Privacy Policy

Last updated: 5 October 2026

LumenGame Ltd ("LumenGame", "we", "us") respects your privacy and is committed to protecting personal data. This Privacy Policy explains what information we collect, why we collect it, how long we keep it, and your rights when you use the website at lumengameplay.com (the "Website"), play our social games, or submit enquiries.

This policy applies to visitors and users worldwide, including Australia. It should be read together with our Terms of Use and Responsible Play information.

1. Data controller

The data controller responsible for your personal data is:

LumenGame Ltd
175 Piccadilly, London W1J 9TB, United Kingdom
Email: [email protected]

2. Categories of personal data we collect

2.1 Information you provide directly

• Contact and enquiry data: name, email address, company name (optional), project details, message content and consent records when you use the Contact form or Game Development application form.
• Communications: any additional information you choose to include in emails to [email protected].

2.2 Information collected automatically

• Technical data: IP address, browser type and version, operating system, device type, language settings, referring URL and general location derived from IP (country/region level).
• Usage data: pages viewed, time spent, click paths, error logs and performance metrics.
• Local storage data: gameplay preferences or progress stored in your browser by our Games where applicable.

2.3 Information we do not collect

We do not process payment card details on lumengameplay.com because our social games do not involve real-money deposits. We do not knowingly collect special category data (such as health data) unless you voluntarily include it in a message to us.

3. Purposes and legal bases for processing

We process personal data for the following purposes:

• Respond to enquiries (contact and development applications) — performance of steps prior to a contract and legitimate interests in operating our business; consent where required for marketing follow-up.
• Provide and improve the Website and Games — legitimate interests in delivering stable, secure entertainment services.
• Security and fraud prevention — legitimate interests in protecting users, our infrastructure and intellectual property.
• Legal compliance — processing necessary to comply with applicable laws and respond to lawful requests.
• Analytics — legitimate interests in understanding aggregate usage to improve UX, where configured and permitted.

Where UK GDPR applies, our lawful bases include consent, contract, legitimate interests and legal obligation. Where the Australian Privacy Act 1988 applies, we collect data for purposes that are reasonably necessary for our functions and notify you as described in this policy.

4. Cookies and similar technologies

4.1. The Website may use cookies, local storage and similar technologies to remember preferences, maintain sessions and measure performance.

4.2. Essential technologies are used to operate core functionality. Analytics or preference cookies, if enabled, help us understand how visitors interact with lumengameplay.com.

4.3. You can control cookies through your browser settings. Blocking essential cookies may affect gameplay or form functionality.

5. How we share personal data

We do not sell your personal data. We may share information with:

• Service providers who assist with hosting, email delivery, form processing, security monitoring or analytics, under contractual confidentiality and data protection terms;
• Professional advisers (lawyers, accountants) where necessary;
• Authorities when required by law, court order or to protect rights and safety.

If data is transferred outside the UK, EEA or Australia, we implement appropriate safeguards such as standard contractual clauses or equivalent mechanisms where required.

6. Data retention

We retain personal data only as long as necessary for the purposes described above, including:

• Contact and development enquiries: typically up to 24 months after the last interaction, unless a longer period is required for legal claims or record-keeping;
• Server logs: for a limited period aligned with security needs, usually between 30 and 90 days unless investigation requires longer retention;
• Local gameplay data: remains on your device until you clear browser storage.

7. Security measures

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure or destruction. These include access controls, encrypted connections (HTTPS where supported by hosting) and vendor due diligence. No method of transmission over the Internet is completely secure; we cannot guarantee absolute security.

8. Your rights

8.1 UK / EEA (UK GDPR)

Depending on your location, you may have the right to access, rectify, erase, restrict or object to processing, data portability, and to withdraw consent where processing is consent-based. You may lodge a complaint with the UK Information Commissioner's Office (ICO) or your local supervisory authority.

8.2 Australia (Privacy Act)

Australian individuals may request access to or correction of personal information we hold about them, and may complain to us if they believe we have breached the Australian Privacy Principles. If unresolved, you may contact the Office of the Australian Information Commissioner (OAIC).

8.3 Exercising your rights

Submit requests to [email protected]. We may need to verify your identity before responding. We aim to reply within one month (or the timeframe required by applicable law).

9. Children

Our Services are not directed at anyone under 18. We do not knowingly collect personal data from minors. If you believe a child has provided information to us, contact us and we will take steps to delete it.

10. Marketing communications

We do not send bulk marketing email unless you have opted in or we have another lawful basis. You may unsubscribe from promotional messages at any time using the link provided or by emailing us.

11. Automated decision-making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on individuals in connection with lumengameplay.com.

12. Changes to this policy

We may update this Privacy Policy periodically. The "Last updated" date will reflect changes. We encourage you to review this page regularly. Material changes may be communicated on the Website where appropriate.

13. Contact and complaints

For privacy questions, data subject requests or complaints:

LumenGame Ltd — Privacy
175 Piccadilly, London W1J 9TB, United Kingdom
Email: [email protected]