Effective Date of the current Privacy Policy: 27th September 2025

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Last Updated: 13th October 2025

Welcome to Our Privacy Policy (the “Privacy Policy”). 

 

We at Lumion Technologies Limited, a company registered under the laws of the United Kingdom with our offices located at #1650, Arlington Business Par k Theale, Reading Berkshire, RG7 4SA, United Kingdom (hereafter referred to as the “Company” respect your privacy and provides you with this Privacy Policy which has been compiled to tell you about Company’s practices regarding collection, use, and disclosure of information and the use of the ‘Personally identifiable information’ (PII) that you may provide us while accessing and playing our Game, our websites, platforms, software services and related services (collectively referred to as the “Services”). Please note that your access/play or use of our game ‘Lokko’ (hereafter referred to as the “Game”) also constitutes your acceptance of this Privacy Policy as well as our End User License Agreement found here:

EULA: Lokko

Any use or access of the Services the Platform or by providing any information to us through the Services, You agree to the terms of this Privacy Policy. 

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IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE DO NOT ACCESS THE SERVICES AND/OR PLAY THE GAME.

 

Please see Section 18 for a full list of definitions for the capitalized terms which are not otherwise defined under this Privacy Policy or the End User License Agreement.

 

Revisions to Privacy Policy: 

• We reserve the right to update and revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since Your last visit by referring to the “Last Updated” date at the top of this page. You should therefore review this Privacy Policy regularly to ensure that You are aware of its terms and amendments. Your use of the Platform constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us.

 

 

Information collected by the Company:

• Our primary goal of collecting your information is to provide you a safe, efficient, smooth and customized experience. This allows the Company to provide the Services and features that most likely meet your needs, and to customize our Services to make your experience safer and easier.

 

• To access, play or use the Game, a user will have to create an account with the Company. For creating an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. 

 

• The Company through payment gateway service providers collects financial information on the terms and conditions set out in this Privacy Policy and on the payment gateway service providers’ own privacy policies, which can be found on the respective platforms. The Company does not use financial information for any purpose other than processing payments. 

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• Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile in our Game, interests in and use of various games, products and services, and any other personal or preference information.

 

• The Company may also collect and process other information when you interact with the Game online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Game. Such information will be collected and processed irrespective of whether you only access the Game or if you actually play the Game.

 

• The Company may also collect and process certain information when you as a user with a user account interact with the Game such as the information in your personal profile, the relationships you form in the Game, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.

 

Age Identification:

• To identify your age for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We request that anyone under the age of 18 to not send any Personal Data about themselves over the internet to us unless is sent under the supervision of a parent or guardian. We do not knowingly collect Personal Data from children under 13 years old in the Game or as part of the Services. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or played the Game and provided personally identifiable information to us, please contact us at support@appymonkeys.com or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. This in compliance with Article 6(1)(c) of the GDPR.

 

• What other information do we collect from a user that visit or uses our Services?

 

Automatic Information:

• We receive and store certain information such as your location, which automatically becomes accessible to us by virtue of you accessing the Services on your device. Additionally, we use Cookies and obtain certain types of information when your device accesses the Services.

 

Stored Information: 

• We store all data that is shared by you or by a third party on your behalf such as image files, documents etc. either at the time of accessing the Services or on any information provided by you. 

Marketing Information:

• We may invite you to share your email address with us for sales and marketing purposes. You may be invited to do this in the Game, related websites etc., as well as third party ad networks. By opting in to receive these emails on our website or from our ad partners, you are giving your consent to receive these types of sales and marketing emails, as well as us storing Personal Data related to such emails and related material in accordance with the terms and conditions of this Privacy Policy.

Invitations:

• If you choose to use any invitation service to tell a friend about the Game, the Company will need you to provide such Personal Data of your friend as necessary to send this invitation. The Company stores this Personal Data to send a one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact the Company at support@appymonkeys.com or the mailing address at the end of this Privacy Policy to request us to remove this Personal Data from our database. 

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• We may also collect, use, store and disclose aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data as this data will not reveal your identity.

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• We do not collect any special categories of Personal Data this includes details about your race, ethnicity, religion, political or philosophical beliefs, sexual orientation, health information, unless such information is provided by you to us with your express consent.

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How we use your information

• We may use the information we collect from you when you register an account with us, make a purchase, sign up for our Services, play our Game, respond to a survey or marketing communication, surf our website, or use certain other site features.  

The Company will use this information in accordance with applicable laws in the following ways: 

• To personalize user's experience and to allow us to deliver the type of content and product offerings.

• To improve our Services in order to better serve you. 

• To allow us to respond to your requests more efficiently. 

• To quickly process your transactions. 

• To send periodic emails regarding the Services.

• To identify your age for data protection purposes.

• provide, operate, improve and maintain the Game and the game experience; 

• personalize the Game, content, loyalty programs and related services to you;

• send technical notices, updates, security alerts, 

• for support and troubleshooting reasons;

• send support and administrative messages

• provide news and information about the Game and/or about our games and products;

• monitor the end users playing of the Game and activities in the Game; 

• facilitate sharing on social networks;

• provide adults with advertising in accordance with given consent and/or permissible laws;

• provide children reasonable contextual advertisements in the Game accordance with permissible laws; 

• identify, fix, and troubleshoot bugs and service errors, provide software updates etc;

• resolve disputes, investigate and help curb fraud and illegal behaviour, comply with the law, and to enforce our agreements and policies;

• survey end users opinions about the game and related matters through surveys or questionnaires;

• communication reasons related to the Game and related matters;

• to store, process and use User Created Content in accordance with our End User License Agreement,

• to comply with applicable laws or respond to legal process (like requests from law enforcement or other public or government authorities), to administer, process and examine claims of copyright infringements, or other violations of our End User License Agreement, 

• manage the Game and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties;

• present offers and/or information relating to the Games and other games that you might like;

• make recommendations to you; and

• personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

• We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected. Processing of this information is necessary for the purpose of performance of a contract to which you are a party, in order to support the operation of the Game, facilitate the delivery of requested Services, enable maintenance and update of the Game under Article 6(1)(b) of the GDPR, and purposes justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (“the balancing-of-interest rule”).

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Cookies

• Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved Services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

• We use cookies to:

Understand and save a user's preferences for future visits. Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your web browser’s settings. Each browser is a little different, so look at your browser's help or settings menu to learn the correct way to modify your cookies.

• If users disable cookies in their browser:

If you disable cookies off, some features will be disabled it will turn off some of the features that make your site experience more efficient and some of our services will not function properly.

 

Payment Information.

• In order to access the Game, certain premium game functions, levels, content and features etc. you may be required to pay certain fees. When purchasing such features and functions etc. you may be asked by the platform/service providers to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 18 or older to make purchases in the Game, however children over thirteen but under eighteen may access and play the game under the supervision of a legal guardian.

• Once end-users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. The payment platform/service providers will use the information provided to process the end-user’s order and to send order confirmations via email, as well as to make future purchases easier for the end-user. The Company does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate the Company’ business (e.g. processing orders and payments).

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Storage of Personal Data:

The information provided to the Company may be stored both within and outside United States of America, Canada or India. The Company shall:

• Not keep the Personal Data for longer than is necessary for the purposes of performing the Services unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules; 

• Store, process and use the Personal Data for the sole purpose of performing the Services; 

• Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access; 

• Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of  your Personal Data;

• Refrain from exporting or transferring  your Personal Data to any Third Country, and from collecting, using or Processing Personal Data within any Third Country, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented in accordance with the terms and conditions of this Privacy Policy (International Data Transfers). Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes.

 
Information Sharing Policy

• Generally, the Company will not disclose personally identifiable information that We collect through Your use of the Services to unaffiliated third parties. We reserve the right, however, to provide such information to our affiliates, third party contractors, employees, contractors, agents, and designees to the extent necessary to enable them to perform certain related services (such as improving Services related services and features, or maintenance services) on our behalf. 

• We also reserve the right to disclose such information to any third party if we believe that we are required to do so for any or all of the following reasons: (i) when required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Services; (iv)  and/or (v) to protect the rights, property, or safety of or our employees, the users of the Services, the public, or you.

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Changes of business ownership and control:

• the Company may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of the Company. Information provided will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Information for the purposes for which it was originally given to us.

• We may also disclose information to a prospective purchaser of our business or any part of the business.

• In the above instances, we will take steps to ensure that your privacy is protected.

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Data retention:

• Unless a longer retention period is required or permitted by law, we will only hold your Information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy.

• Even if we delete Your Information, it may persist on backup or archival media for legal, tax or regulatory purposes.

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Rights of the User:

• Right to access: Upon request you can obtain confirmation from Us as to whether your personal data is being processed by us. If this is the case, You can request us to give you access or copy of the your personal data we hold.

• Right to rectification: You have the right to request for correction and/ or update and/or completion of your inaccurate or incomplete personal data.

• Right to erasure: You can request the deletion of your personal data, subject to applicable legal requirements.

• Right to object: You can object to the processing of your personal data on grounds relating to your situation as per applicable local data protection law.

• To exercise these rights or for any privacy-related inquiries, please contact us at support@appymonkeys.com

 
Security: 

• The Company takes different measures for the security of your Personal Data. All information you provide to us is stored on our secure servers. Once we have received your information, we will use strict procedures and security features to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way. We will collect and store Personal Data on your device using application data caches and other technology. We have put in place procedures to deal with any suspected Personal Data breach and will promptly notify you, and regulators where applicable, of a breach where we are legally required to do so. We are not responsible for circumvention of any privacy settings or security measures contained on our Services. The Company declines all liability if the Personal Data is subject to unauthorized use or access in such cases.

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International Data Transfers

• We may transfer and share your information to third parties (including service providers operating on our behalf) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. Where your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur if we have entered into EU Commission approved Standard Contractual Clauses (SCC) with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals. 

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Disputes

• Our goal is to resolve disputes fairly and amicably. For all disputes against the Company, you hereby agree to first contact the Company and try to resolve the dispute informally by sending a written notice of the claim (“Notice”). The Notice must be sent via registered letter to the address listed in section 17 below or by email with confirmation of receipt. The notice must (a) include your name, your residential address and e-mail address and / or mobile phone number associated with your account registered with the Company and/or the platform/service provider; and (b) describe the type and reason for the claim.

Disclaimer:

• You are solely responsible for your interactions with other users of the Services. We reserve the right, but have no obligation, to monitor disputes between you and other users.

• Class action waiver: You agree that any and all claims must be made in your individual capacity and not as a plaintiff, or class member in any purported class or representative proceeding.

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Governing Law

• Any dispute or claim arising out of or in connection with this Privacy Policy or their subject matter (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

• The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, the Services.

• Notwithstanding anything to the contrary, the Company may apply to any court of competent jurisdiction for injunctive or other equitable relief or payment claims.

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CLAUSES SPECIFIC TO USERS WHO ARE DOMICILED IN EUROPE

• While we process your data, we strictly adhere to the General Data Protection Regulation (“GDPR”) currently in force throughout Europe and available to all citizens of the European Union. These are mainly:

• Article 6 (1) (b): We shall only process the data you provide us to the extent that you have provided the consent to process the data which shall be for the performance of our contract with you.

• Article 6 (1) (f): We may process the data to ensure that we achieve our legitimate interests, except to the extent where such interests are overridden by the fundamental rights and freedoms ensured under GDPR.

• Article 6 (1) (c): To the extent that such processing of data is necessary for compliance with the law.

• You can assert the following rights against us within the scope of the GDPR with regard to your personal data:

• Your right to information and access in accordance with Article 15 of the GDPR,

• Your right to rectification under Article 16 GDPR,

• Your right to erasure under Article 17 GDPR,

• Your right to restriction of processing under Article 18 GDPR and

• Your right to data portability under Article 20 GDPR.

• You also have a right to lodge a complaint the competent data protection supervisory authority (Article 77 GDPR in conjunction with § 19 BDSG).

• You can also withdraw a given declaration of consent to the processing of your personal data at any time. Please note that this declaration cannot work retrospectively.

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CLAUSES SPECIFIC TO USERS WHO ARE IN UNITED STATES OF AMERICA

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• CalOPPA (California Online Privacy Protection Act) 

CalOPPA is the first state law in the United States to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

 

• COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online. We do not specifically market to children under 13.

 

• CCPA (California Consumer Privacy Act)

The laws in force in the state of California, United States of America, requires the Company to state the various rights that the California Consumer Privacy Act (as amended by California Privacy Rights Act) provides to those people who are domiciled in California. These include the rights to access specific types of personal data, to know how we process personal data, to request deletion or correction of personal data, to opt out of certain data sharing, and not to be denied goods or services for exercising these rights.

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If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us through the details provided at section 17 below and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and the consumer’s place of residence before completing your request.

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We may need to verify Your identity and place of residence before completing Your CCPA rights request.

 

Fair Information Practices 

• The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify the users via email within 7 business days We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

 

CAN SPAM Act

• The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. If at any time you would like to unsubscribe from receiving future emails, you can email us and we will promptly remove you from ALL correspondence.

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Contacting Us/ Grievance Redressal

• If you find any discrepancies or have any grievances in relation to the collection, storage, use, disclosure and transfer of Your Personal Information under this Privacy Policy or other terms and conditions or policies of any of the Company's entity, please contact us at the following:

  • EMAIL: support@appymonkeys.com 

 

• You can also write to us at:

  • Lumion Technologies Limited

  • #1650, Arlington Business Park Theale, Reading Berkshire, RG7 4SA, United Kingdom

 

Definitions 

• "Applicable Data Protection Legislation" means any legislation in force from time to time which implements the European Union Directive 95/46/EC and Directive 2002/58/EC and the General Data Protection Regulation ("GDPR") 2016/679 of April 27th, 2016 and is applicable to this Agreement and all other applicable laws and regulations that may apply to the transfer of Personal Data. 

• "Personal Data" shall mean any information relating to a Data subject; an identifiable person is one who can be defined, directly or indirectly, notably by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Contact data and Service Data are Personal Data.

• "Contact Data" means any names, phone numbers, e-mail addresses and certain financial details held within commercial systems to conduct billing transactions or relationship management;

• "Controller", "Data Subject", "Personal Data", "Process/Processing" and "Processor", shall have the same meaning as in the European Union Directive 95/46/EC or the General Data Protection Regulation 2016/679 of April 27th, 2016.

• "Service Data" means any party's Personal Data (that is not Contact Data) held within the Parties' systems, applications or databases and that may be accessed, processed, used or stored as a consequence of performing the services under the End User Licensing Agreement. 

• "Third Country" means a country that is: (i) outside of the European Economic Area; and (ii) not the subject of a formal decision by the European Commission, made pursuant to Section 25(6) of the European Union Directive 95/46/EC or under Article 45 (1) of the General Data Protection Regulation 2016/679, stating that that country ensures an adequate level of protection for personal Data.