Privacy policy

Who makes Lumiroomi

Lumiroomi is made by Enmilu, LLC, 1111b South Governors Ave, STE 34169, Dover, DE 19904, United States of America, telephone +1 (315) 757-2822. If you have a question about this policy, write to support@enmilu.com.

What the game keeps on your device

The game saves your progress on the device so you can pick up where you left off: which rooms are finished, which stickers are placed and which lamps are lit; your sticker album, stamps, stars, level and sparks; your houses, the people, pets and families you made, the names you have given them, and your street; your settings (sound, music, haptics, the look, the reminder switch and the play-counts switch); and, so that bought sparks are paid out exactly once, the identifiers of your App Store or Google Play purchases. Pictures you take in Photo mode are kept in the game’s own folder on the device. Nothing else is written down. The only text the game ever asks for is a name: for your street, a house or a room of your own, or a person, pet or family you made. Those names stay in your save, so they go only where it goes, to your own iCloud or Play Games profile, and, while you play together, to the other devices playing; never to us.

Your world in iCloud

On iPhone and iPad, if your device is signed in to iCloud, the game keeps a copy of its save in your private iCloud database (Apple’s CloudKit, container iCloud.app.lumiroomi). This is so the same world appears on your other devices, and so that sparks a grown-up has paid for survive the game being deleted and installed again. Alongside the save it stores a revision number and the device’s name as iOS gives it to apps (usually just “iPhone” or “iPad”), so the game can say which device you last played on.

This copy lives in your own iCloud account under Apple’s iCloud terms. It is readable only by you: the developer has no access to anyone’s private database. If iCloud is off, or you switch off iCloud for Lumiroomi in your device’s Settings, the game simply plays on this device alone and says so under “Your world” in its Settings. Photos are not part of the iCloud save.

Your world in Google Play Games

On Android, if the phone has a Google Play Games profile, Play Games signs you in by itself when the game starts, with no button and no question, and the game keeps a copy of its save as two saved games in your Play Games profile: “world,” the world you are playing, and “kept,” the one put away by Start over or by choosing between two worlds, so that it can be brought back. This is so the same world appears on your other Android devices, and so that sparks a grown-up has paid for survive the game being deleted and installed again. Alongside the save it stores a revision number and the phone’s name as it calls itself in its settings (often its model), so the game can say which device you last played on.

These saved games live in your own Google storage under Google’s terms, together with your Play Games player ID, which is how Google knows they are yours. They are readable only by you: the developer has no access to them. If the phone has no Play Games profile, the game simply plays on this device alone and says so under “Your world” in its Settings. Your world on Android and your world in iCloud never meet. Photos are not part of the saved games. How to delete them is on the support page, under Deleting your data (Android).

Play counts

To balance and improve the game — to learn whether children save up for places or spend in the Shop, how often they stand in front of a room they cannot yet open, how far along the road they get and what they build — the game on iPhone and iPad sends the developer a small record of numbers once a week, when you leave the game. It goes to the developer’s own database at Apple (the public CloudKit database of the same container) and nowhere else. No third party is involved. The counts are on when the game is first opened, and a grown-up can switch them off in Settings › For grown-ups at any time; switching them back on asks for a grown-up’s year of birth first. Turning the counts off stops the sending at once. The Android version sends no play counts.

Our legal basis. In the European Union, the United Kingdom and wherever else the law asks for one, the basis is our legitimate interest in balancing and improving the game (GDPR Article 6(1)(f)): the counts are numbers only, carry no name, are never used for advertising or to single out a player, and a grown-up can object at any time by switching them off, which stops them at once. You can also object by writing to us. In the United States, the counts are collected under the Children’s Online Privacy Protection Act’s exception for supporting the internal operations of the game (16 CFR 312.5(c)(7)): they are used only to balance and improve it, and never to contact anyone, to build a profile of one player, for advertising, or for anything else.

The record contains exactly this, and nothing more:

• the week, the week you first played, and the game’s version;
• whether the device is an iPhone or an iPad;
• days played, and days a room was closed to you;
• rooms finished, places finished, places opened, and your level;
• sparks earned in all, sparks in the purse, and sparks spent on places, on extra rooms, in the Shop and on your houses;
• sparks bought, and how many of each jar was bought;
• whether this device has Lifetime access, and whether it was bought on this Apple Account or shared through the family;
• the furthest place reached on the road (as its number), and how many rooms are finished in each place;
• how many houses and rooms of your own there are, how many people and pets stand in them, how many people and pets were made in the maker, and how many outfits were saved;
• minutes spent in Play, how many times you played together, how many places Lumi built, and on how many days Lumi’s pockets were full.

None of it is a name, anything typed, a picture or where anything stands in a room: no name of a street, house, room, person, pet or family is ever in the play counts.

The record is filed under a random number the game makes up for this purpose the first time. It is not your name, email address, Apple Account, phone number, advertising identifier or device identifier, and we never join it to any of them. Starting over in the game files them under a new number; a switch a grown-up has set stays as it was.

Like every record in CloudKit, each one also carries an identifier Apple gives to whoever created it. It is the same for every world and every device signed in to one Apple Account, and starting over does not change it. We see that identifier, but we have no way to turn it into a name or an account; Apple, which hosts the records for us, can connect it to the Apple Account that sent them, as it can for anything in iCloud. So the counts carry no name, but they are not anonymous in the strict sense of data-protection law: they are pseudonymous, and we treat them as personal data.

Switching it off. The switch is in the game’s Settings, under “For grown-ups”: Share anonymous play counts. It is on until a grown-up switches it off. Off means nothing is sent, ever. The counts are used only for balancing and improving the game, and each week’s record is deleted 25 months after that week at the latest.

Photos

Photo mode makes a picture of your room or house and keeps it in the game’s scrapbook on your device. If you choose to share or save a picture, the system share sheet appears: only then, and only if you pick Photos, does the game ask for permission to add the picture to your photo library. On Android the share sheet hands the picture to the app you pick, and the game asks for no permission. The game never reads your photo library and never sends pictures anywhere.

Playing together

On iPhone and iPad, up to four devices near each other can play in one house; the Android version doesn’t have playing together. The house being played in goes from the device that invites to the others: its rooms and what is in them, with the names written for the street, the houses, and the people, pets and families in them. A visitor’s own people and pets come along too, with any names given to them. It goes straight between the devices, over the Wi-Fi they share or directly from one to the other, encrypted with a key made from the four pictures the players tap, and only while they play: a visitor’s device never writes the house down, and a visitor’s people and pets go home with them when the visit ends. Nothing of it goes to us, or anywhere else.

Players are shown to each other as little Lumis, never by name, and the device’s own name is not sent. There is no chat. iOS asks for Local Network access the first time; it can be switched off again under Settings › Privacy & Security › Local Network.

Purchases

On iPhone and iPad, jars of sparks and Lifetime access are sold through Apple’s In-App Purchase. Apple takes the payment, keeps the receipt and shows prices in your currency; the game receives only which jar was bought and a transaction identifier, which it keeps in your save so the sparks are paid out once. Whether Lifetime access is owned, by you or through your family, the game asks the App Store on the device each time; it is not kept in your save. Nothing in the game asks a child to buy: before any purchase the game asks a grown-up for their year of birth, then the App Store’s own confirmation follows, and Ask to Buy and Screen Time limits apply as they do for any app. The year of birth is checked on the device and forgotten; it is never stored or sent. For refunds, ask Apple at reportaproblem.apple.com.

On Android they are sold through Google Play Billing. Google takes the payment, keeps the receipt and shows prices in your currency; the game receives only which jar was bought and Google Play’s purchase token, which it keeps in your save so the sparks are paid out once. Whether Lifetime access is owned, the game asks Google Play on the device. Nothing in the game asks a child to buy: every purchase goes through Google Play’s own confirmation, and purchase approval in Family Link applies as it does for any app. For refunds, ask Google Play (Google Play’s refund help).

Reminders

If a grown-up switches on the daily gift reminder, the game asks for permission to show notifications and then schedules one local notification on the device for the next morning. There is no notification server: nothing about the reminder leaves the device. Switch it off in the game’s Settings, or in your device’s Settings under Notifications.

Children

Lumiroomi is in the App Store’s Kids Category, for ages 6 to 8. On iPhone and iPad, everything that buys or leaves the game (a purchase, the links in Settings, the share sheet and Apple’s request for a rating) first asks a grown-up for their year of birth, which is checked on the device and never stored or sent. Apart from the play counts above, which carry a random number and no name, we collect no personal information from anyone, children included. The game has no chat, no social features, no content made by other players, no advertising, and no links out apart from this privacy policy and the support page (which open in your browser) and the system share sheet for a photo. If you believe a child has somehow given us personal information, write to us and we will delete it.

No third parties

The game contains no third-party software: no analytics, no crash-reporting service, no advertising network, no social login. On iPhone and iPad, the only network connections it makes are to Apple, for iCloud and the App Store. On Android, the only code in it that isn’t ours is Google’s own Play services, for Google Play Games and Google Play Billing, and its only network connections are to Google, for those; signing in to Play Games is Google’s, to your own Play Games profile, and tells us nothing. Playing together connects only the devices playing, near each other. The game never contacts lumiroomi.app itself.

What we do not collect

Your name, email address, contacts, location, photos (other than the ones you choose to save), health data, browsing history, or any identifier of your device or for advertising; the only identifiers are the play counts’ random number and Apple’s own record identifier, above. On Android, your Play Games player ID goes to Google with your saved games, never to us. We do not track you across apps or websites, and we do not sell or share data.

Your rights

Under the GDPR and similar laws you may ask what personal data we hold about you and have it corrected or deleted, and object to processing based on our legitimate interest. The only personal data we hold are the play counts, and only from a game where they were on. Because they carry no name and we cannot connect their numbers to a person, we cannot tell from anything you could tell us which records are yours, so we cannot show or delete one family’s counts on request (GDPR Article 11). Switching the counts off stops them at once, and that is how to object. Your saves are on your device and in your own iCloud, where you can delete them yourself (delete the game, and its iCloud data under Settings › your name › iCloud › Manage Account Storage). On Android they are on your device and in your own Play Games profile; how to delete them is under Deleting your data (Android) on the support page. Write to support@enmilu.com with any question, and you may complain to your local data-protection authority.

Changes

If the game ever collects something new, this page will say so before it does, with a new date at the top.