Privacy Policy

2. Legal Basis for Processing (GDPR)

Under the European Union General Data Protection Regulation (GDPR, Art. 6), we process your personal data under the following legal bases:

• Consent (Art. 6(1)(a)): We use your email address to send the newsletter only after you choose to subscribe. You may withdraw consent at any time.
• Legitimate Interests or Steps at Your Request (Art. 6(1)(f) or Art. 6(1)(b)): We process messages you send us so that we can answer and handle your request.
• Legitimate Interests (Art. 6(1)(f)): Our hosting providers process limited technical data to deliver the website, maintain its security, prevent abuse, and diagnose failures. These interests are balanced against visitors' rights and expectations.
• Legal Obligation (Art. 7(1) and Art. 5(2)): We must be able to demonstrate that consent was given. The record described above exists for that purpose and for no other — it is not used to identify, profile or locate you.

3. Newsletter & Email Communications

The newsletter is opt-in. We do not purchase mailing lists. You can withdraw your consent at any time through the unsubscribe link included in each newsletter or by emailing us. After you unsubscribe, your address is removed from the active mailing list. We may retain a minimal record where necessary to respect your opt-out, demonstrate compliance, or resolve legal claims; residual copies may remain in backups until their normal expiry.

4. Service Providers & External Platforms

We use technical providers for cloud hosting, content delivery, website security, and email delivery or mailbox services. They process personal data only as needed to provide those services and under their applicable contractual and data-protection terms.

The website links to external platforms including Discord, X, Reddit, YouTube, TikTok, Instagram, and Facebook. These are plain links and do not load social-media tracking code on this website. If you follow a link, that platform processes information under its own privacy policy and acts independently from us.

5. Cookies & Tracking Technologies

At the date of this policy, this website does not set cookies or use local storage, analytics pixels, advertising trackers, or profiling scripts. If we introduce a non-essential technology, we will update this policy and request consent before using it where the law requires.

6. Data Sharing & International Transfers

We do not sell personal data or share it for behavioral advertising. Data may be disclosed to the service providers described above, when required by law, or when necessary to establish, exercise, or defend legal claims. Some providers may process data outside the European Economic Area. Where required, those transfers must rely on an adequacy decision or appropriate safeguards such as the European Commission's standard contractual clauses. You may contact us for information about the safeguard relevant to your data.

7. Data Retention

Newsletter addresses are kept while the subscription is active, followed only by any limited record described above. Direct messages are kept for the time needed to answer and, where necessary, for a reasonable period to document the exchange or handle legal claims. Technical data handled by infrastructure providers is kept according to the shortest period needed for delivery, security, abuse prevention, and troubleshooting. We periodically review whether retained data is still needed.

The record of consent — the addresses and times of subscription and confirmation — is kept while the subscription is active and for a limited period after it ends, so that the subscription can be shown to have been legitimate. It is deleted with the rest of your data if you ask for erasure.

8. Your GDPR Rights

Where the GDPR applies and subject to its conditions and exceptions, you may exercise the following rights:

• Right of Access: You may request confirmation and a copy of the personal data we hold about you.
• Right to Rectification: You may request that we correct inaccurate or incomplete information.
• Right to Erasure: You may request deletion of personal data when the legal conditions for erasure are met.
• Right to Restriction: You may request that eligible processing be restricted.
• Right to Object: You may object to processing based on legitimate interests. We will stop unless we demonstrate compelling legitimate grounds or the processing is needed for legal claims.
• Right to Data Portability: Where processing is based on consent or contract and is automated, you may request eligible data in a structured, commonly used, machine-readable format.
• Withdrawal of Consent: You may withdraw newsletter consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Providing data is voluntary. If you do not provide an email address, you cannot receive the newsletter; if you do not provide enough information in a message, we may be unable to answer it.

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

To make a request, email contact@lunigame.com. We may ask for information reasonably necessary to verify your identity. We normally respond within one month, subject to any extension or limitation permitted by law.

You also have the right to lodge a complaint with the Romanian supervisory authority ANSPDCP.

9. Children's Privacy

This website is intended for a general audience and is not designed to collect personal data from children. People under 16 should not subscribe to the newsletter without authorization from a parent or guardian. If you believe that a child provided personal data without the required authorization, contact us so that we can assess and, where appropriate, delete it.

10. Data Controller & Studio Identity

The controller for the processing described in this policy is Andrei Alexandru, an independent game developer established in Romania (European Union), operating lunigame.com. For privacy questions or requests, contact:

11. Changes & Contact

We may update this policy when our processing activities or legal obligations change. Material changes will apply from the updated date shown above and will be communicated through an appropriate channel when required by law. Questions about this policy may be sent to: