LumieGames Privacy Policy

Preface

This Privacy Policy describes how Beijing Wisdom Teng Tong Technology Co., Ltd. ("we", "us", or "our") collects, uses, stores, and protects your personal data when you use LumieGames and related services (collectively, the "Services").

LumieGames provides users with access to H5 games and Flash games. You may access and play games through LumieGames without creating an account or providing registration information.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains:

1. How we collect and use your personal data;
2. How we use cookies and similar technologies;
3. How we share, transfer, and disclose your personal data;
4. How we protect and retain your personal data;
5. Your rights and controls;
6. How we handle children's personal data;
7. International transfer and storage of personal data;
8. Changes to this Privacy Policy;
9. How to contact us.

1. How We Collect and Use Your Personal Data

1.1 Data Automatically Collected When You Use LumieGames

When you access and use LumieGames, we may automatically collect certain data about your device and your use of the Services. Such data may include your device identifiers, device model, operating system information, application version, IP address, network information, language and region settings, as well as data generated through your interaction with the Services, such as game access records, gameplay-related activity, and operational logs.

We collect and use this data to provide and maintain the Services, ensure the stability and security of the application, detect and resolve technical issues and errors, improve game performance and user experience, prevent abuse, and maintain the normal operation of the Services.

The processing of this data is necessary for us to provide and maintain the Services and is also based on our legitimate interests in ensuring the security, stability, and continuous improvement of our Services.

1.2 Customer Support and Communication

If you contact us regarding technical issues, feedback, or other inquiries, we may collect the information you provide to us, including your email address, device data, descriptions of the issues you encounter, and relevant records of communications between you and us.

We use this information to respond to your requests, provide technical support, investigate and resolve technical issues, and improve the quality of our Services.

1.3 Usage data

During your use of LumieGames, we may collect data generated through your interaction with the Services, including the games you access or play, your usage duration, interaction records, and error or crash information.

We use this data to analyze service performance, improve game quality, optimize user experience, identify and resolve technical problems, and maintain the security and reliability of the Services.

1.4 Cookies and Similar Technologies

LumieGames may use cookies or similar technologies to support the operation and functionality of the Services. Cookies are small data files stored on your device that enable applications and websites to recognize certain information and improve service functionality.

Currently, LumieGames does not use cookies or similar technologies for advertising or personalized marketing purposes.

You may manage or delete cookies through your device or browser settings. However, disabling certain cookies or similar technologies may affect the availability or functionality of certain features of the Services.

2. How We Share, Transfer, and Disclose Your Personal data

2.1 Sharing

We do not sell your personal data.

We may share your personal data only in the following circumstances:

(1) With your consent

We may share your personal data with third parties after obtaining your consent.

(2) Service providers

We may engage service providers to support our operations, such as hosting, technical support, security, or infrastructure services. These providers may process personal data only for the purposes described in this Privacy Policy and according to our instructions.

(3) Legal requirements

We may disclose personal data where required by applicable laws, regulations, legal proceedings, or governmental authorities.

2.2 Transfer

We will not transfer your personal data to another company, organization, or individual except:

• With your explicit consent;
• As part of a merger, acquisition, restructuring, or similar corporate transaction;
• Where required by applicable laws or regulations.

2.3 Public Disclosure

We do not publicly disclose your personal data unless:

• You separately authorize us to do so; or
• Disclosure is required by applicable laws or legal procedures.

3. How We Protect and Retain Your Personal data

3.1 Security Measures

We use appropriate measures to ensure a level of security appropriate to the risk involved and have implemented contractual, technical, administrative, and physical security measures designed to protect personal data from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this policy does not guarantee the security of your personal data 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

3.2 Data Retention

We only keep your personal data for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations. For example, we may retain personal data collected from you to support user inquiries and prevent repeated violations or suspected violations of this policy if your account has been banned or your access to the services has been disabled for any reason. When deleting data, we will take measures to make the data irrecoverable or irreproducible, and electronic files which contain information will be deleted permanently.

3.3 Data Storage

Due to the nature of our Services, some of your personal data may be transferred to, stored in, and processed by our affiliated companies, subcontractors, service providers, etc. located outside the country where you reside, and our support, engineering and other teams based in different areas may be granted access to your personal data. By accepting this policy, you understand and agree that your information may be processed on servers which shall be located in America. Please note that different countries may have different personal data protection laws than your own country, but we will try to ensure that adequate safeguards are in place to protect your personal data in this policy.

4. Your Rights and Controls

Depending on applicable privacy laws, you may have rights regarding your personal data, including:

4.1 Access

You can access the personal data we hold about you, including the categories of personal data collected, where we collect it from, why and how we use it, and who may receive this information. This right is not absolute. For example, we cannot reveal trade secrets, or give you information about other individuals.

4.2 Correction

You have the right to correct any of your personal data we hold that is inaccurate. You can access the personal data we hold about you by logging into your account.

4.3 Erasure

You have the right to request the deletion of personal data concerning you if the reason why we could collect it does not exist anymore or if there is another legal ground for its deletion. As a result of deleting everything in your Imaginative Surge account, you will lose access to Imaginative Surge services including your account, related subscription, related information linked to your account, and other services accessed through your account. However, we may need to retain personal data if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression), but we will let you know if that is the case.

4.4 Objection

According to applicable laws and regulations in your country/region of residence, you may have the right to (a) withdraw your consent where you previously provided such consent; or (b) object to our processing of your information where we process such information on the basis of our legitimate interests described in Section 1 "How we collect and use your personal data". Where consent is required to process your personal data, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

4.5 Portability

You have the right to receive a copy of information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such information is transferred to a third party.

4.6 Restriction

Under certain circumstances stipulated by applicable laws and regulations in your country/region of residence, you may have a right to stop us processing your personal data.

4.7 Opt-out

If you do not want us to use or share your personal data for advertising and marketing purposes or send you advertising and/or marketing communications, you by contacting information listed in the Section 9 to exercise this privacy right.

5. Children's Privacy

Our Services are not intended for children and we do not knowingly collect personal data from children. By children, we mean users under the age of 13 years old or the age stipulated in applicable laws and regulations in your country/region of residence.

If you are a Minor who is between the age of 13 and the legal age of majority as defined by the laws and regulations of your region or country of residence, you should review this Privacy Policy together with your parent or legal guardian. By using the Services, you represent that you have obtained the consent of your parent or legal guardian where required by applicable laws. Furthermore, you should not provide us or other users with any personal data, including, without limitation, your real name, address, telephone number, or email address.

We strongly urge parents to supervise children and minors not to disclose personal data without prior parental consent. Minors may use and access our service only with the involvement of a parent or legal guardian.

If you believe that we have unintentionally collected your children's personal data, you may request the deletion of the data by contacting information listed in the Section 8. In some cases, we may ask the user to provide us with their date of birth for age verification. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal data from the child until a parent/guardian's verifiable consent is obtained.

6. International Transfer and Processing of Personal data

When you use our Services, your data may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of data outside the country of collection where appropriate, for instance, the standard contractual clauses provided by the European Commission, your explicit and unambiguous consent, being necessary for the performance of the agreement between you and us, etc. If permissible under local law, you are authorizing us to process your data in any of the locations where we operate by using our Services.

7. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will notify you through appropriate means, such as posting the updated Privacy Policy within the Services or providing other legally required notifications.

8. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our processing of your personal data, please contact us: