Data Privacy Notice

1. Scope of This Notice

This Data Privacy Notice describes how Luminix Play Limited handles personal information in connection with our websites, mobile applications, games, software, player support, community tools, promotions, and related online services, collectively called the "Services" in this Notice.

Luminix Play Limited is the business responsible for this Notice. Our contact address is UNITR 6, ROOM 6A, 6/F, WAH TAI INDUSTRIAL BUILDING, 11 SAN ON STREET, TUEN MUN, NEW TERRITORIES, HONG KONG.

This Notice is designed to explain what we collect, why we use it, when we disclose it, and how users may contact us about privacy matters. It should be read together with any product-specific notices, consent screens, platform permissions, or app store disclosures that apply to a particular Service.

2. Information You Give Us

We collect information that you choose to provide directly. This may include account registration details, username or display name, email address, approximate age or age band, profile settings, support requests, survey answers, contest entries, user reports, feedback, and communications with our team.

If you contact support, we may keep the content of your message, screenshots or files you provide, device details needed to troubleshoot the issue, and records of the steps taken to respond.

3. Information Created When You Use the Services

When you use the Services, certain information is generated automatically. Depending on the product and your settings, this may include gameplay events, progress, scores, achievements, session length, feature usage, virtual item activity, crash logs, error reports, anti-cheat signals, security logs, IP address, device model, operating system, app version, browser type, language, country or region inferred from network data, and timestamps.

We may also receive purchase-related information from app stores or payment providers, such as order number, item purchased, currency, price, refund status, and payment platform account references. We normally do not receive full payment card numbers from those third-party processors.

4. Device Identifiers and Advertising Choices

Some Services rely on device-level or app-level identifiers to operate reliably. These may include installation IDs, advertising IDs, platform account IDs, device identifiers, IP addresses, and fraud-prevention signals.

We use these identifiers to protect accounts, preserve progress, identify technical problems, detect abuse or automated play, prevent payment fraud, measure performance, and support advertising or analytics where permitted.

Advertising IDs are generally controlled through your device settings. You may reset or limit interest-based advertising on supported devices. If an identifier is necessary for security, fraud prevention, account integrity, or core functionality, disabling it may limit or prevent use of some features.

5. Children and Teen Users

Our Services are not intended for children under 13, and we do not knowingly collect personal information from children under 13. If we learn that such information has been collected without the required permission, we will take reasonable steps to delete it or disable the related account.

Parents or guardians who believe a child has provided personal information may contact us using the details at the end of this Notice. We may request information needed to verify the request and locate the relevant account or record.

Teen users who have not reached the age of majority in their location should use the Services only with permission and supervision from a parent or legal guardian.

6. How We Use Personal Information

We use personal information for the following business and service purposes:

• to provide accounts, gameplay, saved progress, virtual items, customer support, updates, and other requested features;
• to verify users, secure accounts, detect unauthorized access, investigate bugs, prevent cheating, and protect the fair operation of games or interactive features;
• to process purchases, refunds, platform entitlements, service messages, and operational notices;
• to analyze usage trends, test features, improve performance, personalize non-sensitive settings, and understand how users interact with the Services;
• to run promotions, surveys, events, newsletters, and marketing communications where allowed by law and your preferences;
• to comply with legal obligations, enforce our terms, respond to lawful requests, resolve disputes, and protect the rights and safety of Luminix Play, users, and others.

7. Legal Reasons for Processing

Where privacy law requires a legal basis, we may process information because it is necessary to provide the Services or perform a contract with you, because we have a legitimate interest in operating and protecting our business, because we must comply with legal obligations, because you have given consent, or because processing is needed to protect important interests such as safety and security.

Consent-based activities may include optional marketing, certain device permissions, or use of precise location if a product ever requests it. You may withdraw consent where the law gives you that right, although some features may no longer be available afterward.

8. Cookies, SDKs, and Similar Tools

Our websites and applications may use cookies, local storage, software development kits, pixels, tags, and similar tools. These technologies can keep you signed in, remember preferences, measure traffic, diagnose errors, support analytics, deliver or measure ads, and help us secure the Services.

Browser cookies can usually be managed in browser settings. Mobile SDK permissions and advertising preferences are often controlled through the device operating system. Blocking certain technologies may affect login, security, support, or personalization features.

9. When We Disclose Information

We may disclose information to selected recipients where there is a legitimate reason and appropriate safeguards are used. Recipients may include:

• hosting, cloud, analytics, crash reporting, security, moderation, customer support, messaging, advertising measurement, and fraud-prevention providers;
• app stores, payment processors, platform operators, and login providers for account connection, purchase fulfillment, refunds, entitlement checks, and platform compliance;
• professional advisers, auditors, insurers, and business service providers that assist with legal, accounting, compliance, or corporate administration;
• courts, regulators, law enforcement, or other authorities where disclosure is legally required or reasonably necessary to protect users, the public, our rights, or service security;
• a buyer, successor, investor, or business partner involved in a merger, acquisition, financing, reorganization, transfer of assets, or similar transaction.

We do not sell personal information for money. Where laws define certain advertising or analytics disclosures as a "sale" or "sharing," users may have opt-out rights depending on their location.

10. Cross-Border Processing

We may process and store information in Hong Kong and in other countries or regions where our service providers or business partners operate. Those places may have privacy rules that differ from the rules in your location.

When information is transferred across borders, we use protective measures that may include contractual obligations, technical safeguards, vendor due diligence, access restrictions, and encryption where appropriate.

11. Security and Account Protection

We maintain administrative, technical, and organizational safeguards intended to reduce risks of unauthorized access, misuse, disclosure, alteration, or loss. These safeguards may include limited personnel access, authentication controls, encryption in transit, monitoring, logging, backups, and security review processes.

No system connected to the internet can be made completely secure. Users should keep passwords private, avoid reusing credentials, update devices and apps, and contact us promptly if they suspect unauthorized account activity.

12. How Long We Keep Information

We keep information for as long as reasonably necessary for the purposes described in this Notice, unless a longer retention period is required or allowed by law.

For example, account information is generally retained while the account is active; transaction records may be retained for tax, audit, refund, and accounting purposes; support records may be retained to handle follow-up questions or disputes; and aggregated or anonymized analytics may be kept for product improvement because they no longer identify a particular user.

13. Your Privacy Controls

Depending on your location and applicable law, you may be able to request access to personal information, correction, deletion, restriction, objection, withdrawal of consent, or a copy of certain information in a portable format.

You may also manage some preferences directly through account settings, device permissions, notification settings, advertising ID controls, cookie settings, and unsubscribe links in marketing messages.

We may ask for information to verify your identity before responding to a request. Some requests may be limited where we need to keep information for security, legal compliance, fraud prevention, accounting, dispute resolution, or protection of other users.

14. Account Closure and App Removal

If account deletion tools are available in a Service, you may use them to request closure of the account. You may also contact us by email. Account deletion may permanently remove saved progress, account records visible in the Service, and access to virtual items or other account-linked features.

Removing an app from your device stops future collection by that app on that device, but it does not by itself remove information already stored on our systems. A separate deletion request may be needed for server-side records.

15. Third-Party Sites and Platforms

The Services may link to or interact with third-party websites, app stores, social networks, ad networks, payment providers, platform services, or login providers. Their privacy notices and settings govern their handling of information. We do not control their independent privacy practices.

16. Updates to This Notice

We may revise this Notice as our Services, technology, legal requirements, or business practices change. The updated version will show a new effective or last updated date.

For material changes, we will use reasonable methods to notify users, such as posting the revised Notice, displaying an in-service notice, or using another appropriate communication channel.

17. Contact Details

Questions, privacy requests, or complaints about this Notice may be sent to Luminix Play Limited.

• Postal address: UNITR 6, ROOM 6A, 6/F, WAH TAI INDUSTRIAL BUILDING, 11 SAN ON STREET, TUEN MUN, NEW TERRITORIES, HONG KONG
• Email: [email protected]