Golden Gem Master Privacy Policy

Updated on February 28, 2026

We place your privacy choices at the very core of our commitments, and we will refer to you as "you" consistently throughout this document. This privacy policy has been developed with great care to present a thorough yet straightforward explanation of the processes by which your personal information is collected, stored, and used when you interact with our game¡ªhereafter uniformly termed the "Application." We strongly encourage you to read this policy in its entirety to fully understand our privacy values and operational practices. By opening the Application or using any of our services, you are confirming your understanding of and agreement to the terms set forth in this privacy policy.

Information Collection and Usage

1. In-Game Activity Data

We compile an array of distinct data points tied to the ways in which you engage with the game environment. This scope of information incorporates, yet is not confined to, the frequency of your clicks, the entry pages and content you explore, records of when you launch the application, your configured permission settings, data on how game features perform during use, how many apps are installed on your device, the unique package identifiers of those apps, your device¡¯s manufacturer, whether your network connection is active or inactive, firebase_device_id, your device¡¯s specific model, the country where your SIM card was originally issued, the language set on your device¡¯s system, and any cookies that advertisers are able to access. None of this data is shared beyond a select group of authenticated third-party analytics tools: Firebase, Facebook Analytics, and our in-house data tracking system (ECS).

2. Device-Specific Information

To enhance your overall experience with the application, we gather specific details related to your device and its network connectivity. The precise set of data we collect is contingent upon several variables, such as your interaction patterns with the app, the privacy settings you have selected, and the specific features you choose to use. Such details may encompass the version of the SDK/API in use, the type of platform you are operating on, time markers, the application¡¯s unique identifier and its current version, a distinct device identification code, the device¡¯s maker, the version of the operating system installed, the system language, the time zone configured on your device, and the status of your network connection (for instance, Wi-Fi). Additionally, we keep track of how the app is listed on Google Play, the methods employed to load advertisements, the advertising platforms utilized, and the unique identifiers associated with ad delivery. Any data obtained through your device¡¯s Android ID is stored for the purpose of monitoring activities related to in-app advertising, and this particular data is classified as personal information.

3. Advertising-Related Data

The advertising identifier linked to your Android device is employed to deliver tailored advertisements, and this unique identifier is used solely for the purposes of advertising and data analysis. It is crucial to emphasize that this identifier does not hold any sensitive data capable of being utilized to individually recognize you or connect to your personal information. Moreover, it bears no association with permanent device identification codes, such as SSAID, MAC address, or IMEI numbers.

4. Network-Connected Information

When you connect to the internet during your gameplay sessions, we compile specific details regarding your network format (e.g., Wi-Fi or cellular data) as well as your IP address. Such data is indispensable for upholding the consistent operational performance of the game¡¯s network linkages.

5. Third-Party Monetization and Analytics Data

Third-party Software Development Kits (SDKs) embedded within our app may retrieve certain categories of user data, which includes the following:

l   Google AD ID: Leveraged within the framework of Google¡¯s advertising ecosystem.

l   Device-related details: For example, device category, technical specs, and the nation where the services are being used.

l   Anti-fraud data: To identify click-based fraudulent activities and preserve the integrity of the advertising infrastructure.

l   Demographic insights: Extracted from IP address analysis, delivering an understanding of geographically linked usage trends.

l   Ad, marketing and analytics-related metrics: Utilized by third-party SDKs to refine marketing initiatives, conduct investigative research, and analyze user behavioral patterns.

l   Advertiser-accessible cookie files: Saved on your device or retrievable by advertising entities.

The data captured by these SDKs is regulated by the separate privacy policies of their respective providers. Third-party entities cover monetization collaborators (e.g., Google Admob, Facebook Audience Network, IronSource) and analytics solutions (e.g., Firebase, Facebook Analytics, our internal operational systems). Direct links to their privacy policies are made available in the Privacy Policies of Third-Party Partners section for your careful examination.

Legal Bases for Personal Data Processing

Our handling of your personal data adheres strictly to the purposes set forth in this policy, and all such data processing activities are grounded in the following legal pillars:

1. Contractual Necessity

The handling of your personal data stands as a regular necessity for us to meet the contractual obligations we have to you. This lets us provide the services you¡¯ve requested and verify who you are¡ªfor example, managing your sign-up information to let you use our platform and all its functions.

2. Statutory Obligations

We carry out data handling procedures to comply with all relevant legal statutes and regulatory mandates. Illustrations of this practice include keeping financial records that align with accounting protocols, or sharing information with law enforcement agencies when required to do so by legal dictates.

3. Legitimate Business Interests

We perform data processing to cultivate our relational ties with you (such as forwarding service-associated alerts), fortify the security of our service offerings, and circulate product-related details. These endeavors allow us to refine our services in light of user input and elevate the overall experience for our users.

4. Explicit User Consent

In particular circumstances, we shall only handle your personal data upon receiving your definitive consent¡ªsuch as deploying non-essential cookies on your device or disclosing user data to enable the delivery of targeted advertising content. It is critical to emphasize that certain service offerings and functional modules of the platform may rely on this form of authorized data handling to perform in accordance with their original design specifications.

Approaches to Information Collection

1. Automated In-Game Data Capture

Once you initiate the game, its native internal systems will autonomously collect the above-referenced data points. This entire data-gathering process adheres rigorously to the provisions outlined in this policy as well as all pertinent legal and regulatory frameworks to guarantee full compliance at all stages.

2. Data from Third-Party Platforms

In the event that you obtain the game through an external third-party distribution channel (e.g., Google Play Store), we may receive restricted batches of user information¡ªincluding unique device identification codes and game download logs. This transfer of data is executed in strict alignment with the privacy protocols of the corresponding third-party platforms and all applicable statutory rules and provisions.

Information Security and Protection Measures

We prioritize the security of your personal data above all other operational considerations, and we implement comprehensive protective measures¡ªincluding advanced data encryption protocols¡ªto mitigate potential risks such as data loss, unauthorized appropriation, unsanctioned access, improper disclosure, malicious modification, or accidental destruction. Encryption mechanisms are uniformly applied to data both in its stored state and during electronic transmission, thereby safeguarding the complete integrity of all information as it is transferred across digital networks.

We enforce rigorous access governance policies that limit the rights to view, access, and process data exclusively to internal personnel with formal authorization and valid operational need. Comprehensive logs of all data access activities are maintained in full detail, and systematic compliance audits are conducted on a regular basis to monitor and verify adherence to all internal data security rules. Beyond this, our game¡¯s technical systems and cloud servers undergo scheduled security assessments and vulnerability scans, which enable us to proactively identify and remediate potential security flaws¡ªthis proactive approach effectively defends our data infrastructure against malicious cyber threats such as unauthorized hacking attempts and malicious software infiltrations.

Your Rights

1. Right to Withdraw Consent

You hold the unwavering right to revoke the consent you have previously granted for any data processing activities predicated on such authorization, at any time and for any reason. Such a withdrawal of consent shall not invalidate any lawfully executed data processing actions that took place prior to the revocation, nor shall it impact any measures or conduct undertaken by third parties in the period before your consent was withdrawn.

2. Right to Access and Modify

Pursuant to the stipulations of all relevant and applicable legal frameworks, you are afforded the statutory right to request access to all personal information we maintain in our records pertaining to you, as well as to submit requests for necessary corrections and amendments to such information as required.

3. Right to Obtain and Rectify Information

We will furnish you with a complimentary copy of all personal information we hold in our records at your formal written request, save for instances where pertinent legislation explicitly authorizes us to levy a reasonable administrative fee for fulfilling this request. We may impose limitations on your access to such information if granting full access would compromise the lawful rights and legitimate interests of other individuals or third parties. In addition, should you be unable to directly update any inaccurate personal data through our official service channels, you may lodge a formal application for us to rectify and amend the erroneous information in our possession.

4. Right to Request Erasure

You are entitled to initiate a formal request for the erasure of your personal data in the following situations:

l   The data in question is no longer necessary for the achievement of the original purpose for which it was initially collected and processed;

l   The processing of the relevant data was originally based on your express consent, which you have subsequently revoked in full;

l   You have raised a formal objection to the ongoing processing of your personal data, and we do not possess overriding and compelling legitimate business grounds to continue such data processing activities.

5. Right to Restrict Processing

You may submit a request to impose limitations on the processing of your personal data in circumstances that include, yet are not confined to, the following:

l   You dispute the correctness of the data currently being processed (processing activities will be restricted during the verification phase, a measure that may lead to temporary disruptions in your ability to access our services);

l   You oppose the unlawful processing of your data and seek to restrict such processing as a substitute for the complete erasure of your personal information;

l   After we have no further need for the data to fulfill its original purpose, you require the retention and restriction of processing to pursue legal claims, or during the period when we are assessing whether our legitimate interests take precedence over your objections to the processing.

Any personal data subject to processing restrictions will only be handled with your clear and explicit consent, for the sole purpose of pursuing legal claims, to safeguard the legitimate rights and interests of third parties, or for reasons related to public welfare. We will inform you without delay whenever any such processing restrictions are removed or lifted.

6. Right to Object to Processing

In cases where your personal data is being processed based on your prior consent, a contractual arrangement, or our legitimate commercial interests, you hold the statutory right to raise a formal objection in accordance with all applicable legal provisions. We may only continue to process your personal data if such processing is deemed necessary for the pursuit of legal claims or is explicitly authorized by relevant legislative requirements.

7. Notification Obligations to Third Parties

Where we have disclosed your personal data to third-party entities, we shall notify those parties of any requests you submit in relation to the correction, erasure, or restriction of your data¡ªunless meeting this notification obligation is technically unfeasible or would entail disproportionate administrative burden. We will also disclose the identities of these third-party data recipients at your formal request.

8. Right Concerning Automated Decision-Making

Save for instances covered by legal exemptions, you are entitled to refrain from being subject to decisions that are derived exclusively from automated data processing (including user profiling) and that may result in legal ramifications or material adverse impacts on your personal interests.

9. Right to Data Portability

In the event that your personal data is processed on the basis of a binding contractual arrangement, your express prior consent, or fully automated processing methods, you may submit a request for us to furnish your data in a structured, machine-interpretable format. Where such action is technically feasible and does not compromise or infringe upon the lawful rights and interests of any third party, we will effect the direct transfer of your data to another designated data controller in accordance with your specific request.

10. Right to Lodge a Complaint

Should you hold the belief that your statutory privacy rights have been infringed or violated in any manner, please reach out to us at joaorobertocardosodelima@gmail.com, and we will take all reasonable and necessary steps to resolve the relevant issue with the utmost promptness. In addition to this, you retain the unqualified right to file a formal complaint with the competent supervisory authority in your country of residence, the country where you are employed, or the jurisdiction in which the alleged privacy violation is deemed to have taken place.

California Privacy Rights

Residents of California are granted extra privacy safeguards pursuant to the California Consumer Privacy Act (CCPA), and these protections are outlined in full detail in the following content. To exercise the rights that are exclusive to the CCPA, please refer to the section that follows, which is labeled ¡°Exercising Your California Privacy Rights.¡± If you do not reside in California, the provisions of this section shall not be applicable to you¡ªwe recommend that you review our main Privacy Statement in lieu of this section.

1. Right to Disclosure and Information Access

You possess the entitlement to obtain specifics regarding, and gain access to, the personal information that we have collected about you within the past 12-month timeframe. This scope of access includes the following elements:

l   The separate and distinct categories of data that we have collected in connection with you;

l   The origins from which this personal information was obtained;

l   The business-related purposes that motivate and justify the collection of your personal data;

l   The particular items of information that we have accumulated and retained concerning you.

2. Right to Request Data Deletion

You are entitled to lodge a formal request for the erasure of any personal information that we have gathered from you. Once we receive such a request, we will not only remove the relevant data from our own systems but also direct our service providers to carry out the same deletion process. Nevertheless, this deletion requirement does not apply in circumstances where we or third-party entities need to retain the data for any of the following objectives:

l   Rendering the services that you have explicitly requested and agreed to receive;

l   Identifying and correcting errors within our technical systems;

l   Adhering to the provisions of the California Electronic Communications Privacy Act (as specified in Sections 1546 and subsequent clauses of the California Penal Code);

l   Conducting public or peer-reviewed scientific, historical, or statistical research initiatives that promote the public welfare, while also complying with ethical guidelines and privacy-related regulations;

l   Satisfying legal duties, or in other comparable situations where retention is mandated by law.

3. Data Retention Protocols

We reserve the right to keep your personal data for an prolonged timeframe on the condition that you have granted your explicit consent and have not revoked that consent at any point afterward. Additionally, extended periods of data retention may be necessary to fulfill statutory obligations or adhere to official mandates and directives issued by relevant authorities. Should the game discontinue its operational activities entirely, all personal information in our possession will be permanently removed and erased from our technical systems and databases.

4. Processing of Your Requests

Our objective is to provide responses to all properly verified consumer requests within 45 days of their receipt. In situations where an extension is required due to unforeseen circumstances (with the maximum allowable extension bringing the total timeframe to 90 days), we will notify you through email, telephone, or other electronic means of communication, and furnish a clear and comprehensive explanation for the delay. As a general rule, we do not impose any charges for the processing of such requests or for providing responses to them. However, if a request is determined to be excessive in scope, repetitive in nature, or clearly lacking in legitimate merit, we retain the authority to levy a reasonable administrative fee. Prior to initiating any processing that would incur a fee, we will first clarify the reasoning behind our decision and provide you with a detailed breakdown of the estimated costs involved.

5. Non-Discrimination Commitment

The exercise of your rights under the CCPA will not lead to any type of unjust treatment on our part. Specifically, we will not refuse to provide you with our services, impose discriminatory pricing or rates, or offer you services of inferior quality or inconsistent standards as a result of you asserting these rights. Your privacy protections under the CCPA do not modify or alter the terms of service that you have previously agreed to abide by.

6. Notice on Minors' Data Collection

Our service offerings are neither designed for nor intended to be utilized by individuals who are under the age of 13. We do not intentionally or knowingly gather personal information from children within this age group. In the event that we become aware that we have collected such data inadvertently, we will promptly and permanently erase it from our servers and databases. Parents or legal guardians who discover that their child under the age of 13 has disclosed personal information to us should get in touch with us without delay to start the data removal process. For users between the ages of 13 and 16, explicit opt-in authorization is a prerequisite for using our services. Parents or legal guardians of these teenage users may also contact us at any time with any questions, concerns, or requests related to their child¡¯s personal data.

Rights of EU and UK Residents

Individuals domiciled in the United Kingdom or any member nation of the European Union are granted distinct privacy protections under European Union data protection frameworks. These specific entitlements are elaborated in full detail in the following provisions:

l   Right to Confirm Data Processing and Obtain Clarification: You are entitled to request written confirmation as to whether your personal data is being processed by us, as well as thorough and comprehensive details regarding the exact personal information we maintain in relation to you.

l   Right to Inspect and Correct Data: You hold the legal authority to examine the precision of your personal data and make any required revisions to it, ensuring that all information stored within our technical systems remains accurate and up-to-date at all times.

l   Right to Demand Data Erasure: Should you desire that we no longer keep your personal data in our possession, you have the statutory right to insist on its complete deletion¡ªan action that will result in the permanent removal of such information from all our databases and storage systems.

l   Right to Restrict Data Processing: If we lack a valid and lawful basis for continuing to process some or all of your personal data, you may submit a request for us to terminate these processing activities, thereby safeguarding your information against any unauthorized use or handling.

l   Right to Data Portability: You may request and obtain a copy of the personal data you have provided to us in a format that is compatible with machine processing. This format facilitates the seamless transfer of your data to another party or the independent management of your information as you see fit.

To exercise any of the aforementioned rights, please send a formal request via email to joaorobertocardosodelima@gmail.com. We are committed to providing a response to your request within a single calendar month from the date of receipt. In the event that you believe we are not adhering to applicable data protection laws and regulations, you also retain the unrestricted right to file a formal complaint with the data protection authority in your local jurisdiction.

Third-Party Privacy Policy Links

Our privacy policy includes hyperlinks to the privacy notices of our third-party collaborators. It is crucial to understand that these privacy documents are managed independently by the respective third parties and are not within our sphere of control or oversight. These notices outline the methods by which third-party organizations gather, employ, and disclose user information, and we highly advise you to read and review them carefully and thoroughly prior to interacting with or using their services. The applicable hyperlinks are listed in the section that follows:

l   Adjust: https://www.adjust.com/terms/privacy-policy/

l   Unity: https://unity3d.com/legal/privacy-policy

l   Pangle: https://www.pangleglobal.com/privacy

l   Mintegral: https://www.mintegral.com/en/privacy

l   Vungle: https://vungle.com/privacy/

l   Max/Applovin: https://www.applovin.com/privacy/

l   ironSource: https://www.is.com/privacy-policy/

Children's Privacy Protection

Protecting the privacy of minors stands as a core and non-negotiable priority for our team. We strongly encourage parents and legal guardians to take an active role in overseeing and monitoring their children¡¯s online behaviors and interactions with digital platforms. Should you uncover that your child has disclosed personal information to us without your prior knowledge or explicit authorization, please reach out to us without delay. Once we receive such a notification, we will take immediate and decisive action to permanently remove and erase all relevant personal data from our databases and records.

Revisions to the Privacy Policy

We reserve the right to update and revise this privacy policy on a periodic basis to align with changes in our business operations, advancements in technology, or shifting legal and regulatory obligations. All revised iterations of the policy will be made accessible within the application itself or on the associated third-party distribution platform where the game is hosted. Whenever practically possible, we will inform you of these modifications through appropriate communication channels (such as in-app alerts or direct email notifications). After being notified of changes, we strongly urge you to carefully and thoroughly review the updated policy. Your continued usage of the game following the publication of any revisions will be deemed as your full acceptance of the updated terms and conditions. If you do not agree with the revised privacy policy, you may opt to terminate your use of our services at any time.

Contact Information

If you have any questions, comments, feedback, or concerns pertaining to this privacy policy or our practices regarding the collection, processing, and protection of personal data, please get in touch with us using the following method:

Email: joaorobertocardosodelima@gmail.com