Privacy Policy

1. Who we are

Virtual Gems LTD (“we”, “us”, “our”) builds and publishes mobile apps. We are the controller of your personal information, which means we decide how it is used and are responsible for it under UK data protection law.

Company

Virtual Gems LTD, registered in England and Wales, company number 17570097

Registered office

[Registered office address]

Privacy contact

admin@virtualgems.co.uk

ICO registration number

[add once registered]

Send any question or request about your personal information to the privacy contact above.

2. What this policy covers

This is the general privacy policy for every Virtual Gems app. It explains what personal information we collect, why, and what your choices are, wherever in the world you use our apps or contact us.

Each app also has its own privacy notice, available in the app and on its store listing. That notice gives the specifics for that app: exactly what it collects, the permissions it asks for and the providers it uses. If an app’s notice differs from this policy, the app’s notice applies to that app.

The app stores and sign-in services you use with our apps (such as Apple and Google) have their own privacy policies. Those policies cover what they do with your information for their own purposes.

3. Information we collect

We collect only what our apps need to work, to be improved and to be kept secure. We do not show third-party advertising and we do not sell your personal information.

What we collect depends on the app and the features you use. Each app’s privacy notice lists exactly what applies to it.

Information you give us

• Account details: your email address and password. Passwords are stored in hashed form, so we cannot read them.
• Profile details: a display name or profile photo, where an app offers a profile.
• Content you add: the things you create, log or upload in an app, such as entries and photos.
• Messages to us: what you send when you ask for support or give feedback.
• Marketing choices: whether you have opted in to marketing emails.

Information collected automatically

• Device information: device model, operating system version, language, time zone, app version and device identifiers.
• Usage information: screens viewed, features used, session times, and crash and error reports.
• IP address: and the approximate location (country or city) it indicates. We do not collect precise GPS location.
• Push notification token: an identifier that lets us send notifications to your device, if you allow them.

Information we receive from others

• Apple or Google sign-in: if you sign in this way, we receive an account identifier and your email address, and sometimes your name. Apple lets you hide your real email address behind a relay address. We never receive your Apple or Google password.
• App stores: when you buy something, Apple or Google tells us what you bought, when, and whether a subscription is active. We never receive your card details.

Some apps may ask for more sensitive information, such as health or fitness details. Where one does, its privacy notice says so and we ask for your explicit consent first. Otherwise, please do not upload sensitive information about yourself or other people.

4. How we use your information

UK law requires us to have a lawful basis for each use of your personal information. The table shows what we do and the basis we rely on.

Where we rely on consent, you can withdraw it at any time (see section 12). Where we rely on legitimate interests, you can object.

You need to give us account details to create an account. Without them we cannot provide the parts of the apps that need one.

We do not make decisions about you by automated means alone that have a legal or similarly significant effect on you.

5. Device permissions

Some apps ask for access to parts of your device, such as the camera, your photo library or notifications. An app asks only at the moment a feature needs it. Every permission is optional, and saying no affects only the feature that depends on it.

Each app’s privacy notice lists the permissions it uses and why.

You can change these at any time in your device settings: on iPhone, Settings and then the app’s name; on Android, Settings, Apps, the app’s name, then Permissions.

6. Marketing emails

We send marketing emails only if you have opted in. Every marketing email has an unsubscribe link, and you can also opt out by emailing admin@virtualgems.co.uk.

Opting out does not stop service messages we need to send, such as password resets or notices about changes to this policy.

We never give your email address to other companies for their own marketing.

7. Who we share information with

We share personal information only with the service providers that help us run the apps, and where the law requires it. Our service providers act on our instructions under contract.

Some apps use additional providers. Each app’s privacy notice names them.

Apple and Google also use information for their own purposes, as independent controllers, under their own privacy policies.

We may also share information with:

• professional advisers, such as lawyers and accountants, where needed for their advice;
• regulators, courts and law enforcement, where the law requires it or to protect our rights or the safety of others;
• a buyer or successor, if our business or an app is sold or reorganised. We will tell you before your information moves to a new owner.

We do not sell your personal information or share it with advertisers.

8. Purchases and subscriptions

All payments in our apps are taken by the Apple App Store or Google Play, not by us. We never see or store your card details.

The store tells us what you bought, when, and whether your subscription is active, so we can unlock what you paid for.

You manage and cancel subscriptions in your App Store or Google Play account settings. Refunds are handled by the store under its own terms. Deleting your account with us does not cancel a subscription, so cancel it in the store first.

9. Children and young people

Our apps are for a general audience and are not intended for children under [13]. We do not knowingly collect personal information from children under that age.

If you are a parent or guardian and believe your child has given us personal information, email admin@virtualgems.co.uk. We will delete it.

In some countries the age at which you can agree to the use of your information is higher, up to 16. If you are under that age where you live, you need a parent or guardian’s permission to use our apps.

Because people under 18 may use our apps, we design them with the UK Children’s Code in mind:

• we collect only the information a feature needs;
• we do not show third-party advertising;
• we do not collect precise location;
• camera, photos and notifications stay off until you choose to turn them on;
• [we do not send marketing emails to anyone we know is under 18: confirm or delete].

10. International transfers

We are based in the UK, but some of our service providers process information in other countries, including the United States and countries in the European Economic Area (EEA).

Our main database is hosted by Supabase in [region, for example London, UK].

When personal information leaves the UK, we protect it in one of these ways:

• sending it only to a country, or to an organisation certified under a framework, that UK regulations recognise as giving adequate protection; or
• using contract terms approved for this purpose in the UK: the International Data Transfer Agreement, or the UK Addendum to the EU standard contractual clauses.

Email admin@virtualgems.co.uk if you would like to know which safeguard applies to a particular provider.

11. Security and how long we keep information

We protect your information with encryption in transit and at rest, hashed passwords, and access limited to the people who need it for their work. No system is completely secure. If a breach is likely to put you at high risk, we will tell you and the regulator as the law requires.

We keep information only as long as we need it for the purposes in this policy.

An app’s privacy notice may set different periods for information specific to that app.

You can delete your account at any time in the app at [Settings, then Delete account], or by emailing admin@virtualgems.co.uk.

12. Your rights

You have these rights over your personal information:

• Access: ask for a copy of the information we hold about you.
• Correction: ask us to fix information that is wrong or incomplete.
• Deletion: ask us to delete your information.
• Restriction: ask us to limit how we use it.
• Objection: object to uses based on legitimate interests. You can always object to marketing, and we will stop.
• Portability: ask for the information you gave us in a format you can move to another service.
• Withdrawing consent: withdraw any consent you have given. This does not affect what we did before you withdrew it.

To use any of these rights, email admin@virtualgems.co.uk. It is free. We reply within one month, or tell you if a complex request needs longer. We may ask for proof that you are the account holder.

Some things you can do yourself: edit your profile and delete your account in the app, change permissions in your device settings, and unsubscribe from the link in any marketing email.

13. If you live outside the UK

The rights in section 12 apply to everyone who uses our apps, wherever they live. Local law may add to them.

European Economic Area

The EU General Data Protection Regulation also applies to how we handle your information. You can complain to the data protection authority in the country where you live or work. [Our EU representative is: name and address, or delete this sentence.]

United States

We do not sell your personal information, and we do not share it for targeted advertising. Depending on your state, you may have rights to know what we hold, to correct it and to delete it. We will not treat you differently for using those rights, and you may ask an authorised agent to make a request for you.

Our apps are not directed to children under 13, and we do not knowingly collect their personal information.

Other countries

If the law where you live gives you further rights, we will respect them. Email admin@virtualgems.co.uk to use them.

14. Complaints

If you are unhappy with how we have handled your personal information, please tell us first by emailing admin@virtualgems.co.uk. You have a right to complain to us.

We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay.

You can also complain to the UK regulator, the Information Commissioner’s Office (ICO), at any time:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

15. Changes to this policy

We update this policy when our apps or the law change. The current version is always available in the apps and at https://virtualgems.co.uk/privacy.

If a change significantly affects how we use your information, we will tell you in the app or by email before it takes effect.