Privacy Policy

1. Introduction

StorySpark INTERACTIVE ENTERTAINMENT LIMITED ("we," "our," or "the Company") respects and protects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect the personal data you provide through our application (the "App"). Please read this policy carefully to understand our data processing practices.

This policy complies with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Hong Kong Personal Data (Privacy) Ordinance, and other applicable privacy laws and regulations.

2. Information We Collect

We may collect the following types of personal data:

Identity data: name, email address, phone number, date of birth
Account data: username, password, account settings
Technical data: IP address, device information, browser type, operating system
Usage data: app usage, viewing history, interaction records
Location data: approximate location based on IP address
Advertising identifiers: device advertising ID (such as Google Advertising ID or Apple IDFA) used for ad delivery, attribution, and frequency capping

3. How We Collect Data

We collect your data through the following methods:

Direct interactions: when you register for an account, fill out forms, or contact us
Automated technologies: through cookies, server logs, and similar technologies when you use our App
Third parties: we may receive data from business partners, social media platforms, or public sources

4. How We Use Your Data

We use your personal data for the following purposes:

To provide and manage our services
To personalize your experience and content recommendations
To improve our App and services
To communicate with you and respond to your inquiries
To send relevant information (if you have opted in)
To prevent fraud and ensure security
To comply with legal obligations
To display personalized and non-personalized advertisements through third-party ad networks
To measure ad performance, attribute ad installs, and analyze ad revenue

Session Replay Diagnostics

If you explicitly choose "Join" in the App, we may use Session Replay for eligible sessions to diagnose technical issues and improve Lumi Drama. Eligibility may be based on a paid subscription, a temporary technical anomaly, or a remotely managed diagnostic group. Consent is always required in addition to those criteria.

Session Replay may collect in-App screens, taps, scrolling, navigation, and technical events. Text entered in shared form inputs is masked, and we do not intentionally record passwords, verification codes, email addresses entered into forms, payment credentials, receipts, tokens, request or response bodies, console output, or replay network telemetry. Ordinary page text and images may remain visible in a recording.

Replay data is processed through our self-hosted PostHog service in the United States. We retain recordings according to operational need, diagnostic relevance, account status, and applicable legal requirements, rather than for a fixed guaranteed period.

You can withdraw consent at any time in the App by going to Settings > Privacy & Data > Lumi Drama Experience Program and turning the switch off. This stops future recording on that App installation; it does not automatically delete recordings already collected. To request deletion or exercise another privacy right, contact contact@lumidrama.cc.

5. Data Sharing and Disclosure

We may share your personal data with the following parties:

Service providers: third parties that help us operate the App or provide customer support
Business partners: companies we collaborate with to provide specific services
Legal requirements: when required by law or to protect our rights
Advertising partners: we work with third-party advertising networks and monetization platforms, including but not limited to AppLovin, Google AdMob, Meta Audience Network, Mintegral, Pangle, Unity Ads, Liftoff, and Bigo Ads. These partners may collect device identifiers, coarse location, and usage data to serve and measure advertising
Corporate transfers: if we are involved in a merger, acquisition, or sale of assets

We do not sell your personal data. Any third-party service providers must adhere to confidentiality obligations and may only process your data for specified purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data from accidental loss, unauthorized access, use, alteration, or disclosure. These measures include:

Encryption of data in transit and at rest
Regular security assessments and testing
Access controls and authentication
Employee training and confidentiality agreements

While we strive to protect your personal data, please note that no method of internet transmission or electronic storage is 100% secure.

7. Your Privacy Rights

Under applicable privacy laws, you may have the following rights:

Right of access: to obtain a copy of your personal data that we hold
Right to rectification: to request correction of inaccurate or incomplete data
Right to erasure: to request deletion of your personal data in certain circumstances
Right to restrict processing: to limit our processing of your data in certain circumstances
Right to data portability: to receive your data in a structured, commonly used, and machine-readable format
Right to object: to object to our processing of your personal data
Right to withdraw consent: to withdraw any consent you have previously given

To exercise these rights, please contact us using the contact information provided below. We will respond to your request within 30 days.

8. Cookie Policy

We use cookies and similar technologies to improve user experience, analyze usage patterns, and provide personalized content. The types of cookies we use include:

Essential cookies: necessary for the basic functionality of the App
Analytics cookies: help us understand how users interact with our App
Functional cookies: remember your preferences

You can control and delete cookies through your browser settings. However, please note that disabling certain cookies may affect the functionality of the App.

9. Advertising and Tracking

We use third-party advertising SDKs to display ads within the App. These SDKs may use device identifiers, cookies, and similar technologies to provide relevant ads and measure their performance.

On iOS, we use Apple's SKAdNetwork for ad attribution. SKAdNetwork does not access device identifiers and provides aggregated attribution data.

You can opt out of personalized advertising:

On Android: go to your device Settings > Google > Ads > Opt out of Ads Personalization
On iOS: go to your device Settings > Privacy & Security > Tracking, or reset your Advertising Identifier

By installing and using the App, you acknowledge that the third-party advertising SDKs listed in Section 5 may collect and process the data described therein for the purpose of serving ads. If you do not consent to this data processing, please uninstall the App.

California Consumer Privacy Act (CCPA) – Do Not Sell My Personal Information

Under the CCPA, California residents have the right to opt out of the "sale" of their personal information. The sharing of certain data (such as device advertising identifiers) with our advertising partners for targeted advertising purposes may be considered a "sale" under the CCPA. To exercise your right to opt out, please:

Reset your device advertising identifier (Android: Settings > Google > Ads > Reset advertising ID; iOS: Settings > Privacy & Security > Apple Advertising > Reset Advertising Identifier)
Opt out of ads personalization (Android: Settings > Google > Ads > Opt out of Ads Personalization; iOS: Settings > Privacy & Security > Tracking)
Contact us at contact@lumidrama.cc with the subject "CCPA Opt-Out"

10. Children's Privacy

Our App is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If you discover that we may have collected data from a child, please contact us immediately, and we will take steps to delete such information.

11. Contact Us

If you have any questions about this Privacy Policy or need to exercise your privacy rights, please contact us:

Email: contact@lumidrama.cc

Last updated: August 27, 2026