LUMINI
Effective Date: August [ ], 2026
DAILYBREAD CO., LIMITED ("DailyBread," "we," "us," or "our") develops and publishes mobile games and related products (the "Services"). This Privacy Policy explains what personal information we handle, why, and the choices available to you.
This policy is arranged so that Parts A, B, C and D describe practices that apply to everyone. Part E contains additional information that applies only if you live in a specific region. Part F contains administrative information. If you do not agree with this policy, please refrain from using our Services.
Part A — Introduction
A.1 Who We Are
DAILYBREAD CO., LIMITED is a limited company. Our products are distributed through mobile application stores, our own websites, and (where applicable) third-party gaming platforms. Where handling of your Personal Information for a specific product materially differs from what is described here, we will provide you with supplementary information at the point of collection or inside the product.
A.2 When This Policy Applies
This Privacy Policy applies whenever you:
- play any of our mobile games, in either online or offline mode;
- use one of our websites that links to this Privacy Policy;
- engage with our community pages or channels; or
- contact us through any of our support routes.
Part B — Data Practices
B.1 Personal Information That We Collect
Depending on how you interact with our Services, we collect different categories of personal information. The table below discloses the categories (including statutory categories under the CCPA), specific data types, and the sources of such information. Please note that the table below outlines only the categories of personal information that may potentially be collected by the Service. Depending on your specific interactions with the Service, we will only collect the minimum information necessary for the corresponding context. In certain scenarios, relevant usage data may be stored exclusively on your local device.
| Category | Specific Personal Information | Source of Information |
|---|---|---|
| A. Identifiers & Customer Records | Account IDs: unique in-game user ID and third-party platform IDs (e.g., Apple, Google, Facebook) | Automatically collected ; Received from third-party |
| Device & Technical IDs: Device IDs (IDFV, Android ID), Advertising IDs (IDFA, GAID), IP address, system language, country/region settings | Automatically collected | |
| Purchase IDs: Transaction ID / Order ID (generated by App Store / Google Play) (Note: We do not collect or process your sensitive payment or financial data, such as credit card numbers or banking details, which are handled exclusively by the third-party payment processors). | Received from third-party | |
| Profile Information： Nickname and profile picture and third-party platform profile Information (e.g. Facebook) | Provided voluntarily by you； Received from third-party | |
| B. Commercial Information | Purchase & Subscription History: Records of subscriptions, in-app purchases, transaction amounts, and timestamps | Provided voluntarily by you Received from third-party |
| Virtual Asset Records: Records of premium features unlocked, virtual currencies, or virtual items obtained | Automatically collected | |
| User Identification Linking: Internal user identification numbers associated with specific orders | Automatically collected | |
| C. Internet Activities | Gameplay Data: Game progress, level completion, puzzle-solving stats, scores, and achievements unlocked | Automatically collected |
| Interaction Logs. Timestamps of game access, session duration, and clickstream data within the game menu,Records of using specific features | Automatically collected | |
| System Logs. App version used, crash logs, and performance telemetry data | Automatically collected | |
| D. Geolocation Data | Coarse Location: Country, region, or city-level location derived from your IP address or device language settings. (Note: We do not collect precise GPS data) | Automatically collected |
| E. Inferences Drawn from Other Personal Information | User Profiling & Segment: Inferences drawn from your gameplay data, purchase behavior, and game engagement to create a profile regarding your preferences or player segment (Note: We do not draw inferences that reveal sensitive personal characteristics). | Automatically collected |
B.2 Why We Collect Your Personal Information
| Purpose | Examples of Processing Activities | Personal Information | Legal Basis |
|---|---|---|---|
| Service Provision & Maintenance | Operating and maintaining the games, saving game progress, and processing in-app transactions. | Category A, B | Contract |
| Responding to player inquiries and providing customer support. | Contract / Legitimate Interests | ||
| Sending service-related notifications and legally required policy updates. | Contract / Legal Obligation | ||
| Game Experience and Service Improvement | Analyzing usage trends and player behavior to improve game mechanics | Category A,B,E | Legitimate Interests |
| Monitoring, diagnosing, and fixing technical bugs and crashes. | |||
| Delivering in-game personalized content recommendations tailored to preferences. | |||
| Surveys, Events & Marketing | Processing surveys, marketing events, feedback, and suggestions submitted voluntarily by you. | Category A, E | Consent |
| Advertising | Delivering non-personalized (contextual) ads. | Category A,D | Legitimate Interests |
| Delivering personalized ads. | Category A,C,E | Consent | |
| Measuring ad campaign effectiveness, tracking installations, and preventing ad fraud/invalid clicks. | Category A,C | Legitimate Interests | |
| Security and Compliance | Monitoring, detecting, and preventing cheating, hacking, fraud, or other illegal activities | Category A,B,C | Legal Obligation / Legitimate Interests |
| Complying with applicable legal obligations, regulatory requirements, government requests, or defending our rights. | |||
| Facilitate Corporate Acquisitions, Mergers and Transactions | Category A, B | Legitimate Interests | |
| Other Circumstances with Prior Consent | Any categories as specified at the time of collection | Consent | |
B.3 How We Disclose Your Personal Information
| Categories of Recipients | Purpose & Activities | Personal Information Disclosed |
|---|---|---|
| Vendors and Service Providers (Processors) | To perform services on our behalf, including cloud hosting, customer support tools, data analytics, and functional SDKs. | Category A, B, C |
| Advertising and Business Marketing Partners | To deliver personalized/contextual advertisements, conduct campaign attribution. | Category A, C, D, E |
| To conduct joint-marketing activities, IP collaborations, or promotional partnerships. | ||
| Affiliates | To support global operations, internal administration, and shared business infrastructure among our parent, subsidiary and affiliated companies. | Category A, B, C |
| Law Enforcement, Authorities and Professional Advisors | To comply with legal obligations, court orders, or government requests. | Category A, B, C |
| To enforce our ToS, protect our legal rights, and protect the safety of players. | ||
| Potential Buyers or Merger Partners | To disclose, transfer, or assign your personal information to a third party in the event of any merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. | Category A, B, C,D, E |
B.4 Sensitive Personal Information
We do not routinely collect Sensitive Personal Information. We do not ask you to provide, and we do not knowingly infer, information about your health, race, ethnicity, religion, political opinions, sexual life or orientation, precise geolocation, biometrics, or trade-union membership. If you volunteer such information in the content of a support ticket, we will handle it only to respond to your enquiry and will delete it once the enquiry is resolved.
Part C — Your Rights
C.1 The Rights You May Have
Depending on where you live and which laws apply to your Personal Information, you may have some or all of the following rights:
- Access — to obtain a copy of the Personal Information we hold about you.
- Correction — to have inaccurate or incomplete Personal Information corrected.
- Deletion / Erasure — to have your Personal Information deleted, subject to legal exceptions.
- Portability — to receive certain Personal Information in a structured, commonly-used, machine-readable format.
- Restriction — to restrict how we handle your Personal Information in certain circumstances.
- Objection — to object to certain handling, including direct marketing.
- Withdrawal of consent — where our handling is based on your consent.
- To lodge a complaint — with the data protection or consumer protection authority for your country.
C.2 Making a Request
To exercise any of these rights, email us with the subject line "Privacy Rights Request." Tell us:
- which right you want to exercise;
- enough information for us to identify you (typically the account email address or the in-game user ID); and
- for deletion or correction requests, the specific Personal Information concerned.
We may follow up to verify your identity before we act on a request. We will respond within the timeframe required by the law that applies to you. Your rights are not absolute — we may decline a request where the law allows us to do so, and we will explain our reason in that case.
C.3 Children
Our Services are not aimed at children below the minimum age set by the law of the country where the child lives. We do not knowingly collect Personal Information from children below that age.
If you are a parent or legal guardian and you believe your child has provided Personal Information to us, please contact us at the address in Part F. We may send a follow-up email to verify your identity. Once verification is complete, we will delete the child's Personal Information from our records and disable any associated account. If the child was using an offline guest mode with data stored only on the device, deletion will need to be performed on that device.
Part D — How We Safeguard Personal Information
D.1 Security
We maintain commercially reasonable administrative, technical, and physical safeguards to protect Personal Information against unauthorised access, alteration, disclosure, and destruction. No system is completely secure — if you believe you have identified a security issue, please report it to us at the contact address in Part F.
D.2 Retention
We keep Personal Information only for as long as we need it for the purposes described in this policy, plus any additional period required by law (for example, financial records may be retained to meet accounting or tax obligations). Where deletion is not immediately feasible (for example, in backups), we isolate the data and prevent further processing until scheduled deletion occurs.
D.3 International Transfers
We operate internationally. Your Personal Information may be handled in countries other than your own, including countries whose data protection laws differ from those of your country. Where we transfer Personal Information across borders, we put in place safeguards required by the applicable law — including, for European users, the European Commission's Standard Contractual Clauses, and the UK International Data Transfer Addendum for UK users. For further region-specific detail, see Part E.
D.4 Corporate Transactions and Legal Process
We may disclose or transfer Personal Information (a) to a purchaser or successor in the context of a proposed or completed merger, acquisition, reorganisation, or asset sale; (b) to comply with a valid legal process, including subpoenas, warrants, and court orders; (c) to respond to valid requests from public authorities; (d) to enforce our terms and agreements; or (e) to protect the safety of you, other users, our staff, or the public. Where lawful, we will give you advance notice of any government-initiated disclosure that concerns you.
Part E — Region-Specific Notices
E.1 Additional Information for Users in the United States
This Section E.1 supplements Parts A–D for users located in the United States. In case of any conflict, this Section E.1 prevails in respect of such users.
E.1.1 The rights described below may be available to you depending on your state of residence. If a right listed below is not available to you under the law that governs your Personal Information, we have discretion to provide it.
- Right to know / access — to know what categories of Personal Information we collect about you, for what purpose, and to whom we disclose it, and to obtain a copy.
- Right to correct — to have inaccurate Personal Information corrected.
- Right to delete — to request deletion of your Personal Information, subject to legal exceptions.
- Right to data portability — to receive a copy of certain Personal Information in a portable format.
- Right against discrimination — not to be discriminated against for exercising privacy rights.
- Right to opt out of sale or sharing — see Section E.1.2 below.
- Right to limit use of sensitive personal information — where the state law applying to you provides one.
- Right to opt out of automated decision-making or profiling — where applicable.
- Right to appeal — where we decline a request. Appeal instructions will be provided with any denial.
- Right to obtain a third-party list — to request the specific third parties to which we have disclosed Personal Information.
E.1.2 Sale, sharing, and targeted advertising.
As at the Effective Date of this Privacy Policy, DailyBread does not sell Personal Information, and does not "share" Personal Information for cross-context behavioural or targeted advertising as those terms are defined under laws such as the CCPA/CPRA. Because we currently do not integrate any third-party advertising SDKs in our products, no opt-out is required to stop such activity. If our practices change, we will update this Privacy Policy and provide the opt-out mechanisms required by law before making that change.
E.1.3 Authorised agents.
In certain states you may designate an authorised agent to submit a request on your behalf. If you do, please (a) provide the agent with signed written permission, and (b) provide us with reasonable proof of your identity and of the agent's authority.
E.1.4 Additional information for California consumers.
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA"), requires us to disclose the categories of Personal Information we have collected in the preceding twelve months. These categories are set out in the first column of the table in Section B.1 of this Privacy Policy; the sources of that Personal Information are set out in the third column of the same table; the purposes for which we handle it are set out in the table in Section B.2; and the categories of third parties to whom we disclose Personal Information are set out in Section B.3.
E.2 Additional Information for Users in the EEA, the UK, and Switzerland
This Section E.2 supplements Parts A–D for users located in the European Economic Area, the United Kingdom, or Switzerland (each, a "Designated Country"). In case of any conflict, this Section E.2 prevails in respect of such users.
E.2.1 Controller.
DAILYBREAD CO., LIMITED is the controller of Personal Information handled in connection with your use of the Services.
E.2.2 Legal bases.
The legal bases for our processing under the EU/UK GDPR are set out in the "Legal Basis" column of the table in Section B.2.
E.2.3 Your rights.
In addition to the rights described in Part C, you also have the right to lodge a complaint with your national data protection authority:
- EEA supervisory authorities: see the member list on the European Data Protection Board's website (edpb.europa.eu).
- United Kingdom: the Information Commissioner's Office (ICO), ico.org.uk.
- Switzerland: the Federal Data Protection and Information Commissioner (FDPIC), edoeb.admin.ch.
E.2.4 Direct marketing.
We will only send you electronic marketing communications (such as email or SMS) where you have given us your prior consent, or as otherwise permitted by applicable law based on our legitimate interests. You can withdraw your consent at any time by using the unsubscribe link included in each marketing message or by contacting us at the address in Part F.
E.2.5 International transfers.
When we transfer Personal Information from a Designated Country to a country that is not the subject of an adequacy decision, we put in place appropriate safeguards, including the European Commission's Standard Contractual Clauses (for transfers subject to EU GDPR) and the UK Information Commissioner's International Data Transfer Addendum (for transfers subject to UK GDPR). For transfers from Switzerland, we apply the Standard Contractual Clauses with the modifications recommended by the FDPIC. A copy of the applicable safeguards is available on request.
Part F — Administrative
F.1 Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will change the "Effective Date" at the top and, where the change is material, we will provide additional notice — for example, by placing a notice in the Services or by contacting you directly. Any change will take effect from the Effective Date.
F.2 Contact Us
For any questions or concerns about this Privacy Policy or how we handle Personal Information, or to exercise any of your rights, please contact us at:
DAILYBREAD CO., LIMITED
Email: support@luminigamestudio.com