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Privacy Policy

This Privacy Policy explains how Luma Play collects, uses, shares, and protects information when you visit luma-play.com or use our games, including Marble Sudoku and Clay Gallery: Slide Puzzle (together, the “Services”).

1. Controller and Contact

Luma Play UG (haftungsbeschränkt)
Wiesbadener Str. 3, 45145 Essen, Germany
Commercial register: Essen HRB 37485
Email: team@luma-play.com
Website: https://luma-play.com/

2. Information We Process

a) Website and Support Requests

When you contact us, we process the name you provide, your email address, message content, and related correspondence so that we can respond, protect our rights, and comply with legal obligations. Our website host may also process standard server logs such as IP address, request time, browser or device information, and requested pages for security and reliable operation.

b) App Functionality and Firebase Remote Config

Clay Gallery uses Firebase Remote Config to provide and update gameplay and monetisation settings without requiring a new app release. Firebase may process a Firebase installation ID, country and language code, time zone, operating-system and platform version, app and package identifiers, app version, and SDK version. This information is used for app functionality, service maintenance, and aggregated usage trends.

c) Analytics

For eligible players, Clay Gallery uses Google Analytics for Firebase to understand game usage and improve the game. Analytics may process:

  • app-instance, advertising, and other installation or device identifiers;
  • approximate location derived from a masked IP address;
  • app lifecycle, screen, session, and gameplay events such as level starts and completions, puzzle size, moves, duration, rewards, progression stage, ad impressions, and checkout events;
  • in-app purchase events and product information such as product ID, product name, and price; and
  • device, operating-system, app, and SDK information.

Clay Gallery does not send your name, email address, or a Luma Play account identifier to Firebase Analytics. The game does not offer user accounts.

d) Crash Reporting

For eligible players, Clay Gallery uses Firebase Crashlytics to diagnose crashes and non-fatal errors. Crashlytics may process stack traces, crash logs, relevant app and device state, device model and operating-system information, app version, active scene, a Crashlytics installation identifier, and developer-defined diagnostic keys. We use this information to maintain reliability and fix defects.

e) Advertising and Mediation

Clay Gallery uses Unity LevelPlay for ad mediation. Depending on availability, consent choices, and configuration, ads may be provided by Google AdMob, Unity Ads, and Mintegral. These providers may collect and share approximate location derived from IP address, advertising and other device or installation identifiers, ad views and interactions, app activity, device and app information, diagnostics, and purchase-history signals. They use this information for advertising or marketing, analytics, app functionality, fraud prevention, security, and legal compliance. Personalised advertising is used only when permitted by applicable law and your choices.

f) In-App Purchases and App Stores

Purchases are processed by Google Play or the Apple App Store. We do not receive or store your payment-card or bank-account details. We may receive product, transaction-status, and entitlement information needed to provide the purchased content and restore purchases. As described above, analytics and advertising providers may also process purchase-event or purchase-history signals.

g) Local Game Data

Game progress, settings, age-range choice, privacy acknowledgement, and similar save data are stored locally on your device. Luma Play does not operate a Clay Gallery account, cloud save, or leaderboard. Local data is removed when you clear the app’s storage or uninstall the app, subject to your device and platform backup settings.

3. Consent and Age Protections

Clay Gallery asks players to select an age range. If an under-16 range is selected, the game does not initialise Google UMP, Unity LevelPlay, or mediated advertising SDKs, and Firebase Analytics and Crashlytics collection remains disabled. Firebase Remote Config may still process the limited app, device, and installation information described above to provide app functionality.

For eligible players in the EEA, UK, and Switzerland, advertising choices are managed through Google User Messaging Platform (UMP). When Google requires a privacy-options entry point, you can change your choices from the game’s Privacy & ads settings. Withdrawing consent does not affect processing that occurred before withdrawal.

4. Legal Bases

Where applicable, we process information to perform our contract with you and provide requested app features, to comply with legal obligations, with your consent where required, and for legitimate interests such as securing, maintaining, analysing, and improving the Services. Where we rely on legitimate interests, we balance those interests against your rights and expectations.

5. Sharing and International Transfers

We share information only as needed with the service providers and advertising partners described above, app-store operators, hosting and technical providers, professional advisers, authorities when legally required, or a successor in a lawful business transaction. These providers may process information outside your country. Where required, transfers are protected by recognised safeguards such as adequacy decisions or standard contractual clauses.

6. Retention and Security

We keep personal information only for as long as needed for the purposes described, our configured provider retention periods, dispute resolution, fraud prevention, and legal obligations. Support correspondence is normally retained until the request is resolved and for any necessary follow-up or legal period. Provider retention periods are described in their policies. Aggregated or de-identified information may be retained when it can no longer reasonably be linked to you.

We and our providers use reasonable technical and organisational safeguards. Data disclosed by the Firebase and advertising SDKs is encrypted in transit. No online system can be guaranteed completely secure.

7. Your Rights and Data Deletion

Depending on your location, you may have rights to access, correct, delete, restrict, or object to processing, receive a portable copy of certain data, withdraw consent, and complain to a supervisory authority. You can request deletion through our Data Deletion page or by emailing team@luma-play.com. We may need limited information to verify and locate the relevant records.

8. Children

Our age controls are designed to prevent advertising and optional telemetry SDKs from processing data for players who select an under-16 range. If you believe a child’s information has been processed contrary to this policy, contact us so that we can investigate and take appropriate action.

9. Complaints

You may complain to your local data-protection authority. Our competent supervisory authority in Germany is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW).

10. Changes to This Policy

We may update this Privacy Policy when our Services, providers, or legal obligations change. The “Last updated” date shows when this page was most recently revised.

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