Privacy Policy

Effective Date: 15/01/2025  |  Last Updated: 20/06/2025

This Privacy Policy describes how Bogdan Kagitin ("developer," "we," "us"), an individual developer based in Estonia, collects, uses, and shares information when you use the mobile game Lumen Grove (the "Game").

1. Data Controller

Bogdan Kagitin
Estonia
Email: info@points.gs

2. What Data We Collect

2.1 Automatically Collected

2.2 Data from Third-Party SDKs

We integrate the following services, which collect data on our behalf and for their own purposes:

Service Provider Purpose
Unity Analytics Unity Technologies, Inc. Gameplay behaviour, performance analysis
Google AdMob Google LLC Displaying in-game advertisements
Unity Cloud Save Unity Technologies, Inc. Storing game progress and settings
Tenjin SDK Tenjin, Inc. (US) Marketing attribution and user acquisition analytics

Unity Technologies operates as an independent data controller for data collected through Unity SDKs and processes it under their own Privacy Policy: unity.com/legal/privacy-policy.

Google LLC operates as an independent data controller for data collected through Google AdMob and processes it under Google's Privacy Policy: policies.google.com/privacy.

Tenjin, Inc. operates as an independent data controller for attribution data and processes it under their Privacy Policy: tenjin.com/privacy.

2.3 Anonymous Authentication

The Game assigns a persistent anonymous session ID at first launch. This ID is not linked to your name, email, or payment information. It is used solely to save and restore your progress via Unity Cloud Save.

3. Legal Basis for Processing (GDPR)

Purpose Legal Basis
Crash reporting, game stability Legitimate interests (Art. 6(1)(f))
Delivering purchased IAP content Contract performance (Art. 6(1)(b))
Advertising and behavioural analytics Consent (Art. 6(1)(a))

4. How We Use Your Data

5. Children's Privacy

The Game requires users to be 13 years of age or older. At first launch, users must confirm they meet this requirement. We do not knowingly collect data from children under 13 and comply with applicable law, including GDPR and COPPA.

6. Third-Party Services and Independent Data Collection

Our third-party SDK providers collect data under their own privacy policies and terms, independently of our instructions. We are not responsible for their data practices.

Unity Technologies may collect device identifiers and usage data for their own analytics, fraud prevention, and product improvement. We encourage you to review their Privacy Policy at unity.com/legal/privacy-policy.

7. International Data Transfers

Unity Technologies, Google LLC, and Tenjin, Inc. are based in the United States. Data processed through their SDKs may be transferred to the US or other countries outside the EEA. Such transfers are subject to appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission. See each provider's Privacy Policy for details.

8. Data Retention

Data type Retention period
Analytics and gameplay data Up to 24 months from collection
Anonymous user identifiers Until the Game is uninstalled or deletion is requested
Crash reports Up to 12 months

9. Your Rights (GDPR)

If you are in the European Economic Area, you have the right to:

Submit requests to info@points.gs. We respond within 30 days.
You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate: aki.ee

10. Analytics and Advertising Opt-Out

You may opt out of analytics and personalised advertising at any time:

11. Consent Records

Where we rely on your consent to process data, your acceptance is recorded via Unity Cloud Save solely to confirm agreement and ensure compliance. You may withdraw consent at any time — withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

12. Push Notifications

We may send push notifications about game updates. You can disable them at any time in your device settings.

13. Changes to This Policy

We may update this Policy at any time. The "Last Updated" date at the top will reflect changes. Continued use of the Game after changes constitutes acceptance.

14. Contact

Bogdan Kagitin
info@points.gs