Privacy policy

DRAFT for legal review. Written in plain language from how Gem Keep is planned to work. It has not been checked by a lawyer. Items marked [CHECK] need the owner or a lawyer. Do not treat this as final until the draft box is removed.

Last updated: 13 November 2026.

Who we are

Gem Keep: Merge Tower Defense ("the game") and this website are run by IT Support Partners Pty Ltd, ABN [CHECK], of Australia ("we", "us"). You can reach us at hello@playgemkeep.com. [CHECK: postal address if required.]

The short version

We do not ask for your name, email address, phone number, contacts, photos or precise location to play.
Your game gets an anonymous player ID. That ID is how we back up your progress and check your purchases.
If you watch an optional reward video, the ad company may use your device's advertising ID. Ads are never forced on you.
We do not sell your personal information.
You can ask us to delete your data at any time.

Three different things

This policy covers three things, because each handles information differently.

This website (playgemkeep.com).
The browser demo (playgemkeep.com/play), a free sample of the first levels.
The Gem Keep app for Android. [CHECK: update this list before launch if the app is released on other stores.] The app is not released yet. The sections below describe how it is planned to work, and we will update this policy before it is released and whenever it changes.

This website

Visitor statistics. We use Google Analytics 4 to count visits and clicks, for example how many people try the demo or tap the Android button. It sets cookies on your device and sends Google information such as the pages you view, your approximate location (from your IP address, which is shortened), your browser and device type. We use it only to understand and improve the site. You can block it in your browser settings or with an extension. [CHECK: add a consent banner if the site is aimed at visitors in the EU, UK or other places that require one.]
Launch list. If you join the launch list, we store your email address only to tell you when Gem Keep launches and about big news. You can unsubscribe from any email, or write to us and we will remove you. [CHECK: name the service that stores the list, and the endpoint; keep this in line with the Spam Act 2003 (consent, sender details, unsubscribe).]
Search. We use Google Search Console, which tells us how people find the site in Google Search. It does not identify you to us.
Hosting. The site is hosted on Microsoft Azure. Like any web host, Azure's servers see your IP address and the pages you request, and keep short-term logs for security and reliability.
Links. Our social media links (TikTok, Instagram, YouTube) take you to other companies' sites, which have their own privacy policies.
Email to us. If you write to us, we keep your message and address so we can reply and keep a record.

The browser demo

The demo keeps your progress, name and settings in your own browser (local storage) and nothing else. It does not create an account, does not send your progress to us, and takes no payments. [CHECK: if rewarded ads are added to the demo, update this section to name the ad provider and what it collects.] Clearing your browser data removes your demo progress.

The app: what we plan to collect

[CHECK: this section must match exactly what the released app and its code do, and what is declared in Google Play's Data safety form. Re-check it against the final build.]

Information	What it is for	Who handles it
Anonymous player ID and a login token, made by our server the first time the app connects	To link your cloud save and purchases to your game. It is not your name, email or phone number.	Us, on Microsoft Azure
Cloud save: your progress, settings, Gold, Rubies and unlocks	To back up your game so it survives a lost or changed phone, and to apply the one-time opening balance and weekly schedule	Us, on Microsoft Azure
Purchase records: the receipt (purchase token) from Google Play, what was bought and when. We never see your card details.	To give you what you bought, stop double use of a receipt, handle refunds and prevent fraud	Us; Google Play
Reward video records: that you watched a reward video and which reward was claimed	To pay the reward once and enforce daily limits	Us; Google (AdMob)
Advertising ID and approximate location (from your IP address), used by the ad company if you choose to watch a reward video	To show and measure ads and prevent ad fraud	Google (AdMob), under its own privacy policy
Leaderboard and league entries: a generated display name (for example "Brave Otter 42"), an avatar, your score and rank. [CHECK: confirm names are generated and not chosen.]	To show weekly boards and leagues	Us. Other players can see the generated name, avatar and score.
Replay logs of leaderboard runs, kept for about 14 days [CHECK]	To check a disputed or suspicious score	Us, on Microsoft Azure
Crash and performance data, only if we turn crash reporting on: device model, operating system, error details [CHECK]	To find and fix crashes	[CHECK: provider]
Support messages, if you email us (including your player ID if you share it)	To help you and to restore a save or delete data	Us

The app also stores some settings on your device only, such as sound, the Classic dark look, and the parental controls. These are not sent to us.

What we do not collect

We do not collect your name, email address, phone number, contacts, photos, files, microphone or camera data, or your precise location in the app. [CHECK: re-confirm against the final app permissions.] The game's Guild chat is not part of the first release. If we add chat or any way for players to message each other, we will update this policy first. [CHECK]

Children

Gem Keep is made for players aged 13 and over and is not directed at younger children. [CHECK: decide and state the target age group, and match it to the answer given in Google Play, because it decides which rules apply, including Google Play's Families policy and children's privacy laws.]

When the app first opens, it asks whether the player is 13 or older. If a player says they are under 13, a grown-up is asked to confirm, and the Shop and Guild chat start switched off. A grown-up can also turn the Shop and chat off at any time in Settings under Parental controls. Where a player is under the age of consent, ads are limited to non-personalised ads, or switched off. [CHECK: confirm exactly what the app does for this group.] We do not knowingly collect personal information from children under 13 beyond the anonymous player ID the game needs to work. If you think a child has given us personal information, contact us and we will delete it.

How we use information

to run the game, back up your progress and keep your purchases;
to show ads you choose to watch and pay your reward;
to keep leaderboards fair and spot cheating, fraud and refunds abuse;
to fix crashes and understand how the game and website are used;
to answer you and give support; and
to meet legal duties.

[CHECK: for visitors in the EU, UK or other regions with similar laws, add the legal basis for each use (for example contract, legitimate interests, consent).]

Who we share it with

We do not sell your personal information. We share it only with services that help us run Gem Keep, and only what they need:

Microsoft Azure, our hosting and database provider (Australia East region). [CHECK: confirm the region used for the live app.]
Google: Google Play (purchases and downloads), Google AdMob (reward videos), and Google Analytics and Search Console (website statistics).
[CHECK: any crash reporting, email or support provider added later.]
Authorities or advisers, where the law requires it or to protect our rights, or if the business is sold, in which case your information may pass to the new owner under this policy.

Some of these providers handle information in other countries, including the United States. We take reasonable steps to make sure they protect it. [CHECK: wording for Australian Privacy Principle 8, and for transfers from the EU or UK.]

Keeping it safe, and how long we keep it

Information is sent over encrypted connections and stored with access limited to the people who need it. No system is perfectly secure, and if a breach is likely to cause you serious harm we will notify you and the regulator as the law requires. We keep an account and its data until you ask us to delete it, or until it has been inactive for a long time [CHECK: set a period]. Replay logs are kept for about 14 days [CHECK]. Purchase records may be kept for as long as tax and accounting law requires [CHECK].

Your choices and rights

Deleting your data. The app will have a button to delete your account and cloud data [CHECK: confirm it exists before launch, and add the web page Google Play requires for deletion requests]. Until then, or if you cannot use the app, email hello@playgemkeep.com with your player ID (shown on the Help card in the game) and we will delete your cloud save and records.
Seeing or correcting what we hold. Ask us and we will tell you what we hold and fix mistakes, as the Australian Privacy Act 1988 allows.
Ads. You choose whether to watch a reward video. You can also reset or turn off your advertising ID in your Android settings.
Email. Unsubscribe from the launch list with the link in any email.
Complaints. If you are not happy with how we handled your information, tell us first and we will respond. You can also complain to the Office of the Australian Information Commissioner (oaic.gov.au). [CHECK: add regulator details for the EU and UK if those users are in scope.]

Changes

If this policy changes in a way that matters, we will update the date above and tell players in the game or on this site. Using the app after a change means you accept the updated policy, except where the law requires us to ask again.

Contact

Questions or requests: hello@playgemkeep.com