Lumi Interactive Privacy Policy

Last Update: January 2021

Galaxy Interactive Pty Ltd. and their subsidiaries and parent companies (collectively, “Lumi Interactive”, “Lumi Studios”, “we”, “our,” or “us”) are a gaming company that develops, produces, distributes and co-develops products and services for game developers and their players worldwide.

This is our privacy policy (the “Privacy Policy”), which explains how we collect, use and share data through our mobile games (the “Games”), our websites (the “Websites”), our pages or presence on third party websites (e.g., Facebook) (the “Third Party Platforms”) and other platforms, websites products, offers and services that we offer from time to time, all of which together we refer as “Services” or “Service”.

This Privacy Policy applies when you use our Services. Please read it before using our Services.

Galaxy Interactive Pty Ltd. in this Privacy Policy refers to Lumi Interactive, Lumi Studios and any other corporate entities within the same corporate group (including parent companies and subsidiaries) (“Affiliated Entities”).

If you do not want Lumi to collect, store, use, or share your personal information in the ways described in this Privacy Policy, you may not play our games or use our Services.


1.       INTRODUCTION

Our Privacy Policy applies whenever you use our “Services” which, as we described above, means our games, products, services, content, our websites, and/or other domains or websites operated by Lumi. It describes the ways we use your (personal) data and your rights.

Regardless of whether you are located in or outside of the European Union or European Economic Area, Lumi are the “joint data controllers” of your personal data. We will refer to countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland collectively as the “European Countries” in our Privacy Policy.

2.       DATA COLLECTION

We aim to minimize how much personal information we collect from users when they play the Games or use the Websites. The information we collect about you do not identify you personally but may uniquely identify the device you are using to play the Games or use the Websites (“Device”).

2.1   Data about you that you give us directly

While you use our games, you may give us data directly (like when you are setting up your account), and we will store that data on our databases and use it for the purposes described in this Privacy Policy.

When you use our games you may give us the data such as:

  • Player name and gender
  • Profile information (such as profile photo)
  • Chat log when you contact us for support
  • Other information that helps us make sure it is you accessing your account or helps us providing support to you. Please see the “Support correspondence” section for more detail.
2.3   Data generated using our games

When you use our games, we collect data about the ways in which you use and interact with our games, such as when and for how long you play, game features and other players you interact with, purchases you make, progress or levels you achieve, and other gameplay activities. If you choose to use communication features in Services that allow you to communicate or share information with other players, then we would collect information on what is communicated or shared.

2.4 Payment data

We also collect data related to any purchases you make. If you purchase in-game virtual currency, our third-party payment partners will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address, and financial data. Our payment partners do not share your financial information, like credit card numbers, with us.

When you play our games connected third-party applications or platforms (like Facebook, Apple or Google), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, Lumi does not receive your financial data, but may receive non-financial information related to your purchases, like the order number and the items purchased. The information Lumi receives depends on our game you are playing and the third-party application. Our Terms of Use explain our policies and terms related to charges, billing, third-party credits, and virtual currencies. Please note that purchases of third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

2.5 Other Data we automatically collect
  • Advertising ID which is a unique device identifier associated with your phone to tablet used by advertisers for ad tracking purpose
  • General location information (such as country and city of location when you play the game to be displayed in our multiplayer screen)
  • Device information (such as device name, operating system information, and language
2.6   Support correspondence

When you ask for help from our support team, we may collect and store the contact information you give to us (generally, your name, e-mail address, player ID), data about your game play or your activity in a game. We will also store the communications you have with our support and any additional information in those communications in order to provide support and improve the Services. Please note that in many cases in order to identify you we will need a minimum amount of data (e.g., player ID). Without this information, we will not be able to provide support or answering to your data rights’ requests (as mentioned in Section 5 below), so please be aware that we may contact you and request additional information in order to provide service.

When you contact us for support, the below information will be collected and handled by our support software Helpshift strictly in accordance with our instructions:

  • Player ID
  • Name or nickname
  • Problem description

Our processors also automatically collect additional types of data, such as your Google Play email address if you’ve signed into Google Play and your device information and language to provide and improve our support to you. The data is then transferred to a processors’ servers in the United States. As a safeguard to protect your privacy, we arranged a data processing agreement with our support partners or joint sharing personal data agreements (where our partner is also a data controller of the personal data), where we ensure that your personal information is only used in accordance with our instructions and not for their own purposes or are used in accordance with the applicable law requirements or our contractual arrangements with our partners. In addition, your request is submitted via an encrypted connection and we apply the principle of data minimization to collect only such data that is actually required to best answer your support request. The content of your request will be stored as long as you are an active player of our game, so you can get a faster response in case you have a similar problem in the future. The purpose of using the service support partners is to answer the extensive number of user requests we receive. Our support processors help us to improve our customer service so that you can get a faster and helpful response.

2.7   Data about you from third-party partners

We collect some information from other entities such as Facebook, Apple and Google, if you access our games through your accounts with those entities or you choose to connect your accounts with those companies to our games.

If you play our games through any third-party platforms, such as Google Play, Lumi may receive certain data about you from the provider of the third-party platforms. The information we receive depends on our game you are playing, the third-party application and your privacy settings.

For instance, we may collect and store some or all of the following information from the provider of the connected third-party application:       

  • Profile picture
  • Your social network ID (e.g. Facebook ID), which is usually an ID that cannot be linked to your public profile.
  • Email address you provided to that third-party application
  • Demographic data in aggregate that cannot be personally identified to you (such as to determine a coarse location of your IP address)
  • Data for advertising and analytics purposes, so we can provide you with a better Service


If you access our Games from a third-party platform, you should also read that third-party application’s terms of use and their privacy policy.


2.8   Cookies

Like other online providers, we and our partners may use cookies or similar technologies for analytics purposes to provide and personalize our Service to you. You can disable cookies in your browser, however our Service may not function properly.


3.       USE OF DATA AND LEGAL GROUNDS FOR PROCESSING

The use of data we collect and store is to provide you with the Services you request from us and to improve your in-game experience, but there are other uses as well. The uses for which we collect and store your data include:

  •       to improve and optimize our games and your experiences in our games
  •       to create your player accounts and allow you to play our games
  •       to identify and suggest connections with other players and personalize our Services to you
  •       to communicate with you, including in-game updates and notifications, new Services, and promotional offers that we think might be of interest to you
  •       to enable players to communicate with each other
  •       to provide support and respond to player requests
  •       to provide a safe and fair environment for our multiplayer features
  •       to prevent fraud or potentially illegal activities, and to enforce our Terms of Use
  •       to manage and deliver personalized advertising
  •       to administer promotional activities or events sponsored or managed by us or our partners
  •       to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties.


If you are located in European Countries, our legal basis for collecting and using the data described above depends on what data is and the context in which we collect it.

However, we normally collect data from you only where we need it to perform our contract with you (i.e., our Terms of Use), where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights), or if you give us your consent.

In some cases, we may also have a legal obligation or need to collect data from you or may otherwise need the personal data to protect your vital interests or those of another person (for example, another player). If we ask you to provide data to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your data (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Use), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing data is mandatory. 

Similarly, if we collect and use your data in reliance on our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and direct marketing, for example).If you have questions or need further information about the legal bases on which we collect and use your personal information, please contact us at privacy@lumiinteractive.com at any time.

4.       DATA SHARING

We share some of your data with your friends and other players that you are playing with to facilitate your in-game interactions. We may also share your data with third parties or allow third parties to collect this information from our games in the following manner:

4.1   Friends and other players

Our games support encourage you to interact with other players. In most games, your friends who also play our game will see your player name, photo and your level and rank, but not details of your player profile.

Further, in our games other players (not being your friends) will be able to see your player profile and your country when you battle with them, and send you friend requests through our games. You can turn off displaying of your country via Settings -> Show location option. 

4.2   Third-party analytics and advertising

For a complete list of our third party providers and partners please see here.

As an online business, it is important to us to know how players interact with the Game and interact with each other. We use third party Analytics Partners to collect location information, device information and advertising ID so we can measure, analyze and improve our Games and Services. It is also important to us to keep the Game fair for multiplayer sessions and we cannot deliver this without analytics.

We also share some of your data with advertisers to tailor the advertisements you see when you use our Services to your interests. We use advertising to enable us to offer some of our games for free. These advertisements may include, without limitation, a full-screen ads in between some gameplay for a short period or in-game items offered to players in exchange for watching a video advertisement for a longer period. 

We do not actively share personal data that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

To enable advertisers and ad media partners to serve you with more relevant ads (a practice known as interest-based advertising or behavioral advertising), they may collect, or we may collect and share with them, the following types of data when you use our games:

  • A unique device identifier called Advertising ID
  • Location information
  • Device information

You can review in more detail what our advertising service providers collect from our list of partners here.

If you do want to receive interest based in-application advertisements from third parties, your mobile device could offer your ability to opt-out for all apps on your device. On Android devices, you may opt-out by enabling the “Opt out of Ads Personalization” setting. On iOS devices, you may opt-out by enabling the “Limit Ad Tracking” setting. If you want to opt-out from specific advertising partner please review our information in the full partner list. If you just want to opt-out interest based advertising within our Game, please contact us at developer@lumiinteractive.com. Please note that if you opt out interest based advertising, you will still receive contextual ads which are related to the Game you’re playing not based on your interests.

4.3   Security measures

We share your data if necessary for safety, security, or compliance with law.Your data and the contents of all of your online communications in our games and between you and Lumi may be accessed and monitored as needed to provide our games and may be disclosed:

  •       to satisfy any laws or regulations that apply
  •       when we have to disclose the information in response to lawful requests by public authorities
  •       if our Games are being used in committing a crime or to share data with other companies and organizations for the purposes of fraud protection and other security precautions
  •       to protect the rights or property of Lumi or applicable third parties.
4.4   Other third parties

In addition to the sharing described above, we may share your data with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.

5. Children’s personal information

We do not knowingly collect children’s personal information without parental consent. If you’re a child under 13 please do not provide name, address, phone number or email address that can personally identify you. If you are a parent of a child playing the Games or using our Services, you may review or have your child’s personal information deleted and refuse the further collection of his/her personal information by contacting us at privacy@lumiinteractive.com

6.      YOUR RIGHTS
6.1   Accessing and deleting personal data held by Lumi

You can request a copy of or deletion of your game account data through our game. You can contact us through in-game chats or at privacy@lumiinteractive.com. We will aim to satisfy your request within 30 days, and if we cannot do so we will let you know.     

6.2   Opting In or Out of marketing communication with Lumi

You can unsubscribe from promotional emails by clicking the “unsubscribe” link in our marketing emails. You can opt out of mobile push notifications in your device’s settings page.

If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn of push notifications by visiting your mobile device’s “Settings”. Many of our games also offer the ability to turn off push notifications in the in-game “Settings”. They’re usually titled as “reminders” in our Settings menu.

Please note that if you opt in or out of receiving marketing communications from us, we may still communicate with you from time to time if we need to provide you with information about the games you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy, our Terms of Use or Lumi End User License Agreement.

7.       PRIVACY POLICIES OF LINKED THIRD-PARTY SERVICES

We are not responsible for the ways in which third parties use your data (other than our partners acting under our guidance). Our Websites and Games may contain advertisements from third-party services that may link to their own websites or services. The full list of third party services and their privacy policies are located here.

We are not responsible for the privacy practices or the content of these parties. If you have any questions about how these entities use your data, you should review their policies and contact them directly.

8.       TRANSFER OF DATA

When you use our games, your personal data may be sent outside of the European Countries, for example, to the United States, Israel and Hong Kong and possibly other countries. When we transfer, store, and use personal data collected in the European Countries outside of the European Countries, we comply with our legal obligations and ensure that your personal data is subject to suitable safeguards (such as encrypting communication) or transferred to “approved” territories.

As a global company, we may transfer your personal data to our “Affiliated Entities,” located in European Countries and outside like United States, Israel and Hong Kong which are any other corporate entities under common ownership with Lumi, or to our business partners and service providers from time to time for our legitimate business purposes. For example, Lumi provides certain services to its Affiliates.

We store personal data about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, marketing communication with players and product development. When we transfer your personal data internationally we will take reasonable steps to ensure that your data is treated securely, lawfully, and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your data is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

Additionally, if we share with entities which are not subject to the Privacy Shield framework, and we make sure that these entities ensure an adequate level of protection, the transfer is supported by the European Commission’s standard contractual clauses for the transfer of personal data to a country outside the European Countries. These standard contractual clauses are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/.

9.       DATA RETENTION

We’ll keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights.

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

10.    SECURITY OF YOUR INFORMATION

We work to protect your information but you as a player also have to take certain steps.

We implement reasonable and appropriate security measures to help protect the security of your data and to ensure that your data is treated securely and in accordance applicable laws.

It is important that you protect and maintain your Lumi account’s security and that you immediately tell us of any unauthorized use of your account. If you access our Services through Facebook and your account is hacked or otherwise compromised, this may lead to someone accessing or deleting your game accounts without your permission. So, be careful to keep your Facebook account information, including your social network account password, secure as well. We urge you to log out of your Lumi account and any social network account you have used to access our Services when you are finished using them.

If you have a customer service-related issue, please contact us through in-game chat.

11.    CHANGES TO OUR PRIVACY POLICY

We let you know about any material changes to our Privacy Policy. If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice in-game or on our website or by sending you a notice to your e-mail address we have on file for you before the change becomes effective (and we will ask for your consent where required by law). 

Partners

Analytics partners

NamePrivacy PolicyContact Information
Google Analytics for Firebasehttps://firebase.google.com/support/privacy/#guides_for_enabling_opt-in_for_end-user_personal_data_processinghttps://firebase.google.com/support/
Facebook AnalyticsGeneral Facebook data policy:
https://www.facebook.com/about/privacy
GDPR FAQ:
https://www.facebook.com/business/m/one-sheeters/gdpr-developer-faqs/
https://www.facebook.com/help/contact/1461223320847982 
AppsFlyerPrivacy policy:
https://www.appsflyer.com/services-privacy-policy
Opt-out service:
https://www.appsflyer.com/optout
privacy@appsflyer.com 

Other third party providers

NameProvider Type
MailchimpEmail newsletter service
Google FirebaseIn-app messaging, remote configuration and deep link services