Privacy Policy

1. Controller

[Company name to be announced], [Registered address to be announced], registration [Registration number to be announced] is the controller of your personal data. Data protection contact: privacy@luminaplay.com.

2. Data we process

• Account data: nickname, e-mail, hashed password, date of birth (age check), locale, avatar, marketing preference, consent records.
• Play data: rounds, play amounts and outcomes in Lumens, balances and ledger, missions, levels, VIP points, tournaments, clubs, messages, inbox.
• Purchase data: order IDs, package, amount, currency, payment status and provider transaction references. Card data is processed by the payment provider only.
• Technical data: IP address, country/region (from our CDN), device and browser, session identifiers, security logs, error reports.
• Responsible-play data: limits, cool-offs, self-exclusions and their history.
• Analytics and marketing data only with your consent (see Cookie Policy).

3. Purposes and legal bases (GDPR Art. 6)

• Providing the Service, your account and purchases: performance of a contract (Art. 6(1)(b)).
• Age verification, geo-restrictions, responsible-play enforcement, fraud and abuse prevention, security: legal obligation and legitimate interests (Art. 6(1)(c), (f)).
• Accounting, tax and payment records: legal obligation (Art. 6(1)(c)).
• Product analytics and marketing: your consent (Art. 6(1)(a)), withdrawable at any time under Profile → Privacy & data.
• Transactional e-mail (verification, password reset, receipts, responsible-play notices): contract and legitimate interests.

4. Recipients

Hosting provider (EU data centre), content delivery and security provider (Cloudflare), payment provider (hosted payment page), e-mail delivery provider, error monitoring. All processors are bound by data processing agreements. We do not sell personal data.

5. International transfers

Data is stored in the European Union. Where a processor operates outside the EEA we rely on adequacy decisions or the EU Standard Contractual Clauses.

6. Retention

• Account and play data: for the life of the account and up to 12 months after closure, unless a longer period is required.
• Purchase and ledger records: 10 years (tax and accounting law).
• Self-exclusion records: for the exclusion period plus 5 years, to honour the exclusion.
• Security logs: 12 months. Consent records: 5 years.

7. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection, and the right to withdraw consent at any time. Use Profile → Privacy & data to export or delete your account, or e-mail privacy@luminaplay.com. You may lodge a complaint with your local supervisory authority.

8. Children

Lumina is for adults only. We do not knowingly process data of anyone under 18 and delete such accounts when discovered.

9. Automated decisions

We do not make decisions with legal effect based solely on automated processing. Fraud and abuse signals are reviewed by staff before an account is closed.

10. Changes

We will notify you of material changes in the app or by e-mail. The date at the top shows the current version.