PRIVACY POLICY

lu4.org — LU4 Platform
Last updated: 27 July 2026

Data Controller: GAMEVIBE LTD, a legal entity incorporated under the law of England and Wales, company registration number (Companies House number) 17353570, registered office address: Suite 7007, 128 Aldersgate Street, Barbican, London, England, EC1A 4AE, United Kingdom ("we", the "Operator"). The Operator is also the Merchant of Record for Paid Digital Services, as set out in the Platform Terms of Use.

This Privacy Policy explains what information we collect when you use the LU4 Platform, why we do so, with whom we may share that information, and what rights you have in respect of it.

1. Terms Used in This Policy

The terms "Platform", "Operator", "Account", "Virtual Currency" and other capitalised terms not separately defined below have the meaning given to them in the Platform Terms of Use. This Policy additionally uses the following terms:

"Personal Data"
any information relating to an identified or identifiable natural person.
"Processing"
any action performed on Personal Data: collection, recording, storage, use, transfer, deletion, and the like.
"Controller"
the person who determines the purposes and means of the Processing of Personal Data; in this case, the Operator.
"Processor"
a person who processes Personal Data on behalf of the Controller.
"Data Subject"
the natural person whose personal data is processed (i.e., you, as a User).

2. General Provisions

2.1. Scope

This Policy describes what Personal Data we collect in connection with your use of the Platform, for what purposes, on what legal bases, to whom we disclose it, and for how long we retain it.

2.2. Legal Basis for Processing in the United Kingdom and Abroad

As the Operator is established in England and Wales (United Kingdom), the processing of Personal Data is primarily governed by the UK GDPR (Regulation (EU) 2016/679 as it applies in the United Kingdom) and the Data Protection Act 2018. At the same time, given the Platform's international audience, we aim to comply with GDPR (Regulation (EU) 2016/679) standards for users in the European Union, as well as the relevant local law for users in other countries.

2.3. Platform Audience

The Platform serves users from Europe, Asia, the United States, and Latin America.

3. What Personal Data We Process

3.1. Account Data

When you register, we collect your email address and password. Your password is stored exclusively in hashed form.

3.2. Technical and Operational Data

While you use the Platform, we automatically receive: your IP address, the type and version of your operating system and game client, session identifiers, and language settings.

3.3. Gameplay Data

We store Character progress and attributes, Virtual Currency balance, in-game transaction history, and the content of support enquiries.

3.4. Payment Data

Data directly necessary to process a payment is entered by you on the page of the Merchant of Record or the payment processor and does not reach our servers in full.

3.5. Anti-Fraud System Data

As of the date this Policy was last updated, the Platform does not use separate anti-cheat software beyond built-in server-side checks of game logic. If such software is introduced in the future, this Policy will be updated to describe exactly what data it collects.

4. Purposes and Legal Bases for Processing

4.1. Providing the Service

We process Account data and gameplay data on the basis that it is necessary for the performance of our contract with you (the Terms of Use).

4.2. Security and Fraud Prevention

We process technical data on the basis of the legitimate interest of the Operator and other Users in protecting the integrity of the Platform.

4.3. Communications and Newsletters

If you have separately subscribed to receive newsletters, we send messages on the basis of your freely given consent, which you may withdraw at any time.

4.4. Legal Compliance

We process transaction data for accounting and tax record-keeping purposes on the basis of a legal obligation.

5. Who We Share Personal Data With

5.1. Categories of Recipients

We disclose Personal Data to the following categories of recipients: hosting and infrastructure provider; web analytics provider; video content services embedded on Platform pages; CAPTCHA provider; payment processor(s) acting on the Operator's instructions (the Operator also acting as Merchant of Record); user support service; and, where necessary, anti-fraud service providers and competent public authorities.

6. International Data Transfers

6.1. General Approach

Where Personal Data is transferred outside the country in which it was collected (including, for users in the European Union, outside the European Economic Area), we ensure that an appropriate transfer mechanism is used — in particular, the International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission's Standard Contractual Clauses, or another mechanism that complies with the applicable data protection law of the recipient.

7. Data Retention Periods

7.1. General Rule

We retain Personal Data only for as long as necessary for the purposes described in Section 4, or for as long as required by applicable law.

7.2. Specific Periods

Financial transaction data is retained for the period required by United Kingdom tax and accounting law.

8. Your Rights Regarding Personal Data

8.1. General List of Rights

Depending on applicable law, you may have the right to access your Personal Data, to have it corrected or erased, to restrict its processing, to object to its processing, to data portability, and to withdraw consent.

8.2. Supervisory Authority in the United Kingdom

The authority responsible for supervising compliance with data protection law in the United Kingdom is the Information Commissioner's Office (ICO).

8.3. Rights of Users in the European Union

If you are a resident of the European Union, you also have the right to lodge a complaint with the data protection authority of your country of residence.

8.4. Rights of US Residents

If you are a resident of a US state whose law grants additional rights regarding personal data, we will enable you to exercise those rights on request. We do not sell Users' Personal Data to third parties for monetary consideration, and we do not "share" it, within the meaning of applicable US state law (including the CPRA), for the purposes of cross-context behavioural advertising. If this changes, we will provide a separate opt-out mechanism ("Do Not Sell/Share My Personal Information") on the Platform.

8.5. How to Submit a Request

To exercise any of the rights listed above, please send a request to the contact email address given in Section 11.

9. Data Breach Notification

9.1. Procedure in the Event of a Breach

In the event of a breach of Personal Data that may pose a high risk to the rights and freedoms of Users, we will notify the affected Users and, where required, the competent authority, within the time limits set by applicable law.

10. Age and Consent of Minors

10.1. Minimum Age and Parental Controls

The general minimum age for creating an Account is 16, with a lower age permitted where confirmed parental consent has been given, in places where this is expressly allowed by applicable law. Regardless of the foregoing, persons under 13 residing in the United States of America may not register an Account and may not provide us with their Personal Data under any circumstances, in accordance with the requirements of the Children's Online Privacy Protection Act (COPPA).

11. Contact

11.1. Contacting Us

Contact email address for enquiries regarding personal data: Direct@lu4.org.