Last Updated: April 16, 2026
IMPORTANT NOTICE: YOU MUST READ THIS PRIVACY POLICY ("POLICY") TOGETHER WITH TERMS OF SERVICE , THE OFFICIAL PROMOTIONAL PLAY RULES, THE RESPONSIBLE GAMING POLICY AND THE GAME STATEMENT (COLLECTIVELY AS THE "INCORPORATED POLICIES"). BY ACCESSING OR USING OUR SERVICES (AS DEFINED HEREIN), YOU AGREE TO BE BOUND BY THIS POLICY AND THE INCORPORATED POLICIES.
This Policy forms a legally enforceable agreement between Luma Field Inc (referred to as the "Company," "we," "us," or "our") and you (referred to as the "User," "you," or "your"). This Policy governs your access to, use of, and interaction with all our digital products and offerings, including our official websites, mobile applications, online games, user profile systems, and all associated features, tools, and supplementary services (collectively, the "Services"). The protection of personal data collected through our Services is an important priority for us.
Within this Policy, we explain the categories of information we may collect, the purposes for which we process such information, the situations in which we may share it, and the rights applicable data protection laws make available to users.
We restrict use of the Services to individuals who are twenty-one (21) years of age or older. We do not intentionally collect or process personal information from individuals under the age of 21. If we become aware that we have obtained data relating to a person below this age, we will take reasonable steps to remove such information promptly.
1. Information We Collect
• Contact Information: Information such as your name, email address, phone number, and mailing address.
• Account Information: Details associated with your account, including your user ID, password, and account verification status.
• Personal Information: Information such as your date of birth, age, gender, VIP level, and gameplay history.
• Transaction and Usage Information: Data relating to your purchases, redemptions, and interactions within the Services.
• Preference Information: Information about your preferences, including your choices regarding marketing communications and promotional offers.
• Location and Device Information: Technical data that may include your SIM card region, IP address, device settings, operating system, time zone, browser type, and device identifiers. We prohibit the use of VPNs or similar tools to access the Services.
In addition, we may automatically collect certain information through SDKs and similar technologies, including device identifiers, advertising IDs, usage statistics, and analytics data.
We may also collect information you voluntarily provide to us when you register for an account, use the Services, participate in promotional play, make purchases, contact our support team, or engage in gameplay activities.
NOTICE: In certain circumstances, we may collect or process limited types of sensitive personal information for purposes such as identity verification, security monitoring, customer support, and maintaining the integrity of our platform. This may include the following categories of information:
Photographs: For example, selfies or images you submit for identity verification purposes.
Video Recordings: Such as short video clips used for liveness detection or identity verification processes.
Audio Recordings: Including recordings generated during interactions with customer support.
We collect photographs, selfies, video recordings, and audio recordings solely for identity verification or security-related purposes where necessary. Where we require biometric processing, authorized third-party identity verification providers perform it exclusively. We do not create, store, or retain biometric identifiers or biometric templates.
We use such sensitive personal information solely for purposes of security monitoring, identity verification, fraud prevention, and compliance with applicable laws and regulations.
2. How We Use Your Information
We process personal information for the following purposes:
• To provide, operate, and maintain the Services;
• To create, manage, and secure user accounts;
• To process transactions, purchases, and redemptions within the Services;
• To send service-related communications, including updates, notices, and promotional messages where applicable law permits;
• To detect, prevent, and investigate fraud, abuse, or other unauthorized activities;
• To comply with applicable legal, regulatory, and compliance obligations.
Where applicable law requires, the legal bases for processing personal information may include your consent, the necessity of processing for the performance of a contract, our legitimate business interests, or compliance with legal obligations.
You may request the deletion of your account and associated personal information by contacting us at [email protected]. Upon receipt and verification of a valid request, we will take reasonable steps to delete or deactivate your account. Once your deletion request has been processed, your account will be deactivated and your access to the Services will be terminated.
However, even in the event we delete or deactivate your account, we may retain certain information where necessary for legitimate purposes, including:
• Compliance with legal or regulatory requirements;
• Fraud prevention and security monitoring;
• Resolution of disputes;
• Enforcement of this Policy or any of the Incorporated Policies.
3.Identity Verification (KYC) Information
To comply with applicable legal and regulatory requirements, as well as to support fraud prevention and maintain platform integrity, we may require users to complete an identity verification process (commonly referred to as "KYC").
3.1 Types of Information We Collect
When we require identity verification, we may collect or process certain information necessary to verify your identity. This may include:
• Personal identification details, such as your full name, date of birth, and nationality;
• Information government-issued identification documents contain, including passports, driver's licenses, or national ID cards;
• Selfie images you submit for identity verification purposes;
• Residential address information and supporting proof of address where required;
• Device and account identifiers, including your user ID and related account information;
• Video, photo, and/or audio recordings generated during identity verification calls, chats when applicable.
We collect and process this information solely for the purpose of identity verification, fraud prevention, and compliance with applicable legal and regulatory obligations.
3.2 Use of Your Information
Authorized third-party verification providers may collect and process identity verification information and share it with us solely for the purposes described below.
We may use such information to:
• Comply with applicable legal and regulatory requirements;
• Detect and prevent fraud, money laundering, and other forms of misuse of the Services;
• Verify user eligibility to access the Services, including compliance with applicable age restrictions.
3.3 Third-Party Verification Providers
We may rely on trusted third-party identity verification providers, such as Sumsub or similar service providers, to conduct identity verification on our behalf. These providers may collect and process verification-related information as part of the identity verification process.
We contractually require such providers to implement appropriate safeguards to protect your personal information and we permit them to use the information solely for identity verification and regulatory compliance purposes.
3.4 Retention of Data
We retain identity verification information only for as long as necessary to fulfill the purposes described above or as applicable laws and regulations require. Where possible, we retain verification outcomes or status results rather than storing full copies of identification documents.
We do not sell, lease, trade, or otherwise monetize biometric data. We handle any biometric information that may undergo processing as part of the verification process solely for identity verification purposes and retain it only for the period necessary to complete the verification process and to comply with applicable legal requirements.
4.Geolocation and Location Limits
To comply with applicable laws and regulatory requirements, we may restrict access to our Services in certain locations. We may use information such as your IP address and device settings to determine your approximate geographic location.
Access to our Services is currently prohibited in the following territories: Alabama, California, Connecticut, District of Columbia, Idaho, Louisiana, Michigan, Montana, Nevada, New Jersey, New York, and the State of Washington of the United States.
You are responsible for ensuring that your use of the Services complies with the laws and regulations applicable in your place of residence. We strictly prohibit the use of Virtual Private Networks (VPNs) or similar technologies to circumvent geographic restrictions and such use constitutes a violation of this Policy and the Incorporated Policies.
5.Geolocation and Device Verification Consent
To comply with applicable jurisdictional requirements and to prevent fraud or unauthorized access, we may collect, use, and process certain location-related and device-related information when you access or use the Services. Such information may include your IP address, GPS data, Wi-Fi or network signals, device identifiers, operating system information, browser or application settings, and other technical indicators used to help verify your location and maintain the security and integrity of our platform. We may also engage trusted third-party service providers that specialize in geolocation verification and fraud prevention to perform these verification activities on our behalf.
When you access or use the Services, we may use certain technologies to detect attempts to conceal or alter your actual location or device environment. These detection methods may include identifying the use of VPNs, proxy services, remote access tools, virtual machines, emulators, or other similar technologies designed to bypass geographic or technical restrictions. If we cannot successfully verify your location, or if we detect access from a restricted jurisdiction, we may limit, suspend, or make unavailable some features or functionalities of the Services.
We will process any location and device-related information we collect for compliance and fraud prevention purposes in accordance with this Privacy Policy and retain it only for the period necessary to comply with applicable legal, regulatory, and security obligations.
6.Detection of VPN, Proxy, and Circumvention
To maintain fair play and comply with applicable legal requirements, we strictly prohibit the use of technologies intended to conceal or manipulate your actual location or device environment. Such technologies may include VPNs, proxy servers, location-spoofing software, emulators, or remote desktop applications.
We may monitor for the use of these tools or similar circumvention technologies. If we detect such activity, we reserve the right to take appropriate action, including suspending your account or restricting your ability to redeem prizes or access certain features of the Services.
7.Third-Party Data Collection and Sharing
We do not sell your personal information. However, we may share certain information with trusted third-party service providers that assist us in operating and supporting our business. Such sharing occurs only where necessary and remains subject to strict confidentiality and data protection obligations.
These service providers may include identity verification providers (such as Sumsub), fraud detection and risk management service providers, payment processors, cloud hosting and infrastructure providers, as well as analytics and advertising partners.
We contractually require all third-party service providers to process personal information solely on our behalf and only for the purposes we specify. We also require them to implement appropriate technical and organizational security measures to safeguard your information.
8. Protection of Your Data
We implement reasonable technical and organizational safeguards to protect your personal information from unauthorized access, disclosure, alteration, or loss. These measures include the use of encryption technologies and secure server environments. Certified third-party payment processors handle payment transactions. We do not store or retain your full credit card information.
While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage can be guaranteed to be completely secure. We therefore encourage you to use strong passwords and take appropriate steps to protect your account credentials.
9. How and When We Share Information
We do not sell your personal information. However, we may disclose certain information in limited circumstances where necessary to operate our Services or comply with legal obligations. Such disclosures may occur in the following situations:
Service Providers: We may share information with trusted vendors or partners that perform services on our behalf, such as data hosting, customer support, or fraud prevention.
Corporate Transactions: We may transfer or disclose personal information in connection with corporate events, including mergers, acquisitions, reorganizations, financing transactions, or the sale or transfer of assets.
Legal and Regulatory Compliance: We may disclose information where applicable laws, regulations, court orders, or lawful government requests require compliance.
Protection of Rights and Safety: Disclosure may also occur where necessary to protect the rights, property, or safety of the Company, our users, or other parties.
We contractually obligate our third-party service providers to use personal information solely for authorized purposes and to maintain appropriate confidentiality and security protections.
10. Advertising, Analytics and SDKs
To support advertising delivery, analytics, and performance measurement, we may work with third-party partners that use cookies, SDKs, or similar technologies to collect information about interactions with websites and applications. We may use this information to deliver relevant advertising content and to help us evaluate the effectiveness of our marketing campaigns. Where available, users may manage their cookie preferences through their browser or device settings.
We may also use analytics and attribution services third parties provide, such as Google Analytics, Firebase, and AppsFlyer, to analyze user engagement, measure campaign performance, detect fraudulent activity, and improve the functionality of our Services. These partners may collect and process certain information through SDKs and related technologies in accordance with their respective privacy policies.
We do not sell personal information in exchange for monetary compensation. However, applicable privacy laws may regard certain disclosures we make for advertising or analytics purposes as "sharing." Where law requires, users may exercise their right to opt out of such sharing in accordance with applicable local regulations.
11. Links to the Third-Party
The Services may include links to external websites or platforms for informational or convenience purposes. Third parties operate these websites independently and we do not control them.
We bear no responsibility for the privacy practices, content, or policies of such third-party services. We recommend that users review the privacy policies of any external websites or platforms before providing or submitting personal information.
12. Legal and Safety Disclosures
We may disclose personal information where we reasonably believe such disclosure becomes necessary to comply with applicable laws, regulations, legal processes, or governmental requests. Disclosure may also occur where necessary to enforce this Policy and any of the Incorporated Policies, investigate suspected violations or misconduct, or protect the rights, property, or safety of the Company, our Users, or third parties.
13. Requests for Data Deletion
Users may request the deletion of their personal information where permitted under applicable laws and regulations. Deletion requests may be submitted by contacting us at: [email protected].
For security and verification purposes, we may require users to confirm their identity before we process a deletion request. This verification may include confirming the registered email address or other account-related information. We will review and process all requests in accordance with applicable legal, regulatory, and operational requirements and within the timeframes applicable law requires.
14. Protection of Children's Privacy
Our Services are intended for individuals who are 21 years of age or older. We do not knowingly collect personal information from individuals under the age of 21.
If we become aware that we have inadvertently collected personal information from an individual under the age of 21, we will take reasonable steps to promptly delete such information from our records.
15. California Privacy Rights
This section applies solely to individuals residing in California. Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"), California residents have certain rights regarding their personal information.
Information We Collect
We collect the following categories of personal information from California residents:
• Identifier information, such as IP address, device ID, email address, and online identifiers;
• Geolocation data, approximated from IP address.
We collect this information from you directly, automatically through cookies and similar technologies, and through third-party analytics and advertising partners.
Why We Collect and Share Your Information
We use this information to operate and improve our website, analyze usage, and serve advertisements. We share this information with third-party analytics providers (such as Google Analytics) and advertising platforms (such as Meta and Google Ads) to perform these functions. Under the CCPA, this type of sharing for cross-context behavioral advertising is considered a "share" of personal information.
Your Rights
If you are a California resident, you have the right to:
• Know what personal information we have collected about you, including the categories of sources, business purposes, and third parties with whom we shared it.
• Request deletion of your personal information, subject to certain exceptions.
• Request correction of inaccurate personal information we maintain about you.
• Opt out of the "sharing" of your personal information for cross-context behavioral advertising.
• Not receive discriminatory treatment for exercising any of these rights.
How to Exercise Your Rights
To submit a request to know, delete, or correct your personal information, please contact us at [email protected]. We will verify your request using information you provide, such as your email address or device information, and respond within the timeframes required by law.
Authorized agents may submit requests on your behalf; we may require proof of your written permission and may verify your identity directly.
Opt-Out of Sharing
We currently do not provide a "Do Not Sell or Share My Personal Information" link within our Services. If you would like to opt out of the sharing of your personal information for cross-context behavioral advertising, please contact us at the email address provided above. We are actively evaluating mechanisms to provide a direct opt-out channel in the future.
16. Non-Confidential Submissions
Unless otherwise required by applicable law, any ideas, suggestions, feedback, or other materials you provide to us that are not subject to a confidentiality obligation may be used by the Company freely and without compensation.
17. Contact Us
For any questions, concerns, or requests regarding privacy or data protection, please reach out to us at: [email protected].