Christopher's Genie Privacy Policy

1. Introduction

GMI Partners Inc., operating as GMI Studios ("we," "us," or "our"), is committed to protecting the privacy of all players of Christopher's Genie ("the Game"), a free-to-play mobile match-3 puzzle game available on iOS and Android, based on the YouTube series of the same name.

This Privacy Policy explains what information we collect, how we use and share it, your rights and choices, and how we protect your data. This policy applies to users of the Game.

By downloading, installing, or using the Game, you acknowledge this Privacy Policy. Where applicable law requires consent for a particular activity, we request it separately. For questions, contact us at support@gmistudios.io.

2. Information We Collect

2.1 Information You Provide Directly

• Account and age-gate information: username/display name, avatar selection, guild preferences, and the result of the rewarded-ad age check (under 13, age 13 to 17, or age 18 or older); the exact age entered in the slider is not sent to our servers
• Authentication data: if you sign in with Apple (Apple user ID, and optionally your name and email) or Google Play Games (Google Play Games player ID)
• User-created content: custom levels you build and share within the Game
• Support communications: messages and information you provide when contacting our support team

2.2 Information Collected Automatically

When you use the Game, we and our third-party service providers automatically collect the following:

• Device information: device model, operating system version, app version, platform (iOS/Android), screen resolution, and language settings
• Device identifiers: push notification token, and through our integrated SDKs, advertising identifiers (IDFA on iOS, GAID on Android) where permitted by your platform settings and applicable law
• Gameplay data: game progress, scores, achievements, genie collection and upgrades, Blob League rankings, level completion data, session duration, feature usage, and in-game events
• Purchase history: records of in-app purchases (transactions are processed by Apple or Google; we do not receive or store your payment card details)
• Technical and diagnostic data: crash reports, error logs, performance metrics, and loading times
• Approximate location: coarse, city-level location derived from your IP address (used by Mixpanel for analytics geolocation). We do not request device GPS or precise location permissions
• Referral data: when you use or receive an invite link, metadata such as friend codes, invite identifiers, and referral source information is processed through AppsFlyer

2.3 Information We Do NOT Collect

For clarity, we do not collect: precise GPS location, contacts, photos, microphone or camera access, browsing history, phone number, physical address, or financial account information.

3. Third-Party Services and SDKs

The Game integrates the following third-party services, each of which may collect data as described below and in accordance with their own privacy policies:

Each of these services operates under its own privacy policy. We encourage you to review their respective policies for full details on their data practices.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and operate the Game: deliver gameplay, process purchases, manage accounts, and enable features like guilds and the Blob League
• Improve the Game: analyze gameplay patterns, identify bugs, balance game mechanics, and develop new levels and features
• Communications: send push notifications about events, rewards, and updates (with your consent, revocable at any time via device settings)
• Moderation and safety: review user-created content, enforce our Terms of Service, and detect cheating or fraudulent activity using automated tools, gameplay analytics, and manual review
• Attribution and referrals: track where installations come from and manage the invite/referral system
• Diagnostics: monitor crashes, errors, and performance to maintain service quality
• Legal compliance: comply with applicable laws, respond to lawful requests, and protect our legal rights

5. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

• With other players: your username, scores, Blob League rankings, guild membership, and user-created levels are visible to other players within the Game
• With service providers: the third-party SDKs listed in Section 3 process data to provide analytics, attribution, rewarded advertising, error monitoring, hosting, and notifications, subject to their terms and applicable privacy obligations
• With platform partners: Apple and Google receive purchase transaction data through their respective app stores
• For legal reasons: when required by law, subpoena, court order, or governmental request, or when necessary to protect our rights, safety, or property
• In a business transfer: if GMI Studios is involved in a merger, acquisition, bankruptcy, or asset sale, your information may be transferred to the acquiring entity. We will provide notice before your data becomes subject to a different privacy policy

6. Advertising Identifiers and Tracking

Christopher's Genie offers optional rewarded advertisements that grant an in-game reward after verified completion. Rewarded ads are provided through Unity LevelPlay, which may use ironSource Ads, Unity Ads, and Google AdMob. A neutral age screen in the Game is completed before a rewarded ad is loaded:

• iOS: The Game uses Apple's App Tracking Transparency (ATT) framework to request permission before accessing IDFA or tracking activity across other companies' apps and websites. You can change this at any time in your device's Settings > Privacy > Tracking.
• Android: Rewarded ads are not offered to players identified as under 13. Players identified as age 13 to 17 receive only non-personalized rewarded ads. For players identified as age 18 or older, the Google Advertising ID (GAID) and personalized ads may be used only where permitted by platform settings and applicable law. You can reset or opt out of personalized advertising in your device's Settings > Google > Ads.
• Meta/Facebook SDK: The Meta SDK is configured with automatic app event logging and advertiser ID collection enabled. This data is used for analytics and attribution and is not used by us to select rewarded ads. You can manage your Meta data preferences at facebook.com/adpreferences.

7. Children's Privacy

We use age-based safeguards for certain features, including rewarded advertising, and handle personal information in accordance with applicable privacy laws.

7.1 Data Collection from Children Under 13

• Age-check information is used to apply the rewarded-ad settings described below; the exact age entered in the slider is not sent to our servers
• Rewarded ads are not offered to players identified as under 13
• Players identified as age 13 to 17 may be offered only non-personalized rewarded ads. Players identified as age 18 or older may receive personalized rewarded ads where permitted by their platform settings and applicable law

7.2 Parental Rights

Parents and guardians may at any time:

• Review the personal information we have collected from their child
• Request correction or deletion of their child's data
• Refuse further collection or use of their child's information
• Request that we stop sending push notifications to their child's device

To exercise these rights, contact us at support@gmistudios.io. We will verify the parent-child relationship before processing any request.

7.3 Parental Controls

We strongly encourage parents to use the built-in parental control features on their child's device (Apple Screen Time, Google Family Link) to manage in-app purchases, screen time limits, and app access.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this policy:

• Account and gameplay data: retained while your account is active and as reasonably necessary afterward for security, backups, disputes, and legal obligations
• Analytics data: retained according to our operational needs and provider settings, and may be aggregated or anonymized when it is no longer needed in identifiable form
• Purchase records: retained as needed for transaction records and applicable tax, accounting, and legal obligations
• Crash and error logs: retained as reasonably needed to diagnose problems, maintain security, and improve reliability
• Support communications: retained as reasonably needed to resolve requests, maintain records, and address disputes

When information is no longer reasonably needed, we delete or anonymize it, subject to legal obligations, security needs, dispute resolution, and ordinary backup processes.

9. Data Security

We implement technical and organizational measures to protect your information, including:

• Encryption of data in transit (TLS/SSL)
• Access controls limiting employee access to personal data on a need-to-know basis
• Infrastructure hosted on AWS with industry-standard security practices
• Cloudflare for DDoS protection and web application security
• Regular monitoring through Sentry and Firebase Crashlytics for anomalies

No system is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If we become aware of a data breach affecting your personal information, we will notify you and applicable authorities as required by law.

10. International Data Transfers

GMI Studios is headquartered in Vancouver, Canada. Personal information may be stored or processed in Canada, the United States, and other locations where our service providers operate.

When personal information is processed outside your jurisdiction:

• Safeguards: we use contractual, organizational, or other safeguards where required by applicable law
• Service providers: our service providers process information under their own terms and applicable privacy obligations
• Local laws: information processed in another country may be subject to the laws of that country

11. Your Privacy Rights

11.1 All Users

Regardless of where you live, you may:

• Request access to the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your account and associated data
• Disable push notifications through your device settings at any time
• Choose not to view optional rewarded ads and manage advertising identifier or personalization choices through your device settings

To exercise these rights, email support@gmistudios.io. We will respond within the period required by applicable law.

11.2 EU/EEA/UK Residents (GDPR)

Under the General Data Protection Regulation, you additionally have the right to:

• Receive your personal data in a structured, commonly used, machine-readable format (data portability)
• Restrict the processing of your personal data in certain circumstances
• Object to processing based on our legitimate interests
• Withdraw consent at any time where consent is the legal basis for processing
• Lodge a complaint with your local supervisory authority

Legal bases for processing: We process your data based on: (a) your consent (for example, push notifications and ATT opt-in), (b) performance of our contract with you (Terms of Service), (c) our legitimate interests in operating, improving, and securing the Game, and (d) compliance with legal obligations.

11.3 California Residents (CCPA/CPRA)

Under the California Consumer Privacy Act and California Privacy Rights Act:

• You have the right to know what personal information we collect, use, and disclose (detailed in Sections 2-5)
• You have the right to request deletion of your personal information
• You have the right to opt out of the "sale" or "sharing" of personal information. We do not sell personal information. Our use of analytics and attribution SDKs may constitute "sharing" under CPRA; you may opt out by adjusting your device's tracking settings
• You have the right to non-discrimination for exercising your privacy rights

To submit a verifiable consumer request, email support@gmistudios.io. We will verify your identity before processing.

11.4 Canadian Residents (PIPEDA)

Canadian residents may have rights under applicable federal or provincial privacy laws, including rights to request access or correction and to withdraw consent where consent is the basis for processing. Contact our Privacy Officer at support@gmistudios.io.

12. "Do Not Track" Signals

Some web browsers transmit "Do Not Track" signals. As a mobile application, Christopher's Genie does not currently respond to browser-based DNT signals. However, you can control tracking through your mobile device's settings as described in Section 6.

13. Third-Party Links and Content

The Game may contain links to external services, including the Christopher's Genie YouTube channel and social media pages. When you follow an external link, the third party's terms and privacy policy apply, and we are not responsible for its practices.

14. Changes to This Privacy Policy

This Privacy Policy is effective as of July 30, 2026 and supersedes prior versions of the Privacy Policy for the Game. By continuing to use the Game, you acknowledge the practices described in this policy.

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through an in-game notification or pop-up. The effective date at the top of this policy will be updated accordingly. If a change requires notice or consent under applicable law, we will provide that notice or request consent as required.

15. Contact Us

If you have questions, concerns, or wish to exercise your privacy rights:

For EU/UK residents, you may also contact your local data protection authority if you believe your privacy rights have been violated.