Privacy Notice for Mobile Applications
This notice supplements our Privacy Policy (Japanese). With respect to the App, if this notice conflicts with other provisions of the Privacy Policy, this notice prevails. The Japanese version is authoritative; in case of any discrepancy between language versions, the Japanese version prevails. ALTO Inc. (“we”, “us”) provides this notice for the mobile game application “Jewel Sort: Gem Puzzle” (the “App”).
Last updated: August 14, 2026
1. Information We Collect and Why
The App does not collect information that by itself allows us to identify you, such as your name or email address. There is no account registration. Game save data (your progress) is stored only on your device, and the save data itself is never transmitted. However, some gameplay information — such as the level numbers you start and clear — is sent as usage analytics events described in Section 1.2.
The App uses the following third-party services, which may collect device information for ad delivery, usage analytics, crash reporting, and consent management.
1.1 Advertising (Google AdMob)
We use Google AdMob, provided by Google LLC, to display ads. The App may show an interstitial ad after you clear a level, after you undo a move, or after you retry a level (including an automatic restart when no moves remain), subject to conditions such as display intervals and random selection. AdMob may collect advertising identifiers (Android Advertising ID / iOS IDFA), IP address, device information (model, OS), ad and app interaction data (such as taps, impressions, and video views), and diagnostic information for ad delivery, measurement, and fraud prevention.
- In regions where prior consent is required (such as the EEA, the UK, and Switzerland), personalized ads are served only with your consent. Without consent to personalization, or if you decline, non-personalized, limited, or technical ads may still be served.
- On iOS, if you do not allow tracking in Apple’s App Tracking Transparency (ATT) prompt, the IDFA is not used for advertising.
For details on how Google handles data:
- Google Privacy Policy
- How Google uses information from sites or apps that use its services
- AdMob ad technology providers
1.2 Usage Analytics (Google Analytics for Firebase)
We use Google Analytics for Firebase, provided by Google LLC, to improve the App. Collected events include:
- Level start / clear / restart / undo (level number, moves, duration, etc.)
- Interstitial ad display (level number, etc.)
- Ad revenue information (value, currency, ad format, ad unit)
- Events collected automatically by the Firebase SDK, such as first open and session start
These events carry device-level identifiers such as an app-instance ID and, depending on your settings, the advertising ID, as well as an approximate location derived from a (masked) IP address and diagnostic information. We do not use these identifiers to identify individuals. See Privacy and Security in Firebase.
1.3 Crash Reporting (Firebase Crashlytics)
We use Firebase Crashlytics, provided by Google LLC, to fix defects. When a crash occurs, execution state (stack trace, device model, OS, timestamp, etc.) is collected.
1.4 Consent Management (Google User Messaging Platform)
We use the Google User Messaging Platform (UMP), provided by Google LLC, to obtain and manage consent. UMP communicates with Google — including approximate region determination and device information — to decide whether a consent form is required and to check consent status.
2. Consent and Your Choices
Collection is off by default on a fresh install, and the App does not send analytics or crash data to third-party services until it has been determined whether consent is required, your consent status has been confirmed, and collection has been enabled. If collection is enabled as a result of this confirmation, events temporarily held in the App in the meantime may then be sent. Once collection has been enabled, on subsequent launches some information (such as automatic launch events or crash data) may be sent on the basis of your most recent effective setting during the brief interval before your settings are re-checked and applied.
- Users in the EEA, the UK, and Switzerland are shown a consent form at first launch. Your choices there (including per-purpose and per-vendor choices) apply to ad personalization. Whether analytics and crash reporting are enabled is also determined by your choices for measurement-related purposes and for Google.
- In regions not covered by the consent form (including Japan), the consent form may not be shown at first launch, depending on applicable law and the App’s configuration. In that case, analytics and crash reporting become active shortly after launch. If you do not want this, you can stop collection at any time using the settings below.
- On iOS, if Apple’s App Tracking Transparency (ATT) prompt is shown, you can choose whether to allow tracking.
You can change your choices at any time in the App (the “i” button at the bottom-left).
- Ad privacy settings — re-open the consent form (available to users in regions where the consent form applies).
- Stop / resume usage data collection — stop or resume the collection of usage data. After you stop, no further events are collected, and events from the stopped period are never sent retroactively. When you stop collection (including when you withdraw measurement-related consent via the consent form), unsent crash reports are discarded.
You can also control advertising identifiers and ad personalization through your device settings and your Google account’s ad settings.
Where the GDPR or equivalent laws apply, our legal bases for processing are as follows: ad personalization, usage analytics, and crash reporting are based on your consent (Art. 6(1)(a) GDPR); determining whether consent is required and checking consent status, serving and measuring non-personalized, limited, or technical ads, preventing fraud, and ensuring security are based on our or third parties’ legitimate interests (Art. 6(1)(f) GDPR).
3. Sharing and International Transfers
We share information collected in the App with third parties only in the cases set out in our Privacy Policy: with your consent, for outsourced processing to the extent necessary to achieve the purposes of use, pursuant to applicable laws and regulations, or in connection with a business succession. Transmission to the service providers listed in Section 1 (Google LLC), and transmission to Google-certified ad technology providers in the course of ad delivery, likewise take place within these cases.
Information collected in the App may be processed outside Japan — including in the United States — by Google LLC and, in the course of ad delivery, by Google-certified ad technology providers. Google LLC is certified under the EU-U.S. Data Privacy Framework, its UK Extension, and the Swiss-U.S. DPF, and states that it relies on Standard Contractual Clauses or other lawful transfer mechanisms for transfers not covered by an adequacy decision or the DPF (details: Google’s privacy frameworks). Transfer safeguards applied by ad technology providers vary by provider; please check each provider’s privacy policy (available from Google’s list of ad technology providers) and the vendor information shown in the consent form. For further information about these transfer mechanisms, including how to obtain a copy of the Standard Contractual Clauses where applicable, contact us using the form below.
4. Retention
We process information collected in the App only for as long as necessary to fulfil the purposes described in this notice. Specific retention periods are determined based on the type of information, the purpose of use, the settings of each service, legal obligations, and security needs. Information collected by third-party services is retained according to their policies (data retention at Google). We do not store collected information on our own servers.
5. Children
The App is not directed at children under 13. In addition, in regions where the minimum age at which a person can give valid consent on their own is higher than 13, the App is not directed at children under that age. If we learn that information about such a child has been collected, we will promptly take appropriate action, including deletion.
6. Your Rights (EEA / UK / Switzerland)
Where the GDPR or equivalent laws apply, you have the rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right to lodge a complaint with a supervisory authority. To exercise these rights, contact us using the form below. You can withdraw consent at any time via the in-app settings (Section 2); withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.