OsyaPlay

Lumen Trail — Privacy Policy

Last updated: 27 October 2026

Who we are. Lumen Trail ("the game") is developed and published by Ilya Osipov, trading as OsyaPlay, Attemsgasse 44/1/7, 1220 Vienna, Austria. Contact: hello@osyaplay.com. We are the controller for the processing described here under the EU General Data Protection Regulation (GDPR).

The game itself. Lumen Trail is played offline. It does not ask you to create an account and we run no servers for it. Your progress is stored only on your device:

  • levels;
  • lumens;
  • items;
  • the hero's name you choose;
  • settings.

We do not receive any of it. If you uninstall the game, this data is deleted with it.

Advertising (Google AdMob). In the free version you can choose to watch a short video ("rewarded video") to continue after a fall. These videos are provided by Google AdMob (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).

  • What Google processes. To show and measure ads, Google may process:
    • your device's advertising identifier;
    • IP address;
    • device and app information;
    • information about interactions with ads.
  • Consent (EEA, UK, Switzerland). Before any ad is requested, the game shows Google's consent form. You can accept or refuse personalised ads. You can change your choice at any time under Settings → Privacy. If you refuse, Google may still show non-personalised ads, which use limited data, for example for frequency capping, fraud prevention and aggregated measurement.
  • iPhone and iPad. iOS asks whether the game may track you across other companies' apps and websites (App Tracking Transparency). If you decline, your advertising identifier is not shared.
  • No ads after buying. Buying "Play without ads" removes the videos. You continue after a fall without watching anything.
  • More information. Google's privacy policy: https://policies.google.com/privacy. How Google uses data from partner apps: https://policies.google.com/technologies/partner-sites.

In-app purchases. Purchases ("Play without ads", lumen packs) are processed entirely by Google Play or the Apple App Store under their own terms and privacy policies. We never receive your payment details. We receive only what the store confirms: which product was bought and a transaction reference. The game keeps these on your device so that a purchase is delivered once and can be restored.

Legal bases.

  • Consent (Art. 6(1)(a) GDPR) for personalised advertising and the related access to your device (§ 165 (3) TKG 2021).
  • Performance of a contract (Art. 6(1)(b)) for purchases.
  • Our legitimate interest (Art. 6(1)(f)) for non-personalised ads that keep the free version free.

Children. The game is not directed at children under 14 (or the higher age of digital consent in your country). We do not knowingly collect personal data from children.

Your rights. Under the GDPR you have the right to:

  • access, rectification and erasure of your data;
  • restriction of processing;
  • data portability;
  • object to processing;
  • withdraw consent at any time (Settings → Privacy).

Since we hold no personal data about you ourselves, requests about advertising data are best directed to Google. Write to us at hello@osyaplay.com for anything about the game. You may also lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde, Barichgasse 40–42, 1030 Vienna, www.dsb.gv.at) or with the authority in your country.

Changes. We will update this policy when the game changes, for example when online events are added, and change the date above.