > Privacy & Age. Stopping it prevents future event submission and SDK caching. Analytics remains unavailable for known users under 18 and unresolved profiles.
- Advertising privacy choices: Eligible users can open Settings > Privacy & Age and select Privacy Choices when Google UMP requires that entry.
- Advertising mode: The App requests only non-personalized rewarded ads and does not request Apple tracking permission or access IDFA.
- Google ad controls: Adults may also use My Ad Center and Google's partner-app information page linked above.
- Provider-held pseudonymous data: You may contact privacy@kaosfxgames.com about information already held by a provider. Because the App has no account and does not display its internal analytics identifier, we may be unable to associate a provider's pseudonymous record with you. We will explain any identification limitation and assist where reasonably possible.
- Local data: Use any in-App reset option that is available, or delete the App to remove local game data, subject to Apple backup and restore behavior.
- Marketing: We do not operate a marketing mailing list through the App.
Deleting the App stops future App-originated collection but does not automatically erase information already held by a provider. Browser "Do Not Track" settings do not directly control native mobile apps. Applicable Global Privacy Control or opt-out signals may be honored by providers in contexts where they receive them.
8. Retention
We retain information only for as long as reasonably necessary:
- local game progress, settings, and privacy choices remain until you reset them, delete the App, or the operating system removes them;
- advertising consent records remain until they expire, are refreshed, or are withdrawn, and may be retained as needed to demonstrate compliance;
- identifiable or pseudonymous GameAnalytics event and technical data is retained for no more than 12 months from collection;
- statistics that have been irreversibly aggregated or anonymized may be retained longer because they no longer identify or single out a user;
- Google retains advertising and related information according to its own policies, settings, consent state, and legal obligations; and
- support and privacy-request correspondence is ordinarily deleted 30 days after the request is closed, unless a longer period is required to comply with law, demonstrate how a request was handled, resolve a dispute, prevent abuse, or establish, exercise, or defend legal claims.
The App does not create purchase, subscription, refund, payment, accounting, or tax records at launch.
9. International transfers
Google, GameAnalytics, Apple, and their subprocessors may process information in countries other than your country of residence, including the United States. Privacy laws in those countries may differ from local law.
Where required, transfers from the European Economic Area, United Kingdom, or Switzerland are based on recognized safeguards such as adequacy decisions, Standard Contractual Clauses, the United Kingdom Addendum, or another lawful transfer mechanism. You may contact us for more information about applicable safeguards.
Gems GO! is not offered in Mainland China. We will review applicable hosting, localization, consent, data-transfer, and regulatory requirements before making the App available there.
10. Security
We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information. Local save data is protected by the security features of your device and iOS. Network communications by integrated SDKs use their platform security measures.
No storage or transmission method is completely secure. We cannot guarantee absolute security. You are responsible for maintaining the security of your device and Apple Account.
11. Your privacy rights
Depending on where you live, you may have rights to:
- be informed about processing;
- access and obtain a copy of personal data;
- correct inaccurate or incomplete personal data;
- request deletion;
- restrict or object to processing;
- receive certain data in a portable format;
- withdraw consent;
- opt out of sale, sharing, targeted advertising, or certain profiling;
- appeal the denial of a request where applicable; and
- lodge a complaint with a competent privacy or data-protection authority.
To exercise a right, email privacy@kaosfxgames.com and state that your request concerns Gems GO!. We may ask for limited information needed to verify and handle the request. Because the App has no user account and does not expose an analytics identifier, we may be unable to identify records held only under a provider-generated pseudonym. We will not request more information than reasonably necessary, and we will explain if we cannot identify the relevant record. Rights are subject to applicable legal conditions and exceptions.
European Economic Area, United Kingdom, and Switzerland
You may exercise the GDPR or UK GDPR rights listed above. You may also complain to the supervisory authority in your country. In Italy, the authority is the Garante per la protezione dei dati personali.
United States
Residents of California and other U.S. states with applicable privacy laws may request access, correction, deletion, portability, and information about categories of data, purposes, and recipients. They may also opt out of sale or sharing, targeted advertising, or certain profiling, and may have a right to appeal. We will not discriminate against you for exercising an applicable right. Authorized agents may submit requests where permitted, subject to verification.
Australia
Where the Australian Privacy Act applies, users may request access to or correction of personal information and may complain to us about our handling of it. If a complaint is not resolved, they may contact the Office of the Australian Information Commissioner.
Brazil and other jurisdictions
Where applicable, users may request confirmation of processing, access, correction, anonymization, portability, deletion, information about disclosure, and withdrawal of consent, and may contact the relevant local authority, including Brazil's ANPD.
12. Children's and teenagers' privacy
Gems GO! is intended for users aged 13 and older and is not directed to children under 13. It may nevertheless be accessed by a younger user through an Apple parental exception or an inaccurate age declaration, so the App does not treat the storefront rating alone as proof of age.
For users under 13, the App does not initialize GameAnalytics, AdMob, or UMP and does not offer ads. The full non-ad game, local save, progression, audio, haptics, accessibility, and gameplay settings remain available.
For users aged 13–17, GameAnalytics, personalized ads, and publisher first-party ad identifiers remain disabled. Where legally permitted, the App may offer optional contextual rewarded ads configured with Google's teen or under-age treatment and capped at Google's Teen (T) content rating. If an age-appropriate ad cannot lawfully or technically be provided, the offer is hidden.
Because the App does not collect personal information through advertising or analytics from known users under 13, it does not use a parental-consent flow for those features. If a child sends personal information through a support email, a parent or guardian may contact us so that we can investigate and delete it where appropriate.
If the intended audience, SDK configuration, or data practices change, we will update the App's safeguards, consent flows, App Store disclosures, and this Policy before the change takes effect.
13. Third-party advertisements and links
Rewarded advertisements shown to eligible teens or adults may link to third-party websites, applications, or stores. Those third parties control their own processing. Review their privacy notices before providing information. We are not responsible for third-party content or privacy practices outside the App, except as required by law.
14. Changes to this Policy
We may update this Policy when the App, providers, legal requirements, or data practices change. We will update the date at the top and, where required, provide additional notice or request new consent. Material changes apply prospectively unless applicable law permits otherwise.
15. Contact us
For privacy questions, objections, consent withdrawal, complaints, or rights requests:
- Giovanni Auzas, independent developer operating as Kaosfx Games
- Sassari, Italy
- Privacy: privacy@kaosfxgames.com
- Support: support@kaosfxgames.com
- Website: https://www.kaosfxgames.com