Privacy Policy

1. Who we are

The App and this website (gemnova.pages.dev) are provided by Klynovate (“we”, “us”, “our”). We are responsible, as the controller, for the personal information described in this policy, except for information that Google collects and uses for advertising as an independent controller (see section 3). You can contact us at any time using the form on our Support page.

2. Information stored on your device

The App has no account system. You don’t need to give us your name, email address or any other contact details to play. Your game progress, scores, statistics and settings (such as sound, vibration, language and reminders) are stored only on your device and are not sent to us. Your ad privacy choices are also stored on your device so that the App can respect them.

Uninstalling the App deletes this data. Depending on your device settings, it may still be included in your device’s own backups (for example iCloud or Google backups).

3. Advertising (Google AdMob)

The App is free because it shows ads. Ads are provided by Google AdMob, a service of Google LLC (“Google”). The Google Mobile Ads SDK built into the App collects information directly from your device, which may include:

• Advertising identifiers: the Identifier for Advertisers (IDFA) on iOS, only if you allow tracking, and the Android Advertising ID (AAID) and app set ID on Android;
• IP address, which can be used to estimate your approximate location (for example your country or city);
• Device and app information, such as device model, operating system and version, language, screen size and the App’s version;
• Ad interactions, such as which ads were shown, clicked or watched;
• Diagnostic information related to ads, such as performance and crash data.

Google uses this information to deliver ads, measure their performance, limit how often you see the same ad, and detect and prevent fraud and abuse. Where you allow it, Google also uses it to show personalized ads based on your interests. Non-personalized ads still rely on some of this information: they are chosen based on context, such as your approximate location and the content of the App, and the information is also used for frequency capping, reporting and fraud prevention.

Google processes this information under its own privacy policy. Learn more in How Google uses information from sites or apps that use its services and the Google Privacy Policy. We only receive aggregated reports about ad performance from Google, not information that identifies you.

To keep ads appropriate, we set a maximum ad content rating in the App so that ads are suitable for a broad audience.

4. Your ad privacy choices

• EEA, UK and Switzerland: consent. If you are in the European Economic Area, the United Kingdom or Switzerland, the App asks for your consent through Google’s User Messaging Platform (UMP), a consent management platform certified by Google that uses the IAB Transparency & Consent Framework, before your information is used for personalized ads or other purposes that require consent. You can review or change your choices at any time in the App under Settings → Privacy settings.
• United States: “Do Not Sell or Share”. If you live in a US state with a comprehensive privacy law (for example California, Colorado, Connecticut, Virginia or Texas), you can opt out of the “sale” or “sharing” of your personal information and of targeted advertising. Open Settings → Privacy settings in the App and choose to opt out (“Do Not Sell or Share My Personal Information”). Your choice applies to the device on which you make it.
• iOS: App Tracking Transparency. On iPhone and iPad, the App uses Apple’s App Tracking Transparency prompt to ask your permission before the IDFA can be used for tracking. If you choose “Ask App Not to Track”, the IDFA is not shared, and you will still see ads, which may be less relevant to you. You can change this at any time in iOS Settings → Privacy & Security → Tracking.
• Android: advertising ID. You can reset or delete your advertising ID in your device settings (for example Settings → Privacy → Ads or Settings → Google → Ads, depending on your device).

These choices don’t remove ads from the App, but they limit how your information is used for them.

5. Feedback, support requests and ad reports

Sending us feedback is optional. When you use Send feedback or Report an ad in the App, or the contact form on our Support page, we receive:

• your message and its type (feedback, bug report, ad report or support request);
• your email address, only if you choose to give it so that we can reply;
• technical details that help us understand the problem: the App’s version and build number, platform (iOS, Android or web), operating system version, device model and language setting;
• basic gameplay statistics, if the App attaches them (for example the number of games played or recent scores);
• a pseudonymous code derived from your IP address. Our server combines your IP address with a secret value that changes every day and keeps only a one-way hash of the result, which we use to limit spam and abuse (at most 5 messages per day). We do not store your IP address itself.

Submissions are stored in a database operated for us by Cloudflare, Inc. We use them to reply to you, fix bugs, improve the App and, for ad reports, to block inappropriate ads or advertisers. We keep each submission for up to 24 months and then delete it. Please don’t include sensitive personal information in your message.

6. App settings downloads (remote configuration)

When you open the App, it downloads a small settings file from this website (for example how often ads may appear or how difficulty is tuned), so that we can adjust the game without an app update. Like any internet request, this reveals your IP address and basic technical information, such as the App’s user agent, to our hosting provider Cloudflare. The file is the same for everyone. We don’t use these requests to identify or profile you, and we don’t keep logs of them ourselves.

7. Notifications

If you turn on the daily reminder, the App schedules local notifications on your device using your device’s notification system. No push notification server is involved and nothing is sent to us. You can turn reminders off in the App’s Settings or in your device’s notification settings.

8. This website

This website does not use cookies, analytics, advertising or any other third-party trackers. It is hosted by Cloudflare, which processes technical data such as your IP address, browser type and the pages you request in order to deliver the website and protect it from attacks; see the Cloudflare Privacy Policy. If you use our contact form, section 5 applies.

9. Legal bases for processing (EEA, UK and Switzerland)

• Consent: for personalized ads and, where the law requires it, for storing or accessing information on your device. You can withdraw your consent at any time in Privacy settings; this does not affect processing that took place before.
• Legitimate interests: to offer the App free of charge through advertising (including non-personalized ads, ad measurement and fraud prevention), to deliver the App’s settings file, to keep our services secure and free of abuse, and to understand feedback and improve the App.
• Responding to your request: to answer support requests you send us.
• Legal obligations: where we must keep or disclose information by law.

10. Sharing and “selling”

We share personal information only with:

• Google, which collects advertising data directly through its SDK as described in section 3;
• Cloudflare, which hosts this website and stores feedback on our behalf;
• authorities or others, when required by law or needed to protect rights, safety and security.

We do not sell your personal information for money, and we don’t share the feedback you send us with advertisers. However, under some US state privacy laws, allowing Google to use advertising identifiers for personalized ads may count as a “sale” or “sharing” of personal information, or as “targeted advertising”. You can opt out at any time as described in section 4.

11. Children

The App is designed for a general audience and is not directed to children under 13 (or under the minimum age that applies in your country). We don’t knowingly collect personal information from children. Ads in the App are limited by a maximum ad content rating. If you believe a child has sent us personal information through our feedback features, please contact us and we will delete it.

12. Data retention

• On your device: until you delete the App or its data.
• Feedback, support requests and ad reports: up to 24 months after we receive them, then deleted; sooner if you ask us.
• Rate-limiting records (hashed, see section 5): used for 24 hours, then deleted routinely.
• Advertising data collected by Google: according to Google’s policies (see How Google retains data).
• Website and hosting data processed by Cloudflare: according to Cloudflare’s policies.

13. Security

Information sent between the App or this website and our servers is encrypted in transit (HTTPS). Access to stored feedback is limited to us, and we store only hashed codes derived from IP addresses, never the addresses themselves. No method of transmission or storage is completely secure, but we work to protect your information and review these measures when we change the App.

14. International data transfers

We, Google and Cloudflare may process information in countries other than the one you live in, including the United States, whose data protection laws may differ from those of your country. Where required, these transfers are protected by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and their UK and Swiss equivalents) or the EU–U.S. Data Privacy Framework.

15. Your rights

Depending on where you live (for example under the GDPR in the EEA and UK, US state privacy laws, or Japan’s Act on the Protection of Personal Information), you may have the right to:

• access the personal information we hold about you and receive a copy of it;
• have it corrected or deleted;
• restrict or object to our processing, and withdraw your consent at any time;
• opt out of the sale or sharing of personal information and of targeted advertising;
• not be treated differently for exercising your rights;
• lodge a complaint with your local data protection authority.

How to make a request. For advertising, use Settings → Privacy settings in the App and your device’s tracking or advertising ID settings. Google collects advertising data directly and we don’t receive information that identifies you, so requests about that data are best sent to Google. For feedback you have sent us, use the form on our Support page. As there are no user accounts, please include details that help us find your submission, such as the email address you used, the approximate date and part of your message. We may ask for more information to verify your request, and we will respond within the time required by applicable law. If we decline your request, you can appeal by replying to our answer.

16. Information for users in Japan

External transmission of user information (Telecommunications Business Act, Article 27-12)

The App sends the following user information from your device to these external parties:

You can limit the use of your information for advertising as described in section 4. Feedback information is sent only when you choose to send feedback.

Act on the Protection of Personal Information (APPI)

• Business operator: Klynovate. Our address (and, for a corporation, the name of its representative) will be provided without delay on request through our contact form.
• Purposes of use: as described in this policy (answering inquiries, fixing bugs and improving the App, handling ad reports and preventing abuse).
• Requests for disclosure, correction, deletion or suspension of use of retained personal data: see section 15.
• Security control measures: access to stored feedback is restricted to authorized persons, communications are encrypted, IP-derived data is stored only in hashed form, and retention periods are enforced.
• Understanding the external environment: we entrust the storage of feedback to Cloudflare, Inc. in the United States and take these security measures with an understanding of the personal information protection system of the United States.

17. Changes to this policy

We may update this policy from time to time, for example when we change the App or when laws change. We will post the updated policy on this page with a new effective date. If we make significant changes, we will also let you know in the App or on this website.

18. Contact us

Klynovate
Contact form: gemnova.pages.dev/support

If you are in the EEA, the UK or Switzerland, you also have the right to lodge a complaint with your local data protection authority.