Privacy Policy

1. Who we are

Lumen Peak Games is an independent game studio. The data controller responsible for your personal data under the EU General Data Protection Regulation (GDPR) is:

In this policy, “we”, “us” and “our” mean Lumen Peak Games. We have not appointed a data protection officer, as the law does not require one for a studio of our size and activity. You can contact us about any privacy question at the email address above.

2. Games covered by this policy

This policy applies to every game published by Lumen Peak Games on Google Play or any other platform, and to this website. The entries below show the services each game uses. We add every new game here before it is released.

3. Data we collect

Saved on your device

Our games save your progress, scores, settings and unlocked items on your device. We don’t receive this data. It is deleted when you uninstall the game or clear its data, unless the game offers cloud saving (for example, through Google Play Games), in which case section 2 says so.

Collected automatically by services in our games

The services listed in section 5 collect some data automatically while you play. Depending on the game, this can include:

• device identifiers, such as the advertising ID on Android, the app set ID and IDs that a service creates when the game is installed; on iOS, Apple’s advertising identifier (IDFA) only if you allow tracking;
• device and app information, such as device model, operating system version, language, app version and network type;
• your IP address, which services use, for example, to estimate your approximate location (country or city) and to detect fraud;
• how you interact with the game and with ads, for example when the game is opened and which ads are shown or tapped;
• crash reports and performance data.

Online features

Some games have online features, such as achievements, leaderboards, cloud saves or content that other players can see. If you use them:

• if you use Google Play Games, the game receives your Play Games player ID, display name and profile picture;
• your scores and results, and any content you create or leave in a shared game world, are stored online and may be visible to other players.

Purchases

If a game offers in-app purchases, payment is handled by Google Play or another app store. We never see your card number or billing details. We receive only what we need to deliver your purchase: an order number, the item bought, and the date and status of the purchase.

When you contact us

If you email us, we receive your email address, your message and anything you choose to include, such as screenshots or your device model.

What we don’t collect

Our games don’t ask for access to your contacts, photos, camera, microphone or precise (GPS) location, and we don’t collect special categories of data, such as health information. If a game ever needs a device permission, it will explain why before asking, and we will update this policy first.

4. Why we use data

The GDPR requires a legal basis for every use of personal data. These are our purposes and the legal basis for each.

Running the game and the features you choose to use

Saving progress, online features and delivering purchases. Legal basis: performance of a contract with you (Article 6(1)(b) GDPR).

Showing personalized ads

Legal basis: your consent (Article 6(1)(a)). You can withdraw it at any time, as described in section 7.

Showing non-personalized ads, measuring ad performance and preventing ad fraud

Legal basis: our legitimate interest in funding free games and keeping advertising honest (Article 6(1)(f)). Where the law requires consent to store or read information on your device, we ask for it first.

Analytics and crash reports, in games that use them

Understanding how our games are played and fixing errors. Legal basis: our legitimate interest in improving our games (Article 6(1)(f)), or your consent where the law requires it.

Answering your messages and privacy requests

Legal basis: our legitimate interest in helping players (Article 6(1)(f)) and, for privacy requests, our legal obligation (Article 6(1)(c)).

Meeting legal obligations

For example, keeping purchase records for tax purposes. Legal basis: legal obligation (Article 6(1)(c)).

Establishing, exercising or defending legal claims

Legal basis: our legitimate interest (Article 6(1)(f)).

We don’t make decisions about you based solely on automated processing that have legal or similarly significant effects. Advertising partners may build a profile of your interests to personalize ads; where the law requires it, this happens only with your consent.

5. Third-party services

Our games use the following services. Section 2 shows which game uses which. Each provider handles data according to its own privacy policy.

6. When data is shared

We don’t sell your personal data. Data is shared only in these cases:

• Service providers that process data on our behalf, under contracts that require them to protect it and use it only on our instructions.
• Independent partners such as Google (advertising, Google Play, Google Play Games) and Unity, which also use data for their own purposes as described in their privacy policies. When ads are personalized, advertising partners use device identifiers in ways that some laws, such as certain U.S. state laws, treat as “sharing” or “targeted advertising”. You can opt out at any time, as described in section 7.
• Other players, who can see your display name, scores and shared content when you use online features.
• Authorities, when the law requires it, or to protect the rights, safety and property of players, us or others.
• A new owner, if a game or the studio is transferred. The new owner must keep protecting your data as described here or tell you about any changes.

7. Your choices about ads

• Consent dialog. If you are in the European Economic Area, the United Kingdom or Switzerland, the game asks for your consent before personalized ads are shown. You can change your choice at any time with the privacy option in the game’s settings.
• Advertising ID on Android. In your device’s Settings, usually under Google › Ads or Privacy › Ads, you can reset or delete your advertising ID. Once it is deleted, apps can no longer use it to personalize ads.
• Tracking on iOS. Under Settings › Privacy & Security › Tracking, you can allow or deny tracking for each app.

Opting out of personalized ads doesn’t remove ads from free games. The ads you see will simply be less related to your interests.

8. Transfers outside the EEA

Some providers, such as Google, Unity and GitHub, process data in the United States and other countries outside the European Economic Area. These transfers rely on the EU–U.S. Data Privacy Framework where the provider is certified under it, on standard contractual clauses approved by the European Commission, or on other safeguards allowed by the GDPR. You can ask us for details.

9. How long we keep data

• Data on your device: until you delete the game or its data.
• Analytics data linked to an app or device identifier, in games that use analytics: no longer than 14 months. After that, only aggregated statistics remain.
• Crash reports: deleted automatically after the provider’s standard retention period.
• Scores and shared content from online features: as long as the feature exists, or until you ask us to delete them. Your Google Play Games profile is controlled by Google and your Play Games settings.
• Purchase records: as long as tax and accounting law requires, usually five years from the end of the year in which the related tax was due.
• Emails: up to two years after your matter is resolved, unless we need them longer to establish or defend legal claims.
• Data held by independent partners, such as advertising data: according to their own policies, linked in section 5.

10. Your rights

Under the GDPR, you have the right to:

• access your personal data and receive a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict how we use your data;
• receive data you gave us in a portable format;
• object to processing based on our legitimate interests, and at any time to processing for direct marketing, including personalized advertising;
• withdraw your consent at any time, without affecting processing that took place before the withdrawal;
• lodge a complaint with a data protection authority, in particular in the country where you live or work. In Poland, this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl.

Players outside the EU may have similar rights under local law, and we handle their requests in the same way.

To use your rights, email lumenpeakgames@gmail.com. We reply within one month; if a request is complex, we may extend this by up to two more months and will tell you why. Using your rights is free. Because you don’t have an account with us, we usually can’t link data to you by name, so please tell us which game you play and, if you use online features, your display name. We may ask for more information only to confirm that a request comes from you.

11. Deleting your data

• Data on your device: uninstall the game, or go to Settings › Apps › [game name] › Storage › Clear storage. This also deletes your local progress.
• Advertising data: reset or delete your advertising ID, as described in section 7.
• Google Play Games data: in the settings of the Google Play Games app, you can delete the data of a single game or your whole Play Games profile.
• Anything else, such as scores and content from online features, analytics data linked to your device, or your emails: write to lumenpeakgames@gmail.com with the subject “Data deletion request” and the name of the game. We delete the data we can link to you within 30 days and confirm by email. We keep only what the law requires us to keep, such as purchase records (section 9).

12. Children

The intended age group of each game is shown on its store listing. We don’t knowingly collect personal data directly from children. If you are younger than the age at which you can consent to data processing in your country (16 in Poland and several other EU countries), please ask a parent or guardian to help with the privacy choices in the game.

If a game is directed at children, or at a mixed audience that includes children, it follows the applicable rules, including Google Play’s Families Policy and laws such as the U.S. Children’s Online Privacy Protection Act (COPPA). Among other things, this means ads shown to children are not personalized and are provided only by ad services certified for use in apps for children.

If you believe a child has given us personal data, contact us and we will delete it.

13. Security

We collect as little data as we can and work with established providers. Data sent between our games and these services is encrypted in transit (HTTPS/TLS). Only we have access to our developer accounts and service dashboards, and we protect them with strong authentication. No system is completely secure; if a breach puts your data at risk, we will notify the data protection authority and, where required, you.

14. This website

This website is a static site hosted on GitHub Pages. It doesn’t use cookies, analytics or advertising trackers. GitHub, Inc. logs visitors’ IP addresses for security purposes; see GitHub’s information about GitHub Pages. Links to app stores take you to sites with their own privacy policies.

15. Changes to this policy

We update this policy when our games or the services they use change, for example before a new game is released. The date at the top shows the latest version. If we make a significant change, such as collecting a new type of data, we will tell you in the game or on this website before it takes effect, and ask for your consent where the law requires it.

16. Contact

Questions about this policy or your data: lumenpeakgames@gmail.com. Please include the name of the game you are writing about.