Privacy Policy

Indie Gems, LLC · Last updated 31 August 2026

Welcome to Gem Arcade! This Privacy Policy describes how Indie Gems, LLC and its affiliates (“Gem Arcade,” “we,” “us” and “our”) collect, use, disclose, and otherwise process your personal information, and describes the choices and rights you may have with respect to your personal information. We use information about you to fulfil our commitment to providing you a great arcade gaming experience.

This Privacy Policy applies to all personal information that is collected by Gem Arcade during any written, electronic, and oral communications online when you:

• interact with our websites, pages, features or content that links to this Privacy Policy, such as https://gemarcade.com/ (collectively, the “Sites”);
• download, install, and use our Gem Arcade launcher downloadable software (“Software”)
• engage any associated tools, or services developed and managed by Indie Gem that link to this Privacy Policy (collectively, including the Site and the Software, the “Services”).

By accessing, visiting, or using our Services, you acknowledge this Privacy Policy and, if you are Gem Arcade user, you agree to the Gem Arcade Terms & Conditions. If you are not comfortable with any part of this Privacy Policy or do not agree with the applicable Terms, please immediately discontinue access or use of our Services.

We may make changes to this Privacy Policy from time to time and will post the date it was last updated at the top of this Privacy Policy. Unless otherwise noted, any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. We will provide additional notice to you if we make changes to this Privacy Policy that materially affects your privacy rights in accordance with applicable laws. We may also provide “just-in-time” disclosure or additional information about our information collection, use, and sharing practices for specific products or service offerings. These notices may supplement or clarify our privacy practices or provide you with additional choices about how we process your personal information.

1. PERSONAL Information We Collect

We collect certain personal information about you and your use of our Services. The definition of personal information (used interchangeably with “personal data”) depends on the applicable law based on your physical location or state residency. Depending upon the law in your jurisdiction, only the definition that applies to your state of residence or location residency will apply to you under this Privacy Policy. The personal information that we collect generally falls into three primary categories: (1) information you voluntarily provide to us; (2) information we collect from you automatically; and (3) information we collect from third parties.

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal information from you:

• Account and Profile Management. When you create a Gem Arcade account, we may collect your email address, display or user handle, password, and information used to verify that you meet our minimum age requirement, such as your date of birth or a confirmation of your age. We may also collect account settings and preferences you configure, including your language preference and communication preferences.
• Payment and Purchase Information. We and our payment processors may collect payment information when you purchase games, tokens, credits, or digital goods through our Services, such as your name, email address associated with your Gem Arcade account, payment card or other payment method information, billing address, and phone number. We receive and retain transaction records, including items purchased, price, currency, purchase date, and billing country, which we use for order fulfillment, receipts, refunds, tax, and fraud-prevention purposes.
• Customer Support. When you engage with our customer support, including by emailing support@gemarcade.com, we may collect records and copies of your correspondence (including email addresses), and any additional information you choose to share with us.
• Competition, Promotional Activity or Sweepstakes (“Promotion”). If you choose to participate in a Promotion through our Services, we will collect and store the personal information you provide in connection with your participation in the Promotion, which may include, your name, date of birth, address email address, phone number, and/or other personal information identified in the Promotion terms. We use the information you provide to administer our promotions. We also may use the information to communicate with you about our products, services, and other promotions.
• Friends and Chat. When you use our social features, we may collect your friends list and friend requests, and the content of messages you send or receive through chat.
• Feedback or Surveys. We may provide you the opportunity to participate in surveys or provide feedback about your experience using our Services. If you participate, we may request certain personal information from you, typically including contact information (such as name and email address). Participation in these surveys is entirely voluntary. We use this information to improve our services and product offerings.

Information We Automatically Collect. To the extent permitted under applicable law, we may automatically collect certain types of personal information about you when you use or interact with our Services.

• Game Metrics Data. When you add games to your library, play free demos, or access purchased games, we automatically collect your game selections, download history, game library contents, and gameplay activity (games launched, session length, in-game progress).
• Gem Arcade Launcher Software. When you download and install our Gem Arcade launcher, we may collect your game selections, download history, game library contents, gameplay activity (games launched, session length, in-game progress). We may also collect information about your device (hardware model, operating system, unique device or installation identifiers), any crash reports, and technical logs used to operate, secure, and improve the service.
• Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data.
• Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID.
• Location Data. When you use our Services, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. We do not collect precise GPS data unless explicitly enabled by the user for specific features. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Information We Collect from Third Parties. From time to time, we may obtain information about you from third party sources as required or permitted by law. These sources may include:

• Social Media. We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver the content or as part of the operation of the third-party website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on our Services and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.
• Other Individuals. We may receive certain information about you from people with whom you are friends or otherwise connected. Please note, if you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Policy.

2. Why We Collect Your Information

We may process your personal information in connection with any of the following:

• To Operate and Administer Our Services. We may use your personal information to provide you with the Services that you request.
• To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us to respond to your inquiries and to fulfill your requests. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
• To Provide You with Service-Related Communications. We may send you administrative, or account-related information to you, for example, privacy policy and terms updates, and security updates. These administrative, service-related communications are not promotional in nature. You may not be able to unsubscribe from certain service-related communications, otherwise you may miss important developments relating to your account or the Services.
• To Provide Marketing Communications. Subject to your marketing preferences (which may include consent to marketing under applicable law), sending you newsletters or marketing communications we believe may interest you, for our Services.
• To Infer Your Interest and Personalize Your Experience. We may process your personal information to personalizing your experience on the Services by presenting offers tailored to you. We may use such information to enable you to interact with our Services more easily across devices, or to recommend more relevant content to you.
• To Research and Develop Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services, including by carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
• To Administer Promotional Events. When you participate in sweepstakes, contests, and similar promotions, we may process your personal information to administer such activities (each of which may have additional rules and could contain additional information about how we process your personal information). You have the right to decline to provide your consent and, if consent is provided, to withdraw it at any time.
• To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
• To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information when actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties; recover payments due to us; and protect our and others’ rights, privacy, safety, or property.
• To Ensure the Security of the Services. We may process your personal information to combat spam, malware, malicious activities, or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
• To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, or as necessary to manage risk as required under applicable law, or to respond to requests by judicial process or governmental agencies.
• With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related services requested, with your permission or upon your direction.

3. When We Disclose Your Information

• Our Corporate Group. We may disclose some or all of your personal information with our subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us for the purposes described in this Privacy Policy unless otherwise prohibited by applicable law or by contractual agreement with our vendors, service providers or other third parties.
• Vendors and Service Providers. We may disclose personal information to vendors, service providers, contractors, professional advisors, and other entities that process this information to provide services to us, such as: assisting us in e-commerce operations; managing a database of customer information; hosting the Sites; designing and/or operating the Sites’ features; tracking the Sites’ activities and analytics; and other legitimate business purposes. These service providers may have access to or process your personal information only for the purpose of providing services to us.
• Business Partners, Sponsors, and Other Third Parties. We may disclose your personal information to business partners, co-sponsors of promotions, and other third parties in order to provide you with services that may interest you. For example, we may co-sponsor promotions, sweepstakes, or other events with a third party and may share your personal information in connection with these events. If you provide additional information to any of these third parties, such information provided to these third parties will be subject to each third party's privacy practices and policies.
• As Necessary to Comply with Our Legal Obligations. We may disclose your personal information law enforcement authorities, government or public agencies or officials, regulators, and/or to any other person or entity having appropriate legal authority or justification for receipt of your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Gem Arcade or third parties (including through the enforcement of this Privacy Policy, our Terms, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas, or court orders).
• Corporate Transaction. We may disclose your personal information to a third party (e.g., prospective buyers and insolvency practitioners) in connection with any change in control of any part of our business or the business of any of our Affiliates, including, without limitation, merger, consolidation, divestiture, spin-off, purchase of all or a substantial portion of our assets, dissolution, liquidation, administration, receivership or other form of insolvency, including during the course of any due diligence process.

We may also share aggregated or anonymized data that does not personally identify you for purposes such as usage analysis, product improvement, or reporting trends.

4. Cookies and Similar Tracking Technologies

We and our service providers may automatically collect information from you when you use the Services using “cookies” and other tracking technologies like web pixels or software development kits (SDKs) to help us customize your experience and better manage content on our Sites and Apps, including to: (a) analyze our web traffic using an analytics package; (b) identify whether you already visited any of our affiliated websites; (c) store information about your preferences (e.g., cookie consent); and (d) to recognize when you return to our Services.

Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. Information that may be collected by cookies when you use the Site may include, without limitation: the pages you visit within the Stie; the date and time of your visit to the Website; the amount of time you spend using the Site; the IP address used to connect your computer to the Internet; and/or your computer and connection information such as your browser type and version, operating system and platform.

Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.

We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party's website for more information on how they use cookies. We use the following types of cookies on our Services:

How to Manage Tracking Technologies

Browser Controls. You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Sites although your access to some functionality and areas may be restricted. If you want to understand your browser’s cookie default setting, or learn to modify your browser’s cookie settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: 

• Google Chrome
• Microsoft Edge
• Microsoft Internet Explorer
• Apple Safari Mobile
• Android Browser

Opting out of Third-Party Analytics. We may use third-party service providers to monitor and analyze the use of our online, web-based, and mobile-based Services, such as Google Analytics. Google Analytics is an analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. To opt out of Google Analytics or to prevent your data from being collected and used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.

Disabling Most Interest Based Advertising.

Interest Based Advertising - Website Browser. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA), which maintains websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info.

Do Not Track. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, since uniform standards for “DNT" signals have not been adopted, we do not disable tracking technology that may be active on the Websites in response to any “do not track” requests that we receive from your browser.

5. Security of Your Information

We take reasonable steps to use appropriate physical, technical and organizational measures to help safeguard your personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. To help protect your information, we use encryption to secure data while it is in transit between your device and our servers; offer account-level protections such as secure password requirements and optional two-step verification; regularly review our systems and security protocols, including access controls and physical safeguards, to help prevent unauthorized access to data; limit access to personal information to authorized Gem Arcade personnel and service providers who require it in order to process or maintain the service. These individuals are bound by confidentiality obligations and may be subject to discipline or termination if they fail to comply. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all information you provide to us via the Services.

6. Third Party Links

The Services may have links to other websites that are not operated by us. We have no control over how these third-party websites may collect your information and no liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.

7. Children DATA

We understand the importance of protecting children’s privacy in the interactive world. Unless otherwise noted, our Services are not intended for individuals under the age of under the age of 13. Therefore, we do not knowingly process personal information from individuals under 13 years old. If you are under 13 years of age, you should not use the Services and should not send any information about yourself to us through the Services.

If you are a parent or guardian and you believe that your child has provided us with information without your consent, and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the “How to Contact Us” section below. If we become aware that a child under 13 has provided us with personal information without parental consent, we will terminate that user’s access to our Service and take steps to delete such information from our systems, unless we have a legal obligation to keep it.

8. Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Your Choices

Within your Gem Arcade account, you can review and adjust how certain types of personal information are collected, stored, and used, as well as manage your connections to third-party platforms. When you are signed in, you can review and update your account details, wallet balance, notification settings and connected platform settings. We are committed to providing clear options for how your information is handled, and we encourage you to review these settings regularly to ensure they reflect your preferences.

• Correct or Update Your Information. If you have created a user account through the Services, you will have the ability to access, update and correct the personal information you have provided in connection with your account by logging into your account through the Services. You may also control who can see your public profile or content associated with your account.
• Changes to Your Marketing Preferences. We offer you certain choices about how we communicate with you. You can change your marketing preferences by:
• Using the unsubscribe function in the email you receive from us;
• Contacting us as set forth under “How To Contact Us” below.

10. ADDITIONAL NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, AND SWITZERLAND

This section only applies to individuals using or accessing our Services while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time of data collection. Pursuant to the General Data Protection Regulation (“GDPR”), for the sake of clarity, references to personal information in this Privacy Policy concern personal data in the sense of the GDPR.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located. If any terms in this section conflict with other terms contained in this Privacy Policy, the terms in this section shall apply to individuals in the European Countries.

Our Relationship with You

Indie Gems, LLC is a data controller with regard to any personal information collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed.

Marketing

Based on your consent, we may inform you about our Services or invite you to event via email, online advertising, social media, telephone, or postal mail. You may withdraw your consent for receiving marketing messages from us at any time by using the unsubscribe function in the email you receive from us. For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see Section 4 – Cookies and Similar Tracking Technologies.

Legal Bases for Processing Your Personal Information

Your Privacy Rights

• Right to Access. You may have the right to obtain a copy of your personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal information that we process, the entities to whom we disclose your personal information, etc.
• Right to Rectification. You may have the right to request us correct any of your personal information in our files.
• Right to Erasure. Under certain circumstances, you may have the right to request erasure of your personal information that we hold about you. To note, this right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.
• Right to Restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances. For instance, this right is available if you contest the accuracy of the personal information, or if you have objected to our processing.
• Right to Object to Processing. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of consent or legitimate interests. However, we may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
• Right to Portability. Under circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another controller.
• Right to Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority or equivalent regulatory body. Contact details contact details for data protection authorities in the European Economic Area are available here, and contact details for the United Kingdom’s ICO are available here. The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC), available here.

Submitting a Request to Exercise Your Privacy Rights

To assert your privacy rights noted above, please email support@gemarcade.com and indicate which rights you would like to exercise.

To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may contact you to verify your request. Depending on your request, we will ask for information such as your name, display or user handle, or an e-mail address you have used with us.

International Transfer of Your Personal Information

We may, subject to applicable law, transfer your personal information, to selected third parties outside the country where you are located and where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). When required by applicable law, we will utilize appropriate safeguards governing the transfer and usage of your personal information, for example, Standard Contractual Clauses. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.

11. How To Contact Us

If you have questions about this Privacy Policy or our privacy practices please email us at support@gemarcade.com, or send your request by mail to Indie Gems, LLC, 3925 Brookside Pkwy, Suite 400, Alpharetta, GA 30022.