LUMA 光 Privacy Policy

Effective for LUMA 光 on iOS and Android. In short: nothing about you leaves your device through the game.

In short

This policy explains in plain words what LUMA 光 (the “Game”) does and does not do with information, and which rights you have under the laws that matter most to our players: the EU General Data Protection Regulation (GDPR), the UK GDPR, the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), the California Consumer Privacy Act as amended (CCPA/CPRA), and the United States Children's Online Privacy Protection Act (COPPA).

Who is responsible

The Game is published by Nami Shams Game Studios, a brand of ICSL FZE, [REGISTERED ADDRESS], United Arab Emirates (trade licence [TRADE LICENSE NO.], issued by [LICENSING AUTHORITY / FREE ZONE]). Contact for all privacy questions: namis@me.com.

Because the Game does not collect personal data, Nami Shams Game Studios does not act as a controller or processor of your personal data in connection with playing the Game. We remain responsible for answering your questions and for the correctness of this policy.

What data the Game collects

None. Specifically, the Game does not:

• ask you to create an account, sign in, or give your name, email address, age or location;
• show advertisements or contain advertising networks or advertising identifiers;
• contain analytics, telemetry, crash-reporting or attribution software of ours or of third parties;
• track you across apps or websites, or build profiles about you;
• read your contacts, photos, microphone, camera, precise location or other personal files;
• send gameplay data, device identifiers or any other information to servers operated by us;
• contain social features, chat or user-generated content.

The Game works fully offline. It does not require an internet connection to be played, except where Apple or Google need one to process a purchase or restore it.

Save data stored on your device

To remember which gardens you have lit, which hidden bells you have found, your language and your settings, the Game stores a small amount of data locally on your device (for example in the operating system's application preferences). This data never leaves your device through the Game. It is deleted when you uninstall the Game. If you use device backup features provided by Apple (iCloud Backup) or Google (Android Backup), the operating system may include this data in your device backup under your own account and settings; that processing is performed by Apple or Google, not by us.

Purchases

The first chapter of LUMA (twelve gardens) is free. The remaining journey can be unlocked with a single, non-consumable in-app purchase. The purchase is processed exclusively by Apple (App Store) or Google (Google Play), who act as the merchant of record. We do not receive your name, payment card, billing address, email address or Apple ID / Google account details. We are told by the platform only that the purchase has been completed, in order to unlock the content on your device; the Game checks this status with the platform on your device. Please read the privacy notices of Apple and Google for how they handle purchase data.

The Game offers a “Restore Purchases” button, which asks the platform whether your account already owns the unlock.

Game Center and Google Play Games (optional)

On devices where we offer it, the endless mode (“The Path of a Thousand Lanterns”) may show an optional leaderboard through Apple Game Center (iOS) or Google Play Games Services (Android). Using it is entirely your choice. If you are not signed in to Game Center or Google Play Games, nothing is sent. If you are signed in and choose to take part, the platform provider receives your score and displays your chosen alias according to its own settings and privacy policy. We do not receive, store or process your Game Center or Google Play Games profile ourselves beyond what the platform shows in the leaderboard interface. You can disable Game Center in your device settings at any time.

Information held by Apple and Google

Apple and Google operate the stores through which you download the Game and may collect information about downloads, purchases, device types and, if you have switched it on, usage and diagnostics data, as described in their own privacy notices. Where you have opted into app analytics or crash sharing in your device settings, the platform provider may make aggregated or de-identified reports available to developers. We do not use any such information to identify you, and the Game itself contains no code that collects it.

When you write to us

If you send us an email (for example for support, or to be notified when LUMA launches), we receive your email address and the content of your message. We use it only to answer you or to send the single notification you asked for, we do not pass it on, and we delete it once the matter is closed or when you ask us to, unless we are legally required to keep it. The legal basis under the GDPR is Article 6(1)(b) (steps at your request) or Article 6(1)(f) (our legitimate interest in answering enquiries). Information about our website is in the studio privacy policy.

Children's privacy (COPPA, GDPR Article 8, UK Children's Code)

LUMA is rated for ages 4 and over (Apple), PEGI 3 and USK 0, and is designed to be safe for children. Because the Game collects no personal information from anyone, including children under 13 in the United States, under 16 (or the lower national age) in the European Union and under 18 where local law so provides, it complies with COPPA and with the GDPR rules on children. The Game contains no behavioural advertising, no links that lead out of the Game without a parental gate where required by store rules, no chat and no way to contact other players. If you are a parent or guardian and believe a child has sent us personal information by email, please contact us and we will delete it promptly.

Legal bases (GDPR / UK GDPR)

Since we do not process personal data through the Game, no legal basis is needed for in-game processing. For emails you send us, see the section above. Local save data stays on your device and is not accessed by us; its storage is necessary for the Game to function as you requested it.

Your rights under the GDPR and UK GDPR

If we hold personal data about you (for example because you emailed us), you have the right to: access it (Art. 15); have it corrected (Art. 16); have it erased (Art. 17); restrict its processing (Art. 18); receive it in a portable format (Art. 20); object to processing based on legitimate interests (Art. 21); and withdraw any consent at any time without affecting earlier processing (Art. 7(3)). To exercise a right, write to namis@me.com. We will answer within one month. You also have the right to lodge a complaint with your local supervisory authority, for example the authority in your country of habitual residence, place of work or the place of an alleged infringement.

United Arab Emirates (PDPL)

As a company established in the UAE we respect Federal Decree-Law No. 45 of 2021 (PDPL). In line with its principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy and security, the Game collects no personal data. Where we hold your email address because you wrote to us, you may request access, correction, erasure, restriction of processing, data portability, and may object to processing or withdraw consent, by emailing namis@me.com. You may also complain to the UAE Data Office. We do not transfer personal data outside the UAE other than as incidental to email services used by us and described in the studio privacy policy.

California and other US states (CCPA/CPRA)

We do not collect personal information through the Game, and therefore we do not sell it, share it for cross-context behavioural advertising, or use or disclose sensitive personal information. We have not done so in the preceding twelve months. California residents (and residents of other states with comparable laws) have the rights to know, delete, correct, and to opt out of sale or sharing, and not to be discriminated against for exercising these rights. Because we hold no such data, there is nothing to opt out of; if you believe we hold information about you, email namis@me.com. An authorised agent may make a request on your behalf. We will verify requests by replying to the email address the request came from. Our “Do Not Track” response: the Game does not track.

Other regions

The same promise applies worldwide. Residents of Brazil (LGPD), Japan (APPI), South Korea (PIPA), China (PIPL), Switzerland (revFADP), Canada (PIPEDA), Australia (Privacy Act) and other countries may use the contact above to exercise any rights their local law gives them with regard to data we may hold, such as an email you sent us.

International transfers

The Game does not transmit your data to us. Purchases and optional Game Center features are processed by Apple or Google under their own transfer safeguards. Emails you send us are processed by our email service provider, which may be located outside your country; where required, such transfers rely on adequacy decisions or standard contractual clauses.

Security and retention

Because the data stays on your device, its security is that of your device; please keep your device and your account protected. Emails are kept only as long as needed to handle your request, normally no longer than twelve months after the last message, unless the law requires longer retention.

Changes to this policy

If we change the Game in a way that affects privacy (for example by adding an optional online feature) we will update this policy before the change takes effect and mention the change in the release notes. The date of the latest revision is shown at the top of this page. We will never add advertising or tracking to a children's game.

Contact and complaints

Questions, requests or complaints: namis@me.com, Nami Shams Game Studios, a brand of ICSL FZE, [REGISTERED ADDRESS], United Arab Emirates.