Last updated: 2026-11-13. In effect from the release of Gemlign 1.0.
1. Who we are
Gemlign ("the app", "we", "us") is a jewel sand sort puzzle for iPhone, published by Mehmet Aktug, trading as Lumina Studio. We are the controller of the information described in this policy.
Contact for anything about privacy: support@luminastudio.ai. Website: gemlign.luminastudio.ai
2. The short version
- The app works without an account. There is no sign-up, no name, no email and no password.
- Your progress, gems, helpers and settings live on your device.
- Version 1.0 has no analytics service and no crash reporting service built in. The app keeps a small event log on your device, and nothing from it is sent to us or to anyone else.
- The app shows ads from Google AdMob. Google decides what its ad code collects. Ads follow Google's consent form (where it applies) and the iOS tracking permission, and ads are not personalised unless you allow it.
- Purchases are handled by Apple. We never see your payment details.
- Notifications are local reminders created on your device, only if you allow them. We do not run a push server.
- The app is for people 13 and older.
- You can erase everything the app stores on your device with Settings > Delete data.
3. What we collect (data map)
3.1 Progress, gems, helpers and settings
Where it lives: a file in the app container on your device. It holds your level, stars, jewels, gems, helper counts, daily reward streak and settings.
Does it leave your phone: no. We do not upload it. Your own iPhone or iCloud device backup (made by iOS, not by us) may contain it.
Who sees it: you.
Delete data in Settings erases it.
3.2 Install ID (Player ID)
What it is: a random number made on your device. It is not built from your device, your name or any advertising identifier. It is shown at the bottom of Settings as the Player ID, so that you can quote it if you email us about a bug.
Does it leave your phone: only if you choose to send it to us in an email.
Who sees it: you, and us if you send it.
3.3 Local event log (on your device only)
What it is: the app writes short events, such as which level you started or finished, into a small log file on your device. Events are limited to numbers, yes/no values and short fixed codes. They contain no free text, and never your name, email, phone number, address, contacts, photos, location or advertising identifier.
Does it leave your phone: no. Version 1.0 contains no analytics vendor code, so nothing from this log is sent anywhere. Delete data erases it. The privacy choice screen and the switches in Settings > Privacy decide whether the log is written.
Who sees it: you. We see it only if you send it to us on purpose.
If we add an analytics or crash reporting service in a later version, we will update this policy before any such data is sent, and the App Store privacy label will match.
3.4 Ad data
What it is: data collected by the Google Mobile Ads SDK to show and measure ads. The table in section 6 lists what Google may collect. Google's privacy policy applies to it.
Does it leave your phone: yes, once ads are requested, after the consent steps described below.
Who sees it: Google and its advertising partners.
3.5 Purchases
What it is: purchases are processed by Apple. The app stores product and transaction information on your device only, so it can unlock what you bought.
Does it leave your phone: the purchase itself goes to Apple only.
Who sees it: Apple.
3.6 Support email
What it is: if you email support@luminastudio.ai, we receive your email address and whatever you write.
Does it leave your phone: only when you send the message.
Who sees it: us.
3.7 Website
The website gemlign.luminastudio.ai hosts this policy, the terms, the support page and the press kit. It is served by Vercel. The site has no cookies, no analytics and no third-party scripts. The website host sees your IP address and the time of the request in its standard access log, and keeps that log for 30 days at most. We do not use it to identify you. The app itself does not download anything from the website.
4. Third-party and Apple components (SDKs)
Version 1.0 contains these components and no others that handle personal data. There is no social login, no attribution SDK, no analytics vendor SDK, no third-party crash SDK, no push SDK and no ad mediation adapter.
4.1 Google Mobile Ads SDK (AdMob)
Purpose: full-screen (interstitial) and optional rewarded ads. There are no banners.
Data it may collect: see the table in section 6.
Consent: Google's consent form where it is required, Apple's tracking prompt for the advertising identifier on iPhone, and our own privacy choice screen.
Provider terms: Google's privacy policy and ad settings apply. Google treats the data it receives under its own terms.
4.2 Google User Messaging Platform (UMP) SDK
Purpose: shows Google's consent form and the privacy options.
Data: your consent record.
4.3 Apple StoreKit
Purpose: purchases. Data: handled by Apple. We keep product and transaction information on your device only.
4.4 Apple UserNotifications
Purpose: local reminders only. There is no push token and no push server. Nothing leaves your device. It starts only after you say yes to our reminder question and to the iOS permission.
5. Consent and your choices
Privacy choice screen: before your first level, in the European Union, the EEA, the United Kingdom, Switzerland, Turkey and wherever the app cannot tell your region, the app shows a privacy screen. It offers "Accept optional", "Essential only" and "Manage choices" for the optional parts: the event log and personalised ads. Nothing in the app is locked behind saying yes, and the app works fully with "Essential only".
Change your mind: Settings > Privacy has the same choices, and the Analytics and Crash reports switches. In version 1.0 these switches only control what is written to the log on your device, because no analytics or crash service is built in.
Google's consent form appears before ads are requested in the regions where Google requires it, for example the EEA, the United Kingdom and Switzerland. Where it applies you can open it again under Settings > Privacy > Ad choices.
Delete data: Settings > Delete data erases what the app stores on your device (see section 10).
6. Ads and tracking
The app is free and is supported by ads. The first levels have no full-screen ads. After that, full-screen ads can appear between levels, and rewarded videos are always optional: you see the reward before you choose to watch. There are no banner ads.
On iPhone, before personalised ads can be used, the app shows Apple's "Ask App Not to Track" prompt. If you allow tracking, ads may use the advertising identifier of your iPhone. If you decline, ads are still shown, but they are not personalised by the advertising identifier. Ads are non-personalised unless you allow it. All features keep working either way.
App Store privacy label: because the ad SDK may track you after you allow it, the app declares tracking. The label lists the data types that Google's ad code may collect.
What Google's ad code may collect
Google describes this on its own pages for the Google Mobile Ads SDK; the exact list depends on the SDK version and on your choices. In summary:
| Data | What it is | Why Google uses it |
|---|---|---|
| IP address | Your network address. It can show your approximate area. | Show ads, limit how often they appear, prevent fraud |
| Device and advertising identifiers | An app or device identifier. The advertising identifier (IDFA) only if you allow tracking in iOS. | Show and measure ads, personalise ads if you allow it, prevent fraud |
| Ad interactions | Which ads were shown, taps, app launches and video views | Measure ad performance |
| Diagnostics and performance | Crash logs and performance figures of the ad code, such as launch time or hang rate | Keep the ad code working |
| Consent record | Your answers in Google's consent form | Respect your choices |
Google's privacy policy: policies.google.com/privacy. How Google uses data from apps that use its services: policies.google.com/technologies/partner-sites.
How to opt out of personalised ads and tracking
- In the app: Settings > Privacy > Ad choices (shown where Google requires it), and the privacy choice screen options.
- On iPhone: Settings > Privacy and Security > Tracking. You can switch tracking off for Gemlign, or for all apps, at any time.
- Reset or clear your advertising identifier with the controls your device offers.
- Google's ad settings: myadcenter.google.com.
- Remove ads: buying Remove ads removes the full-screen ads. Rewarded videos stay optional.
For people in some US states, the ad SDK may count as a "sale" or "sharing" of information (see section 10).
7. Purchases
All purchases go through Apple. We never see or store your card details or Apple ID.
Items: Remove ads, gem packs, helper bundles, a starter pack, a gem jar and the gold track of the monthly Jewel Pass. Prices are shown in the App Store sheet. The Jewel Pass is a one-time purchase for the running month and is not a subscription.
Restore purchases brings back Remove ads and the other one-time purchases. Gems, helpers and Jewel Pass months that were already paid out are stored on your device and are not brought back by Restore purchases; they may not come back after a reinstall.
Refunds go through Apple. If Apple refunds a purchase, the app removes the matching entitlement where it can.
8. Notifications (local only)
The app can show a reminder when your daily reward is ready. It is scheduled on your device by iOS. There is no push server and no push token.
The app asks only when the reminder is offered, and saying no changes nothing else in the app. You can change it any time in iOS Settings or in the app.
Delete data cancels pending local notifications.
9. Children
The app is intended for people 13 and older (the App Store rating is 13+). It is not directed to children under 13, and we do not knowingly collect personal information from children under 13.
We do not verify age.
If you believe a child under 13 has given us information, write to support@luminastudio.ai and we will delete what we can find.
10. Your rights and how to use them
10.1 For everyone
Everything the app stores for you is on your device. You can see and delete it yourself: Settings > Delete data removes your progress, gems, helpers, settings, the event log, the Player ID and local notifications. It does not remove purchases (use Restore purchases) or anything held by Apple or Google.
Because the game has no account and sends us nothing, we hold no profile of you. We cannot find data from your name or email. If you emailed us, we hold that email (section 11).
Withdrawing consent: use the choices in Settings. They take effect at once. For ads, use Ad choices and the iOS tracking setting.
Data held by Apple or Google is governed by their policies and controls.
Requests: write to support@luminastudio.ai. We have no postal address for requests; email is the way to reach us.
10.2 European Union, European Economic Area, United Kingdom and Switzerland (GDPR)
You may have the right to access, correct, delete, restrict, object to and move your data, to withdraw consent at any time, and to complain to your data protection authority.
Our reasons for using data: the on-device log and personalised ads, because you agreed on the privacy screen or in Google's consent form where it is required; purchases, because Apple processes them to deliver what you bought; support email, because you wrote to us and we answer.
We aim to answer within one month.
10.3 California and other US states (CCPA / CPRA and similar laws)
You may have the right to know what we collect, delete it, correct it, and opt out of "sale" or "sharing" for cross-context advertising.
We do not sell personal information for money. The ad SDK may count as "sharing" for advertising. Where the law requires it, the app shows Google's privacy options form under Settings > Privacy > Ad choices.
We do not discriminate against you for using these rights.
10.4 Turkey (KVKK)
You may apply to us about your personal data under the Turkish Personal Data Protection Law, for example to learn whether it is processed, ask for correction or deletion, and object. We aim to answer within 30 days.
The privacy screen and Google's consent form ask for your consent separately. This notice is in English only in version 1.
10.5 Everywhere else
Depending on where you live you may have similar rights. Write to support@luminastudio.ai and say which country you are in.
11. How long we keep data (retention)
| Data | Period | Note |
|---|---|---|
| Save data on your device | Until you delete the app or use Delete data | Your own device backup may keep a copy |
| Local event log on your device | Until you use Delete data or delete the app | Never sent in version 1.0 |
| Website host access logs | 30 days at most | IP address and request time |
| Support emails | 12 months after the last message | Then deleted |
| Ad SDK data | Google's rules | See Google's controls |
| Purchase records | Apple's policy | Not ours |
12. International transfers
Google may process ad data outside your country, including outside the EU, UK and Turkey, under its own terms and transfer mechanisms. Our website host and Apple may also process data in other countries. The app sends no analytics or crash data anywhere in version 1.0.
13. Where to read this policy
The link is in the App Store listing, on the privacy screen, and in Settings > Privacy. The links to this policy, the terms and support open in your phone's web browser, not inside the app.
14. Contact
Questions, requests or complaints about privacy: support@luminastudio.ai
Mehmet Aktug, trading as Lumina Studio. Website: gemlign.luminastudio.ai
15. Changes to this policy
We will update this page when the app, its SDKs or the law change, and change the "Last updated" date. Adding a new SDK or a new kind of data requires updating this policy first. Features that are not in version 1.0, such as an analytics service, a crash reporting service, a leaderboard or cloud save, are described here only when they ship. If a change matters to you, we will say so on this page and in the app's release notes.
Change log. 2026-11-13: first version of the Gemlign privacy policy, for Gemlign 1.0.