Lumaspin

Ring puzzle with 120 levels

Privacy policy

Last updated: 5 September 2026

Lumaspin runs entirely on your device. There is no account, no server of ours, no advertising and no trackers. The app does not request the internet permission. Game progress, stars, best scores, stats, badges, daily tasks, coins, looks and settings are stored locally only — and, if you have Android backup switched on, also in your Google account backup, which Google manages for you and which we cannot access. The only point where data leaves the device is a purchase through Google Play — and Google’s Play Store app handles that.

1. Data controller

We have not appointed a data protection officer or an EU representative because we do not reach the relevant thresholds. Please address all requests to the contact above.

2. What data we process

What we explicitly do not collect

• No account, no registration, no e-mail address
• No location, no contacts, no access to photos, camera or microphone
• No advertising, no tracking, no analytics services, no leaderboards, no notifications
• No server of ours and no internet permission: we receive no data from the app

3. Permissions on your device

The app requests only the following permissions. Each of them can be revoked at any time in your device settings; the app remains usable afterwards, with reduced functionality.

• Google Play billing — Only for purchases through Google Play; the purchase runs through the Play Store app. The app requests no other system permissions.

4. Legal bases

We process personal data under the Swiss Federal Act on Data Protection (revFADP). Where the GDPR applies, we rely on:

• Performance of a contract (Art. 6(1)(b) GDPR) — everything needed for the app to deliver the function you requested.
• Legitimate interests (Art. 6(1)(f) GDPR) — secure and stable operation, abuse prevention, troubleshooting.
• Consent (Art. 6(1)(a) GDPR) — this app requests no special system permissions, so no separate consent is required.
• Legal obligation (Art. 6(1)(c) GDPR) — in particular commercial and tax retention duties for payments.

5. Recipients and third parties

We do not sell data and do not disclose it for advertising purposes. Data is disclosed only to the following parties, and only where required for operation:

Authorities and courts receive data only where we are legally obliged to provide it.

Transfers abroad

Some of the recipients listed above process data outside Switzerland and the EEA, in particular in the United States. We base such transfers on the European Commission’s Standard Contractual Clauses with the Swiss adaptations recognised by the FDPIC and, where applicable, on the EU-US Data Privacy Framework. We will provide information on the safeguards in place on request.

6. Retention and deletion

All game data lives on your device and disappears when you delete the app; any Android backup in your Google account is managed in your Google settings. We retain nothing because nothing reaches us. Purchase receipts are held by Google in your Google account.

Step-by-step instructions are available at Delete data.

7. Children and young people

This app is not directed at children. We do not knowingly collect personal data from children under 16. If we learn that such data has been submitted without parental consent, we delete it without delay.

8. Data security

Wherever the app transmits data at all, connections are encrypted via HTTPS/TLS. On the server side we use access restrictions, tenant separation and regular backups. Nobody can, however, guarantee absolute security for data transmission over the internet.

9. Your rights

• Access to the personal data we process
• Rectification of inaccurate data
• Erasure or destruction of your data
• Restriction of and objection to processing
• Receiving or porting your data in a common format
• Withdrawal of consent with effect for the future

An informal message to info@babala.ch or a call to 076 792 63 50. We normally respond within 30 days. To verify your identity we may request suitable proof. You may also lodge a complaint with a supervisory authority (Switzerland: FDPIC; EU: your competent authority).

10. Changes to this policy

We may adapt this policy when the app or the legal framework changes. The version published on this page, with the date shown above, is the applicable one. We announce material changes inside the app.