Privacy Policy
This Privacy Policy describes how GEMEGAME LIFESTYLE AND HOBBY SDN. BHD. ("we", "us", "our", or "GEMEGAME Studios"), a private limited company registered in Malaysia, collects, uses, stores, shares, and protects information when you ("you" or "user") use any mobile game, application, or website (the "Services") we publish under the GEMEGAME Studios brand.
By accessing or using our Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.
1. Information We Collect
We collect information in three ways: information you provide to us directly, information collected automatically when you use our Services, and information from third-party sources.
1.1 Information You Provide
- Account information: if you create an account or sign in, we may collect your email address, display name, and authentication tokens.
- Communications: when you contact us for support or feedback, we receive your email and any information you choose to share.
- Purchase information: in-app purchases are processed by Apple App Store or Google Play Store. We receive a purchase token and transaction ID, but never your full payment card details.
1.2 Information Collected Automatically
- Device information: device model, operating system version, language, country, mobile carrier, screen resolution, and a non-identifying device advertising identifier (IDFA / GAID).
- Gameplay analytics: anonymised data about how you interact with our games, including session length, levels played, in-game choices, performance metrics, and crash reports.
- IP address and approximate location: your IP address is used to estimate the country or region you are playing from, for content localisation and regulatory compliance.
1.3 Information from Third Parties
If you choose to sign in using a third-party service (e.g. Google Sign-In, Apple Sign-In, or a social network), we may receive limited profile information (email, public profile name, avatar URL) as authorised by you.
2. How We Use Information
We use the information we collect to:
- Operate, maintain, and improve our games and services;
- Personalise your in-game experience (e.g. difficulty calibration, progress saving, localisation);
- Process in-app purchases and prevent fraudulent transactions;
- Diagnose crashes, performance issues, and security incidents;
- Communicate with you about updates, support requests, and policy changes;
- Display relevant advertisements (where applicable, see Section 4);
- Comply with applicable legal obligations under the laws of Malaysia and other jurisdictions where we operate.
3. Children's Privacy
Our games are not directed at children under the age of 13 (or under the age of 16 where applicable under the EU General Data Protection Regulation), and we do not knowingly collect personal information from children under that age.
If we learn that we have collected personal information from a child without verified parental consent, we will delete that information promptly. Parents or guardians who believe their child has provided information to us may contact the address in Section 10 to request deletion.
For titles classified as "Designed for Families" or as having a "Mixed Audience" under the Google Play Families Policy, we apply additional safeguards including non-personalised advertising and disabled cross-app tracking.
4. Advertising and Third-Party SDKs
Some of our games are supported in part by advertising. When you view advertisements in our games, the following third-party services may collect data subject to their own privacy policies:
- Google AdMob: policies.google.com/privacy
- Unity Ads / Unity Analytics: unity.com/legal/privacy-policy
- Firebase Analytics and Crashlytics (Google): firebase.google.com/support/privacy
- Apple App Analytics: apple.com/legal/privacy
On iOS, we comply with Apple's App Tracking Transparency framework. We will request your permission before any cross-app tracking takes place. On Android, you may reset or limit your Google Advertising ID at any time via your device settings.
5. Data Sharing
We do not sell your personal information. We share information only in the following limited circumstances:
- Service providers: cloud hosting, analytics, crash reporting, advertising networks, and customer support tools that process information on our behalf and under contract.
- Legal requirements: when required by valid court order, law enforcement request, or to protect our legal rights or the safety of users.
- Business transfers: in the event of a merger, acquisition, or sale of assets, your information may be transferred under the terms of this Policy.
6. Data Retention
We retain personal information for as long as necessary to provide the Services and fulfil the purposes outlined in this Policy, unless a longer retention period is required by law. Anonymised analytics data may be retained indefinitely. You may request deletion of your data at any time (see Section 8).
7. Security
We use industry-standard administrative, technical, and physical safeguards designed to protect your information from unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.
8. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Right to access a copy of the information we hold about you;
- Right to correct inaccurate information;
- Right to deletion ("right to be forgotten");
- Right to restrict or object to certain types of processing;
- Right to data portability;
- Right to withdraw consent at any time;
- Right to lodge a complaint with the relevant data protection authority.
To exercise any of these rights, please contact us at the address in Section 10. We will respond within a reasonable period and in accordance with applicable law, including the Malaysian Personal Data Protection Act 2010 (PDPA).
9. International Data Transfers
Our games are available globally and our service providers operate in multiple jurisdictions. By using our Services, you understand that your information may be transferred to, processed, and stored in countries outside of Malaysia, including jurisdictions that may have different data protection laws. We take reasonable steps to ensure that such transfers comply with applicable law.
10. Contact Us
If you have any questions, comments, or requests regarding this Privacy Policy or our data practices, please contact us:
GEMEGAME LIFESTYLE AND HOBBY SDN. BHD.
(operating as GEMEGAME Studios)
A-12-16, Pinnacle Petaling Jaya,
Jalan Utara C,
46200 Petaling Jaya,
Selangor, Malaysia
Email: [ EMAIL ADDRESS TO BE ADDED ]
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, our games, or applicable law. The "Effective Date" at the top of this Policy indicates when this version came into effect. We encourage you to review this Policy periodically. Continued use of the Services after a change indicates your acceptance of the updated Policy.