Effective date: March 20th, 2019
We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security and others to make sure that no decision is taken without respect for your privacy.
We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
If you do not want to receive tailored in-application advertisements from third parties, please see – How to Access, Update and Manage Your Information—Opting Out of Third Party Tailored Advertising.
- What information we collect and how we collect it;
- How we use that information;
- Legal bases for use of your information;
- How we share and disclose your information;
- Data subject rights and your choices;
- Third party links and features;
- Children’s privacy;
- Transfer of information to other countries;
- How long we keep your information;
- How we protect the information we store about you;
- California privacy rights;
- How to contact us.
Information We Collect and How We Collect It
The information we collect about you falls into two categories: information you provide directly to us, and information we collect automatically.
1. Information about You That You Share with Us Directly
a. Account and Profile Information
Some apps or parts of our Services use a registration or account set-up process where you will be asked to give us certain information, including:
- your age or birthday;
- your first and last names;
- your e-mail address;
- a password; and
- other information so we can authenticate you or so we can improve our services.
We may also let you create a player profile, separate from your social networking site profile that other GemX FP players can see. Your player profile will include the following information you provide us:
- a profile photo;
- a username(s);
- your gender;
- biographic details (like your age or age range); and
- the approximate location that you provide.
If you create a player profile, we will automatically collect certain information, including:
- if you sign in through or link your social media profile, information associated with your profiles on that social network;
- details about the apps you play; and
- a GemX FP player ID number that is created by GemX FP and used to identify your profile.
Certain apps allow certain information in your GemX FP player profile to be publicly accessible, including:
- The GemX FP player ID;
- Your first and last names; and
- Your player profile picture.
b. Information about your contacts
Certain of our Services give you the ability to import your address book contacts, including names, e-mail addresses, and social media handles, if available, or manually enter them so that you can find your contacts on GemX FP and invite them to play our apps or to other of our Services. You are responsible for obtaining your contacts’ permission when you choose to provide their contact information to us. We may receive information about you from other GemX FP users who import or manually share their contacts. We use and may store any or all of this contact information to enable you and your contacts to connect through all of our Services. If you want to remove the contacts stored in our apps or Services, follow the instructions provided in the particular app or Service to request that we remove them from our systems for that app or Service. If you have provided us your contacts in multiple apps or Services and want to remove those contacts from all apps and Services, you will need to take this step in each app or Service. If you need to enter a password to allow us to access your address book, we will not store that password.
c. Information You Generate Using Our Communications Features
Certain of our Services allow you to communicate or share information with GemX FP and with other GemX FP players. These features include:
- player forums, message boards and chat function;
- the ability to post public comments to other players’ profiles;
- private messaging;
- the ability to send invitations to other players, either directly on our websites or to their e-mail accounts; and/or
- photo or drawing sharing.
You acknowledge and expressly agree that we may access in real-time, record and/or store any of these communications, comments, photos, and drawings on our servers. We use these communications to protect the safety and well-being of our players and GemX FP ‘s rights and property in connection with our Services; to conduct research; to operate, improve, and personalize our Services and our players’ experiences, including through analytics; and to manage and deliver contextual advertising.
d. Payment Information
If you make a purchase in our Services, such as a license to use in-app virtual currency or virtual items in an app you play, our third party payment processor will collect the billing and financial information to process your charges. GemX FP does not collect or store your financial information. However, GemX FP ‘s payment processors may share non-financial information with us related to your purchases, like transaction information, transaction ID, the items purchased and value in order to fulfill your order.
Please note that purchases of third party credits or currencies may also be subject to those parties’ policies.
e. Customer Support Correspondence
When you contact our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your GemX FP player and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support.
2. Information We Collect Automatically
a. Information From Social Networks (like Facebook)
If you play GemX FP ‘s apps or access any of our other Services by using a social network (such as Facebook) ID, we automatically receive certain information about you from the social network, depending upon the GemX FP app you’re playing, the social network, and your friends’ and your privacy settings on that social network. For example, GemX FP will automatically collect and store some or all of the following information provided by the social network:
- your first and last name;
- your profile picture or its URL;
- your social network ID number, which is linked to publicly-available information like your name and profile photo;
- public data for your friends (including their social network ID numbers);
- information from friends who have also linked their social media account with our App;
- the login e-mail you provided to that social network when you registered with it;
- the location of the devices you use to access our Services;
- your gender;
- your exact age and/or age range;
- other publicly-available information on the social network; and/or
- any other information that you or the social networks share with us.
b. Tracking Technologies
We, and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:
- device identifiers such as the IDFA on mobile devices and
- cookies on our websites, which are small pieces of data transferred to your mobile device or computer that enable us to (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
We and our service providers use these technologies to collect and analyze certain kinds of technical information, such as:
- IP addresses;
- the type of computer or mobile device you are using;
- your operating system version and platform type;
- your mobile device’s identifiers, such as your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
- your browser types and language;
- the website you visited before or after visiting our Services, domain names, landing pages, pages viewed, clicks and time on a page;
- whether or not some of GemX FP’S other apps are installed on your device;
- app activity;
- app state and the date and time of activity on our websites or apps.
We may connect this information with your social network ID (where available) or GemX FP user ID.
For more information on how to limit the types of cookies you allow, please see – Opting out of Cookies.
c. Information from Your Mobile Device
If you play GemX FP apps or access our other Services on your mobile device, in addition to your device identifiers, we may also automatically collect:
- the name you have associated with your device;
- your country; and
- information about GemX FP apps you have on your device.
We may also automatically collect, with your permission, your precise GPS location information.
If you want to adjust your privacy preferences on your mobile device, please see – How to Access, Update and Manage Your Information.
d. Information Across Devices and Applications
Sometimes, we (or our service providers) may use the information we collect — for instance, usernames, IP addresses and unique mobile device identifiers or other IDs (like social network ID) — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones and tablets), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
How We Use the Information We Collect
The main reason we use your information is to deliver and improve our services. Additionally, we may use your information to help keep you safe and to communicate with you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
We DO NOT use your non-personal information (meaning information that, by itself, does not identify who you are such as device information) for targeted online marketing through tools like Facebook Custom Audience to contact interested parties.
To administer your account and provide our services to you
- Operate, improve and optimize our Services and our players’ experiences;
- Create player accounts or profiles and to enable you to play our apps;
- Find and recommend other GemX FP players to you;
- Personalize our Services for you;
- Enable players to communicate with each other;
- Provide technical support and respond to player inquiries;
- Protect the safety and well-being of our players;
- Protect GemX FP ‘s rights and property in connection with our Services;
- Prevent fraud or potentially illegal activities;
- Enforce our Terms of Service;
- Manage and deliver contextual and behavioral advertising;
- Notify players of in-app updates, new products or promotional offers;
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- Comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and
- Should you provide us with this information, we may use your email address, name, country and language for customized marketing purposes.
- When we collect your precise geolocation data (subject to your consent) (which may be via the device’s cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties’ apps) that may be related to your location over time.
- If you have registered with an app using your social media account details, we may use the information we receive from your social media provider to identify which of your friends are also using our services so that you can connect with them in our app.
In some services, to ensure a consistent experience across your devices
- Link the various apps and devices you use, so that you can enjoy a consistent experience of our services on all of them. This will allow us to form a single view of your use of our services, so you can easily access your content on multiple devices. For this purpose and better user experience generally, we may use and combine your personal information which we collect across different services used by you.
To improve our services and develop new ones
- Develop new features and services (for example, we may decide to build a new feature further to requests or feedback received from users).
- Conduct research and analysis of your behaviour about your use of, or interest in, our products, services, or content to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour). This software may record information such as how often you use the services, what happens within the services, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from.
To communicate with you
- Communicate with you by postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app.
- When you share your information with us via a social network provider like Facebook, we use this to show information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share information about our services with your connections or on your social network profile.
- With your consent (where needed), to send you email marketing in order to provide you with information about services that you may find of interest. You can opt-out of receiving direct marketing communications from us by following the unsubscribe instructions included in our marketing communications. We also send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, service availability or modification of key features or functions.
To serve you relevant offers and ads
- Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. When you are on our services, third-party ad partners may provide you with advertising based upon your interests. These companies may use technologies to collect data about users, including precise device location data, to help them tailor relevant ads and measure ads’ effectiveness. These companies may collect this data through SDKs or from users who view or interact with their advertisements. For the purposes of European law, most of these ad partners are independent controllers of your information, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the services. It also means that if you are a Facebook app user for example – you provided consent to Facebook in your Facebook app to allow them to show you personalized ads inside of our services.
- Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys;
To prevent, detect and fight fraud or other illegal or unauthorized activities
- Perform data analysis to better understand and design countermeasures against these activities
- Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
- Enforce or exercise our rights, for example our Term Of Service
- To process your information as described above, we rely on the following legal bases:
- Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to maintain your account and provide our cool features to you.
- Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings and we process information for administrative, fraud detection and other legal purposes.
Legal Bases for Use of Your Information
- Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: our Terms of Service and/or our contract to provide our Services to you);
- Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our websites, products, software, or applications; to operate our business and our Services; to make and receive payments; to comply with legal requirements and defend our legal rights; to prevent fraud and to know the customer to whom we are providing Services); or
- Where we have obtained your prior consent.
- We conduct certain marketing activities on the basis of consent, and others on the basis of our legitimate interest in informing you about our services and offers.
How We Share Your Information
We will share your information (which may include personal information) with third parties or allow third parties to collect this information from our Services in the following circumstances:
a. Aggregated/Anonymous Information
From time to time, GemX FP may share Aggregate/Anonymous Information about use of the Services for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes. The sharing of such data is unrestricted.
b. Friends and Other GemX FP Players
The Services allow you to interact with other players. In most GemX FP apps, if you play or register through a social network (for example, Facebook Connect), your friends will see your name, profile photo and your app activity. In some GemX FP apps, other players, including those who are not your social network friends, will be able to see your app activity and profile, which may include your name or user name and your profile photo, and communicate with you within our Services. In certain cases, your profile photo, can reveal your social network ID or GemX FP player ID, and access to a social network ID or GemX FP player ID may allow others to view the public information associated with your related social network profile or GemX FP account. Other players may be able to send you app requests or friend requests through the related social network’s or GemX FP ‘s features.
c. Third Party Advertising and Analytics
We allow advertising on our Services so we can continue to offer many of our Services for free. To do so, we allow third parties (e.g., ad network and ad servers) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or tracking technologies on your computer, mobile device, or other device you use to access the Services.. When advertisers or ad networks place ads in our Services, they may collect or we may share with them and with analytics providers the following types of information from our Services:
- performance data (like the number of clicks on an advertisement);
- aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (for example, players between the ages of 29 and 34 who live in Berlin);
- certain technical information (such as, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
- your social network ID; and
- other contextual data about your game play (such as, your level and session duration).
This information may be used to:
- measure the effectiveness of advertising and/or
- show you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising)
Advertisers or advertising networks may collect this information by using one of more tracking technologies described above, such as browser cookies and web beacons.
Please note, if you click on a third party advertisement, you may no longer be on a site hosted by GemX FP or the social network through which you are playing GemX FP ‘s apps.
If you do not want to receive tailored in-application advertisements from third parties, please see – How to Access, Update and Manage Your Information—Opting Out of Third Party Tailored Advertising.
We may also use third-party web analytics services (such as those of Google Analytics) on our website Services to collect and analyze traffic and player activity through cookies and similar tools to improve your experience; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by [clicking here] (https://tools.google.com/dlpage/gaoptout).
d. Safety, Security and Compliance with Law
Your information, the contents of all of your online communications in our Services, and the communications between you and GemX FP may be accessed and monitored as needed to provide our Service and may be disclosed:
- when we have a good faith belief that we must disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
- to comply with any applicable laws or regulations;
- where, in our sole discretion, we believe that the Service is being used to commit a crime, including in order to report criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and
- to protect the rights or property of GemX FP and other applicable third parties, including to enforce our Terms of Service.
e. Offer Walls
GemX FP apps or their purchase pages may display an “offer wall” that is hosted by an offer wall provider. An offer wall permits third party advertisers to provide virtual currency to players in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by GemX FP. These offers may be shown to you based on certain technical information, like your geographic area or de-identified demographic information. If you click on one of these offers, you will no longer be on a site hosted by GemX FP or the social network through which you are playing GemX FP ‘s apps. To properly credit player accounts and to prevent fraud, a unique identifier, in some cases your social network ID or GemX FP player ID, will be shared with the offer wall provider.
We may share information we collect with our affiliates.
g. Third Party Service Providers
We may share information we collect with our third party service providers that perform services on our behalf, including, but not limited to, payment processing, e-mail delivery, hosting services, and customer service.
h. Sale or Merger
Data Subject Rights and Your Choices
You have certain rights with respect to your information as further described in this section.
a. Your Legal Rights
If you would like further information about your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time. Your local laws may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
- update information which is out of date or incorrect
- delete certain information which we are holding about you
- restrict the way that we process and disclose certain of your information
- transfer your information to a third party provider of services
- revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
If you no longer want GemX FP to use your information, contact us at email@example.com . Place “Delete My Account” in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within the time period stated by applicable law. If you make such a request, you may no longer be able to play such app or use our Services.
If applicable, you may also make a complaint to the data protection supervisory authority in the country where you are based. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.
b. Information We Receive From a Social Network Where You Play Our Apps or From Your Mobile Device
To manage the information GemX FP receives about you from a social network, like Facebook, where you play our apps, you will need to follow that social network’s instructions in order to update your information and change your privacy settings.
To review and update information associated with your GemX FP app profile in certain apps, visit the “settings” page in that app. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.”
c. Opting Out of Geolocation
If you have previously allowed us to access your geolocation data and you no longer wish for us and our service providers to collect and use GPS location information, you may disable the location features on your device. Please see your device manufacturer settings. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features, and/or products made available via the Services.
d. Opting Out of Push Notifications
When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.
e. Opting Out of Third Party Tailored Advertising
- Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising;
These opt-out tools are provided by third parties, not GemX FP. GemX FP does not control or operate these tools or the choices that advertisers and others provide through these tools.
In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” In addition, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not GemX FP. GemX FP does not control or operate these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive advertisements from third parties within GemX FP ‘s apps even if you opt-out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.
f. Opting Out of Cookies
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. If you disable cookies, you may lose some of the features and functionality of our Services because GemX FP cookies are necessary to provide our web-based Services.
California Online Privacy Protection Act Notice
At this time, there is no general agreement on how companies like GemX FP should interpret Do Not Track signals. GemX FP does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
Privacy Policies of Linked Third Party Services and Advertisers
Our websites and apps may contain advertisements from third parties, which are companies other than GemX FP that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these third parties, and the collection, use, and disclosure of your information will be subject to the privacy policies of those third parties. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.
Please see the links below to learn more about the data practices of the third-party advertising partners that we use or may use:
Our Policies Concerning Children
Our websites and apps are not for children under the age of 13 and we do not knowingly collect any personal information from children under 13. Children under 13 should not use our websites or apps at any time. If we learn that we have inadvertently gathered personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable measures to promptly remove that data. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Transfer of Information to Other Countries
How Long We Keep Your Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.
Security of Your Information
We implement appropriate security measures to protect the security of your information. If you have an account registered directly with GemX FP, your profile information is protected by the password you use to access your GemX FP account. It is important that you protect and maintain your GemX FP account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your GemX FP account, the Service allows you to request that instructions be sent to you that explain how to reset your password. If you access our Services through a social network and your social network account is hacked, this may lead to someone playing your GemX FP apps without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well. We urge you to log out of your GemX FP account and any social network account you have used to access our Services after you use it.
When you sign into your GemX FP account or enter payment information, we or our third party payment processor use secure socket layer technology (“SSL”) to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. Although we strive to protect your personal information, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us at online: firstname.lastname@example.org (By post: Room 203, 2nd Floor, QTSC 1 Building, QTSC Software Park, District 12, HCM City, Vietnam)
Your California Privacy Rights
California law permits users who are California residents to request and obtain a list of the third parties to whom we disclose their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year. However, we do not share personal information (as defined by such law) with third party advertisers for their direct marketing purposes.