Privacy Policy

Last updated: 30 June 2026

This policy explains what personal data Gem TD ("the Game", "we", "us") collects when you play, how and why we use it, and the rights you have. Gem TD is operated by Jose Yebenes, an individual based in Spain, who is the data controller. You can reach us any time at [email protected].

You can play Gem TD entirely offline. Accounts, leaderboards, and cloud sync are optional and only activate when you choose to sign in or enable them. Until then, your scores and settings stay on your own device and are never sent to us.

1. Personal data we collect

Account data

Gameplay data

Technical data

2. Cookies & local storage

Gem TD uses only strictly necessary cookies — no advertising, analytics, or cross-site tracking cookies. Under the EU ePrivacy rules and Spain's LSSI (Ley 34/2002), strictly necessary cookies are exempt from prior consent, so the Game does not show a cookie banner.

3. Why we use your data, and our legal basis

Under the GDPR (Regulation (EU) 2016/679) and Spain's LOPDGDD (Ley Orgánica 3/2018), we rely on:

There is no automated decision-making that produces legal or similarly significant effects on you. Providing this data is never a statutory or contractual requirement — it is entirely optional and only needed if you want the online features.

4. Who receives your data

We do not sell your personal data and we do not show ads. We share data only with the processors that run the Game:

Your public leaderboard handle and scores are visible to other players. Your profile is private by default; detailed stats are shown publicly only if you opt in.

5. International transfers

Gem TD runs on Cloudflare's global network, so your data may be processed on servers outside the European Economic Area. Where that happens, the transfer is covered by appropriate safeguards — an adequacy decision or the European Commission's Standard Contractual Clauses, as set out in Cloudflare's Data Processing Addendum.

6. Your rights

Under the GDPR you have the right to:

To exercise any of these, email [email protected]. You can stop cloud features at any time by signing out and disabling cloud sync in the Game. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es) or your local supervisory authority.

7. Data retention

We keep your account and gameplay data until you ask us to delete it, or until your account is removed for a Terms violation. On account deletion we remove your account record and personal identifiers; aggregate or anonymised leaderboard data may be retained. Security logs are kept only for a short period.

8. Children

Gem TD is not directed to children under 13, and you must be at least 13 years old to create an account or use cloud features. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided us data, contact us and we will delete it.

9. Security

We protect accounts with HttpOnly authentication cookies, hashed tokens, token rotation with theft detection, and rate-limiting. No system is perfectly secure, but we take reasonable measures to safeguard your data.

10. Changes to this policy

We may update this policy from time to time. Material changes will be reflected by the "Last updated" date above.

Contact

Questions about your data or this policy, or to make a request? Email [email protected].