Privacy policy

How Lumijayon handles information. Effective date: 2026-10-29.

Template prepared for Juvenstar Studios — have it reviewed by a qualified lawyer before launch.

Who we are

Lumijayon (“Echoes of the Hollow”) is published by Juvenstar Studios, a trade name of Jaysventure ([REGISTERED ADDRESS]), referred to as “Juvenstar Studios”, “we” or “us”. We are the controller of the personal data described here. Contact: [email protected].

Lumijayon needs no registration. We do not ask for your name, phone number, location or contacts, and the game has no chat or social features on the internet. The only exception is the optional adult cash-out program: if you request a PayPal payout, we ask for your PayPal email address (see Payouts).

What we collect

Data	Why	Where
Random device ID (a UUID generated by the game, not your hardware ID)	To keep your coin balance and let you delete your data	On your device and our server
Device secret (random key, stored encrypted on our server)	To sign requests so no one else can change your balance	Your device and our server
Nickname you choose (2 to 20 letters, digits, spaces, _ or -)	To label you in the game and in Campfire games on your local network	Your device and our server. Never shown to other players over the internet
Age band (under 13, 13 to 15, or 16 and over)	To apply the right ad and privacy settings for your age	Your device and our server
Coin events: type (level, Glimmer, daily, ad reward, rescue, shop), amount, depth reached, timestamp, and redemptions	To compute your balance, apply fair-play limits and run the charity pool	Your device and our server
PayPal email address, amount and status of each withdrawal request (only if you request a cash-out, players 18 and over only)	To review and pay your request, prevent fraud and keep financial records	Our server and PayPal
Platform (Android or iOS) and app version	To keep the service compatible and fix bugs	Our server
Ad data processed by Google AdMob and Google’s User Messaging Platform (UMP), see below	To show and measure ads and record consent choices	Google

Your IP address is used briefly in server memory for rate limiting and abuse prevention. Our application does not write it to the database or to its logs. Your hosting provider and network may process it as part of delivering the connection.

Campfire multiplayer runs only between devices on your local network. Nothing from a Campfire session is sent to our server.

We do not use analytics or crash-reporting SDKs in the game. We do not sell personal data, and we do not use it for profiling or automated decisions with legal effects.

Ads and advertising data

Lumijayon offers optional rewarded video ads served by Google AdMob. When you choose to watch one, Google may process your IP address, device information and, where allowed, the advertising ID. Google acts as an independent controller for its own advertising purposes; see Google’s privacy policy. We receive a signed confirmation from Google (server-side verification) containing a transaction ID, your device ID and the reward amount, to stop fraud.

Under 13: ads are requested with child-directed treatment and as non-personalized. The advertising ID is not used. No consent prompt for personalization is shown because personalization is off.
13 to 15: ads are requested as non-personalized with the under-age-of-consent flag. The advertising ID is not used.
16 and over: in the EEA, UK and Switzerland, Google’s UMP asks for your consent. Personalized ads and use of the advertising ID happen only if you agree. Elsewhere, you can limit ad personalization in your device settings. You can reopen the consent choices in the app under Settings.

Because the game is available to children, we use only ad formats and certified ad networks that comply with the Google Play Families policy. See also our ads and rewards policy.

Payouts

Cash-out is available only to players 18 and over. We collect your PayPal email address only when you submit a withdrawal request, and use it only to review and send that payment. It is shared with PayPal to make the payout, and PayPal acts under its own privacy statement. Withdrawal records are kept as financial records for as long as the law requires, even if you delete your other data; when you delete your data they are disconnected from your device ID. Children’s age bands never see cash-out and we never collect PayPal details from them.

Legal bases (GDPR / UK GDPR)

Contract (Art. 6(1)(b)): device ID, nickname, age band and coin events, to provide the game’s sync, daily challenge and rewards.
Legitimate interests (Art. 6(1)(f)): fraud and abuse prevention, rate limiting, security, and ad reward verification. We have weighed these against your rights, and we apply additional safeguards for children.
Consent (Art. 6(1)(a)): personalized ads and advertising ID use for players 16 and over, and for younger players only where valid parental consent applies. You can withdraw consent at any time in Settings without affecting earlier processing.
Legal obligation (Art. 6(1)(c)): where we must keep records (such as payout records) or answer lawful requests.

How long we keep data

Server account data (device ID, nickname, age band, coin events, ad verification records): until you delete it, or automatically after 24 months without activity.
Redemption records for the charity pool: kept for accounting without your device ID or request ID once your data is deleted.
Withdrawal records (amount, PayPal email, status, dates): kept as financial records for the period required by law, without your device ID once your data is deleted.
Backups of the database are rotated and deleted within 30 days of the original record being erased.
Data on your own device stays until you delete it or uninstall the game.

Who we share data with

Google (AdMob and UMP): Google Ireland Limited for the EEA and UK, otherwise Google LLC. Independent controller for ads.
Hosting provider: our virtual server provider ([HOSTING PROVIDER NAME AND LOCATION]) acts as our processor and stores the database.
PayPal: receives your PayPal email and the amount, only when you request a cash-out, to send the payment.
Google Play: distributes the app under its own terms and privacy policy.
Authorities, where legally required.

We do not share data with data brokers or for third-party marketing.

International transfers

Our server is located in [SERVER COUNTRY]. Google may process ad data in countries outside your own, including the United States. Where personal data leaves the EEA or UK, transfers rely on an adequacy decision (such as the EU-US Data Privacy Framework) or Standard Contractual Clauses and the UK addendum, with additional safeguards where needed.

Children

Lumijayon is designed to be suitable for children. We keep data to the minimum needed, and we do not enable chat, tracking for personalization, or public profiles. Parents will find a plain-language summary in the children’s privacy notice. We follow the Google Play Families policy, COPPA, GDPR-K (Art. 8 GDPR) and the UK Age Appropriate Design Code.

Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict or port your data, to object to processing based on legitimate interests, to withdraw consent, and to lodge a complaint with your data protection authority (for example your national authority in the EU, or the UK Information Commissioner’s Office). Parents and guardians may exercise these rights for a child. California residents have similar rights; we do not sell or share personal information for cross-context behavioral advertising.

Because we hold no name or email, we can only find your data using your Device ID, which is shown in Settings. We may ask you to prove control of the device, for example by pointing to your nickname and balance, before acting on a request. We respond within one month.

How to delete your data

In the app: Settings > Delete my data. This erases your server data immediately and resets the game on your device.
On the web: follow the steps on the data deletion page.

Security

All traffic uses HTTPS. Requests are signed with a per-device secret, and secrets are stored encrypted with AES-256-GCM. Access to the server is restricted, and the database is backed up on a schedule. No system is perfectly secure, and we will notify authorities and affected users of breaches as required by law.

Changes and contact

If we change this policy in a material way we will update the effective date above and show a notice in the app. Questions or requests: [email protected].