This policy covers lumia.game and its waitlist. Lumia has one privacy policy for everyone: when the game opens to everyone, a section about the game will be added here, and if you're on the list we'll email you before it applies.
Who we are
lumia.game is run by Artem Dubinin PR Mighty Study, a sole proprietorship registered with Serbia's Business Registers Agency: Belgrade, Serbia, MB 66829090, PIB 113442582. We decide how your information is used (in privacy law, we're the "controller"). Write to us at hello@lumia.game about anything in this policy. We haven't appointed a data protection officer; the same address reaches the people who run Lumia.
What we collect
When you join the waitlist:
- your email address;
- whether you're a parent, educator or investor (the role you pick);
- which page you signed up on, and the campaign tag in the link you followed, if it had one (for example, a link we shared on X);
- the dates you signed up, when we sent your welcome email and when you unsubscribed, if you do;
- a random code that makes the unsubscribe link in your emails work.
We never ask about your child.
Your IP address (your connection's internet address) passes through our server for a moment so we can limit how often one connection can sign up, which stops abuse. We don't store it.
When you visit any page, our host, Cloudflare, handles your IP address and browser details to deliver the page and protect it from attacks, as every web host does. Our visit counter, Umami, is described under Cookies and visit counts below.
Giving us your email is optional. Without it, we can't tell you when Lumia opens.
Why we use it, and on what legal basis
- To email you about Lumia opening: a welcome email now, and an email when Lumia opens. We send only these. Our legal basis is your consent, which you give by joining. You can withdraw it at any time (see below).
- To know who's interested and what brought them (your role, the page and the campaign tag): this is our legitimate interest in building Lumia for the people who want it and in knowing which of our posts work.
- To keep the site and the waitlist safe (your IP address, Cloudflare's logs): our legitimate interest in stopping abuse and attacks.
- To count visits (Umami): our legitimate interest in learning which pages help visitors. You can switch it off (see below).
We don't make automated decisions about you, we don't build profiles, and we never sell your information or share it for advertising.
Who helps us handle it
These companies process information for us, under contracts that let them use it only to provide their service:
- Cloudflare, Inc. hosts the site and runs the waitlist form (a worldwide network; a US company).
- Railway Corporation hosts the database that stores the waitlist (United States).
- Plus Five Five, Inc. (Resend) sends the welcome email and later emails (United States).
- Umami Software, Inc. counts visits, without cookies (United States and European Union).
Your information is stored in the United States. Cloudflare, Railway and Resend are certified under the EU-U.S. Data Privacy Framework, which the European Commission found to give adequate protection; Serbian law recognises that finding. Umami is bound by the European Commission's standard contractual clauses. Ask us for a copy of these safeguards at hello@lumia.game.
How long we keep it
We keep your email and role while you're on Lumia's list. If you unsubscribe, we keep only your address, marked "unsubscribed", so we never email you again by mistake. Write to us and we'll delete everything, including that, within 30 days.
Your rights
You can ask us to show you the information we hold about you, correct it, delete it, limit how we use it, send it to you in a common format, or stop using it for the purposes based on our legitimate interest. Write to hello@lumia.game; we answer within 30 days.
Withdrawing consent: click Unsubscribe in any of our emails (one click), or write to us. It doesn't affect emails already sent.
Complaints: you can complain to Serbia's Commissioner for Information of Public Importance and Personal Data Protection (poverenik.rs) or, if you live in the EU or the UK, to your local data protection authority. We'd be glad to hear from you first.
Cookies and visit counts
This site sets no cookies. We count visits with Umami, which uses no cookies and stores no names or email addresses. To tell visits apart, it makes a code from your IP address and browser that changes every month, and it doesn't follow you to other sites. No other company tracks you across sites from our pages.
Do Not Track: if your browser sends a Do Not Track signal, Umami doesn't count your visit at all. Blocking Umami's script in your browser stops it too, and the site works the same.
Children
This site and its waitlist are for grown-ups. We don't knowingly collect information from children under 13 (under 15 in Serbia). If you think a child signed up, write to us and we'll delete it. Before any child plays Lumia, this policy will gain a section about the game, with the notice to parents and the parental consent that children's privacy law requires.
Keeping it safe
Everything travels encrypted (HTTPS), and only the people who run Lumia can see the waitlist.
Changes
When we change this policy, we change the date at the top. If a change affects how we use your email, we'll email you before it applies.
Artem Dubinin PR Mighty Study · Belgrade, Serbia · MB 66829090 · PIB 113442582