Privacy Policy

This Privacy Policy (the "Policy") describes how LUMITALE PTE. LTD. and its affiliates ("we" or "us") collect, use, disclose, and otherwise process personal information when operating LumiTale and its related products, websites, networks, applications, and other services (collectively referred to as our "Services"). "Personal information" refers to any information related to an identified or identifiable individual.

This Policy is incorporated into and governed by the LumiTale Terms of Service. It explains the information we collect from you through our Services, how we use and disclose such information, and the steps we take to protect it. We have established this Privacy Policy and specifically highlight: we hope you read and understand this Policy (especially the bolded content) carefully before using LumiTale and related services, to make informed decisions.

This Policy applies to all services we provide, including the LumiTale official website (www.lumitale.games), the LumiTale App, and the LumiMaker creation tools.

Our Commitments:

We will collect and use your information following this Privacy Policy, without coercively bundling personal information collection solely based on your agreement to this Policy.

By clicking "Allow" on the pop-up screen, you acknowledge and agree to the collection and use of your information as specified in this Policy. You can refuse to provide your information, but this may affect certain functionalities of the LumiTale platform or result in the inability to use some products and services.

We respect your choice. If you do not wish to have your personal information collected, you can revoke your authorization at any time on the LumiTale platform. If you encounter difficulties in canceling the authorization, you may contact our customer service for assistance.

Policy Update Date: June 29, 2024

Policy Effective Date: June 29, 2024

1. Introduction

In accordance with relevant laws and regulations, providers of network products and services with information collection functions must clearly inform users and obtain consent. This Privacy Policy informs you of the purposes, methods, and scope of collecting and using personal information, and the ways we provide for you to access, update, and protect such information. By using or continuing to use our Services, you agree to our collection, use, storage, and sharing of your information as described in this Policy.

2. How We Collect Your Information

2.1 Account Registration and Login

2.1.1 When you register and log into your LumiTale account, we collect your email address (personal sensitive information used for receiving verification codes to match personal identity). For specific services, we may require additional personal information, such as your name, email address, mailing address, phone number, credit card or other billing information, birth date, geographic area, or preferences. This information may be linked with other information about you. Providing accurate and true information is necessary to successfully register and use the core functions of LumiTale. Refusal to provide such information may result in the inability to access core product features.

2.1.2 To better provide personalized services, you can voluntarily add information such as your birthday, nickname, and avatar during registration or use.

2.1.3 If you log in using a third-party account (e.g., Google ID, Apple ID), we will obtain the authorized information, such as username, gender, nickname, avatar, and identity verification (personal sensitive information). Refusal to authorize this information will prevent the use of third-party account login but will not affect the use of other products and services.

Note: Your email address and verification code results are considered personal sensitive information. We collect this information based on legal requirements. Refusal to provide such information may prevent account registration and related functionality.

2.2 Search Function

When using the search function, we collect your device information (including hardware serial number, model, MAC address, OS type, software list, unique device identifiers such as IMEI, Android ID, IDFA, OpenUDID, GUID, ICCID, SIM card IMSI information), and log information (including search terms, browsing history and times, search times, and frequency). This information helps us quickly match relevant content and improve our products and services.

2.3 Game Media Display and Playback

When using game media display and playback services, we collect your device model, name, unique device identifiers, browser type and settings, language settings, OS and application versions, login IP address, network connection method, network quality data, mobile network information, product version number, and network log information (such as operation logs, service logs). This information helps us provide video display and playback services. Device and log information alone cannot identify specific individuals. If combined with other information for identification, or used with personal information, it will be treated as personal information and anonymized unless otherwise specified by law.

2.4 Customer Service

When you file a complaint, appeal, or inquiry with LumiTale, we require personal information such as name, email, and other contact details (personal sensitive information). We also collect communication details (text/images/audio/video/call records) and other necessary information related to your request.

2.5 Payment Settlement

2.5.1 To facilitate order payments, assess account and transaction risks, verify identity, and detect and prevent security incidents, we may collect your personal virtual property information (limited to transaction records, virtual currency like flowers).

2.5.2 During payment on LumiTale, you may use payment functions. LumiTale supports Apple Pay and Google Pay. We may collect your third-party payment account information (Apple ID, Google ID) (personal sensitive information). This information is necessary to provide the purchased goods and services. We cannot identify specific individuals or access your personal assets solely based on this information.

2.6 Targeted Recommendations

To provide customized services, such as relevant search results, game media, information streams, or ads/promotional information, we collect device information (e.g., hardware model, MAC address, IMEI, IDFA, IMSI, necessary software list), browser model, log information, browsing history, interaction objects, search terms, and personal location (precise location is personal sensitive information). When the LumiTale App is minimized, we still collect personal information to continue content recommendations when maximized.

Personalized Information and Services: We offer options to reject personalized content. If you do not wish to receive personalized content, you can enable/disable push notifications via product settings (Path: "My - Settings - Push Notifications - Enable/Disable").

2.7 Security Assurance

We use some personal common device information (including hardware serial number, model, MAC address, OS type, software list, unique device identifiers) for identity verification, security prevention, fraud monitoring, backup, and archiving. For example, unique device codes (IMEI, Android ID, IDFA, OpenUDID, GUID, ICCID, SIM card IMSI) are used for security and user identification, and internet records for security and fraud monitoring.

2.8 Product Development and Service Optimization

During product development and troubleshooting, we may record and analyze information generated during system failures (motherboard information, CPU instruction set, screen parameters, supported ABIS, hardware ID, phone manufacturer, revision list, compile type, hardware serial number, build date, settings, version, system customizer, device DPI, memory size, SD storage size).

User information may be used to improve website design and promotion, and to statistically analyze product/service usage. Shared statistics with the public or third parties will be anonymized to protect information security.

2.9 Account Cancellation

To cancel your account, go to: "My - Settings - Cancel Account."

We require necessary personal sensitive information (email verification code, User ID) for identity verification. If you have questions about handling your personal information, contact us using the details in Section 9 of this Policy.

2.10 Permissions for Android Users

For Android users, relevant product permissions may be required to provide, process, maintain, improve, develop our products or services:

a) Data caching in SD card during online play or downloads, caching images and data for browsing, saving traffic, storing user information for push services.

b) Camera and flash permissions for uploading personal avatars.

c) Network access permissions for software networking functions.

d) Network status and device network information for compatibility and network state judgment (IP address, WiFi information, base station information, DNS address, DHCP address, SSID, BSSID).

e) WiFi state permissions to prompt users to enable WiFi to save data during downloads.

f) APK installation permissions for in-app updates.

g) Permissions to prevent screen locking during content viewing.

h) Broadcast permissions for internal and custom broadcast messages.

i) Background service permissions for normal download operations when the app is in the background.

j) Wake screen permissions for push notifications.

2.11 Permissions for iOS Users

For iOS users, relevant product permissions may be required to provide, process, maintain, improve, develop our products or services:

a) Camera permissions for uploading avatars and posting.

b) Album permissions for saving images.

c) Network permissions for normal app operation.

Special Reminder: Due to the variety of products and services, core business functions and collected personal information types may vary by product/service content. Specifics are based on actual products/services. We continuously improve products/services and technology, which may require new personal information collection or changes in usage purposes/methods. Unlisted features or products/services will be updated through this Policy, page prompts, pop-ups, website announcements, and user consent will be obtained before collection. Contact us for any questions using the details in Section 9 of this Policy.

3. How We Use Your Personal Information

3.1 Sharing

We keep your personal information confidential and will not share it with third parties, except:

a) With your explicit consent.

b) As required by laws and regulations or mandatory government requirements.

c) With affiliates: Personal information may be shared with affiliates for necessary purposes under this Policy. Affiliates will seek your consent for any changes in processing purposes.

d) With authorized partners: Certain services may be provided by authorized partners, who need specific personal information to offer better services and user experience. For example, sharing personal information with logistics providers for delivery. Authorized partners can only use shared personal information for agreed purposes.

e) Third-party SDK services: Our products may include third-party SDKs or similar applications. By using such services, you agree to the direct collection and processing of information by third parties.

We sign strict confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to process the information per our instructions, this Policy, and other relevant confidentiality and security measures.

3.2 Transfer

We will not transfer your personal information to any company, organization, or individual except:

a) With explicit consent: We will transfer personal information to others with your explicit consent.

b) In cases of mergers, acquisitions, or bankruptcy liquidation, involving the transfer of personal information, we will ensure the new entity continues to adhere to this Policy, or we will request their explicit consent.

3.3 Public Disclosure

We will only disclose your personal information in the following circumstances:

a) With your explicit consent.

b) As required by law, legal processes, litigation, or mandatory requests from government authorities.

3.4 Exceptions

In certain cases, personal information controllers can share, transfer, or disclose personal information without prior consent, as required by laws, regulations, ethical standards, or public safety.

4. How We Protect Your Personal Information

4.1 Reasonable Measures

We take reasonable steps to protect your personal information, with a dedicated technical team and specific procedures for data collection and processing to ensure compliance with our expectations and legal requirements. Regular risk assessments ensure our products are not threatened by data breaches or privacy violations.

4.2 Additional Security Measures

We manage information storage and use through data classification, security management norms, and security development standards. Comprehensive security controls are enforced through confidentiality agreements, monitoring, and auditing mechanisms.

4.3 Employee Access

Only LumiTale employees who need to know such information are allowed access, and all personnel must adhere to confidentiality obligations. Violations may lead to legal responsibility or termination of cooperation with LumiTale.

4.4 Information Retention

We take all reasonable steps to ensure unnecessary personal information is not collected. Personal information is retained only for the necessary and reasonable period unless an extension is required or legally permitted. After expiration, information will be anonymized to ensure security.

4.5 Information Security

The internet is not an entirely secure environment, and email, instant messaging, and communication with other LumiTale users are not encrypted. We strongly recommend not sending personal information through these methods. Use complex passwords to help ensure your account security.

If any physical, technical, or administrative protection measures are compromised, resulting in unauthorized access, disclosure, alteration, or destruction of information, and your rights are affected, we will bear the corresponding legal responsibility. We will promptly inform you of the security incident, potential impacts, measures taken, and suggestions for self-protection. Notifications will be sent via email, letter, phone, or push notification, or public announcements if individual notifications are impractical. We will also report handling details to regulatory authorities as required.

5. How We Use Cookies and Similar Technologies

5.1 We may use cookies and similar technologies to collect personal information, such as your website visit habits, browsing information, and login information, for necessary purposes, simplifying repetitive operations (e.g., registration, login), reviewing usage history, providing tailored services and content, protecting information and account security, and enhancing products and services.

5.2 You can manage, partially/fully reject, or delete cookies and similar technologies through browser settings, preventing us from tracking your personal information. Specific instructions for changing browser settings can be found on the respective browser's settings page. Note: some products/services require cookies or similar technologies. Refusal or deletion may affect the normal use of related products/services or optimal service experience and may impact information protection and account security.

6. Your Rights

6.1 Access, Modify, and Obtain Personal Information Copies

You can access and modify personal information and obtain copies through "Settings."

6.2 Delete Personal Information

You can request deletion of personal information in the following cases:

a) If processing violates laws and regulations.

b) If personal information is collected without consent.

c) If processing violates agreements with you.

d) If you no longer use products or services.

e) If we permanently cease providing products or services.

f) If you cancel your personal account.

When conditions of the LumiTale Terms of Service are met, your account may be canceled or deleted, and all related data will be deleted or anonymized.

6.3 Change Authorization Scope

Some information is necessary for using our services, but most other information is optional. You can change the authorization scope by deleting information, disabling device functions, etc. Withdrawal of authorization will not affect prior information processing based on your consent.

6.4 Responding to Requests

For security, we may require identity verification before processing your requests. We will respond within 15 business days. If unsatisfied, you can file a complaint through LumiTale customer service.

Reasonable requests are generally free, but repeated or excessive requests may incur costs. We may refuse baseless, excessive technical measures (e.g., developing new systems or fundamentally changing practices), risk others' legal rights, or are impractical (e.g., backup tape information) requests.

6.5 Exceptions

We cannot respond to requests in the following cases:

a) Violating any laws or regulations.

b) Directly related to public safety, public health, or major public interests.

c) Directly related to criminal investigations, prosecutions, trials, and judgments.

d) Sufficient evidence of subjective malice or abuse of rights.

e) Responses would harm your or others' legal rights.

f) Involving trade secrets.

7. Protection of Minors

Users under 18 should obtain guardian consent before using our products/services. If you are under 18, read this Policy with a guardian, and use products/services and submit personal information with their clear consent and guidance.

8. Policy Updates

We will update this Privacy Policy based on product updates and legal requirements. Updates form part of this Policy. Without your explicit consent, we will not reduce your rights under this Policy. Significant changes will be notified through prominent position prompts, push messages, or other means. Continued use of our services implies full understanding and agreement to the revised Policy.

Significant Changes Include: 

a) Significant changes in service modes, such as purposes, types, or methods of processing personal information.

b) Major changes in ownership structure or organization, like business adjustments, bankruptcies, or mergers.

c) Major changes in personal information sharing, transfer, or public disclosure.

d) Changes in your rights to participate in personal information processing.

e) Changes in departments responsible for personal information security, contact methods, and complaint channels.

f) High-risk evaluations in personal information security assessment reports.