Privacy Policy

Our Privacy Obligations

Lumin.gg (“Lumin”) operates under the Australian Privacy Principles (APPs) per the Privacy Act 1988 (Cth). The company handles “personal information” defined as “information or an opinion about an identified individual, or an individual who is reasonably identifiable.”

The policy also addresses processing of personal data for European Union residents under the General Data Protection Regulation (GDPR). The company reviews and updates this policy regularly.

The Types of Personal Information We Collect and Hold

Lumin collects personal information to deliver products, services, and customer support across websites, phone apps, and email platforms.

Not all collected information constitutes “Personal Information” if it doesn’t identify a specific person — notably most “User Generated Content” shared among users. This “Non-Personal Information” falls outside this policy’s scope. However, non-personal information used in aggregate or linked with existing personal data becomes treated as personal information.

Information provided without request or through unintended channels bypasses company systems and controls, thus not governed by this policy. Information shared on external platforms (social media, forums) follows those platforms’ privacy policies, though information Lumin collects is governed by this policy.

How We Collect Personal Information

Information You Specifically Give Us

Users may provide personal information through websites, applications, online chat, telephone, paper forms, or in-person meetings. Lumin provides a Collection Notice explaining intended use, delivered verbally or in writing.

Potentially Requested Information:

• Account Details — username, password, profile picture
• Contact Details — email address, phone number
• Location Details — physical location, timezone
• User Generated Content — user messages, posts including videos

Information We Collect From Others

We do not currently collect personal information about users from others.

Information We Collect As You Use Our Service

Lumin maintains interaction records including products, services, and support provided. This covers platform interactions such as page views and button clicks.

The company may passively collect GPS coordinates where available on user devices. Modern smartphones typically display permission requests for this data.

Contact-initiated communications may yield intrinsic personal information. For example, email contact results in email address collection.

Potentially Collected Information:

• Metadata — IP address, computer and connection information, referring web page, standard web log information, language settings, timezone
• Device Information — device identifier, device type, device plugins, hardware capabilities
• Location — GPS position
• Actions — pages viewed, buttons clicked, time spent viewing, search keywords

Links to Other Sites

Third-party website links appear on Lumin’s site, from the company or user-generated content. These sites operate independently outside Lumin’s control. Users should examine terms and conditions and privacy policies before providing information elsewhere.

How We Use Personal Information

Collected information primarily enables delivering requested products or services. More specifically, Lumin may use personal information for:

• providing requested services or products
• delivering technical or other support
• answering service inquiries or addressing complaints
• promoting other programs, products or services of interest (unless opted out)
• platform debugging, testing, and operation
• data analysis, research, and platform improvement
• meeting legal and regulatory obligations
• purposes otherwise permitted or required by law
• other purposes with user consent, unless withdrawn

Lawful Processing Grounds include:

• user consent
• contract performance necessity
• legal obligation compliance
• vital interests protection of users or other persons
• pursuit of legitimate interests not infringing user rights

Automated Decision Making applies to:

• feed content display selection
• advertising and promotional material selection
• moderation decisions protecting platform integrity, safety, and security

When We Disclose Personal Information

Our Third Party Service Providers

User personal information may be held, transmitted, or processed by third-party service providers outside Australia, including cloud-based systems. These providers contractually bind to use information solely on Lumin’s behalf under company instructions.

Third-party service providers include:

• Cloud hosting, storage, networking and related providers
• Marketing and analytics providers

Other Disclosures and Transfers

Lumin may disclose personal information to third parties for:

• providing requested services or products
• complying with court orders, subpoenas, or law enforcement information requests
• purposes otherwise permitted or required by law
• other purposes with user consent

Accessing, Correcting, or Downloading Your Personal Information

Users have rights requesting personal information access that Lumin holds. Unless exceptions apply, the company must allow information viewing within reasonable timeframes without unreasonable expense or charge. Most personal information is accessible through account login.

Users may contact the Privacy Officer to access information unavailable through the platform or download all held personal information in portable format.

Users also possess rights requesting personal information correction. Updates occur through user settings pages, with customer support available for assistance.

Exercising Your Other Rights

Users possess additional rights regarding held personal data, though restrictions may apply due to product and service nature. Much collected data facilitates user contracts, payment processing, and legitimate marketplace user protection — uses protected against the following rights.

Users have the right to:

• seek human review of automated decision-making or profiling
• opt-out of direct marketing and marketing profiling
• erasure, commonly referred to as “the right to be forgotten”
• temporary processing restriction

Users exercise these rights by contacting the Privacy Officer.

To Contact Our Privacy Officer

For inquiries or complaints regarding personal information handling, or to exercise privacy rights:

By Email: privacy@lumin.gg

For GDPR purposes, the Privacy Officer also serves as Data Protection Officer (DPO).

The company endeavors resolving complaints quickly and informally. Formal privacy complaints should be submitted in writing to the Privacy Officer via email. Formal complaint acknowledgment occurs within 10 working days of receipt.

If unresolved to satisfaction, users may lodge complaints with the Office of the Australian Information Commissioner (OAIC) by calling 1300 363 992, complaining online at www.oaic.gov.au, or writing to OAIC, GPO Box 5218, Sydney NSW 2001.

European Union residents may lodge complaints with local Data Protection Authorities (DPA). DPA lists appear at ec.europa.eu/justice/article-29/structure/data-protection-authorities.