Privacy Policy

GDPR Notice

At LuluLab, we’re committed to information security, privacy and transparency. As such, we’ve published a detailed GDPR FAQ, which outlines the measures we’ve put in place to ensure compliance.

1. Privacy

1.1 This Privacy Policy explains how information is collected and utilized by Lulu Lab and its subsidiaries and affiliated companies (“LuluLab”, “our”, “us” or “we”).

1.2 This Privacy Policy applies to the products provided by Lulu Lab, including without limitation, www.lululab.org (the “Site”), 'Mi body nar mi rayt' on Red Barnet Danmark Google Play store and all game developed and analytics services and resources provided by Lulu Lab, including but not limited to, various software applications, site profile services, player reports and game usage analytics, including users who access and use these services through a mobile device (“Services”).

1.3 For the purposes of European data protection laws we are the data controller. If You have any concerns about privacy, please send an email to our Data Protection Officer at data@lululab.org.

1.4 This Privacy Policy applies to information that You and Your Customers provide to us, or that we collect and/or generate through the Services.

1.5 This Privacy Policy may be updated from time to time. We will notify You of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this Privacy Policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Lulu Lab Terms of Service, which is available on https://www.lululab.org/terms.

2. Information collection and use

2.1 Our primary goals in collecting information are to provide, administer and improve our Services and software.

2.2 Personal Information

We will collect Personal Data when You interact with our services such as when You:

• play any of our games,
• submit a request for technical support or
• submit a request for information about the Services,

2.3 The provision of Personal Data by You is necessary for the performance of the Agreement and where in our legitimate interests to provide and improve the Services, complete Your transactions, enforce licensing terms, and administer Your inquiries.

2.4 When you play any of our games, we will collect certain Personal Data including all the answers provided during a gameplay session. This provides us with anonymous usage statistics of the game. 

2.5 When You play the game by any device connected with the internet, we may collect some or all of the following Customer Data:

Unique device identifier generated from the device including but not limited to 1) ID for Advertisers (iOS); 2) Google Advertising ID (Google)

• Platform (automatic),
• Device (automatic),
• OS major (automatic),
• OS minor (automatic),
• IP address (automatic) – used to infer country information,
• Boot-up timestamp: it is the timestamp of when a user boots up a game.

2.6 We may combine Personal Data that we collect from You with information we obtain about You from third parties (e.g., updated contact information and additional demographic information). We may also aggregate Your Personal Data with information collected from other players to customize Your user experience, to improve the quality and value of the Services, to inform You about our products and services that may be of interest to You, and to analyze and understand how our Services are used.

3. Information sharing or disclosure

3.1 In the event that we contract with a third party to provide some part of the service that You have requested or to assist us in analyzing our service or information collected about You and/or Your Customers, Lulu Lab may provide Your information and/or Your Customers’ information to such third party, or such third party may collect information from You or the Customers on our behalf. We may share Your information and Customer information with third parties with whom we have a strategic relationship, such as our affiliates (that provide complementary services such as mediation or monetization services, revenue reporting, attribution services), data providers game developers and advertisers. The information shared with these third parties may be used for industry analysis, tracking game conversions or demographic profiling. When permitted by applicable law, we may also provide Your information and Customer information to our affiliates, business partners, advertisers or other trusted entities for the purpose of providing You with information on goods and services we believe will be of interest to You.

3.2 We will disclose any information about You or Your Customers to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Lulu Lab or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

3.3 In addition, we may disclose information about You or Your Customers to third parties in connection with a corporate reorganization, merger or amalgamation, or the sale of all or substantially all of our assets.

3.4 Finally, we may aggregate and/or anonymize information collected by the Services or via other means so that the information does not identify You or Your Customers. Our use and disclosure of aggregated, anonymized, and otherwise non-identifiable information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose, including with game developers, advertisers, publishers, business partners, sponsors, and other third parties.

4. Changing or deleting Your information

4.1 Under Data Protection Laws you have certain data subject rights including the right to (i) request access to and rectification or erasure of Your Personal Data; (ii) obtain restriction of processing or to object to processing of Your Personal Data; and (iii) ask for a copy of Your Personal Data to be provided to You, or a third party, in a digital format. If you wish to exercise one of the above-mentioned rights, please contact us at data@lululab.org. If Your Personal Data are erased or transferred to a third party, then Your Account may be deactivated. You also have the right to lodge a complaint about the processing of Your Personal Data with Your local data protection authority. You are able to request any changing or deleting your information if in case You register with any of our Services, otherwise all the collected data is anonymous. 

5. Confidentiality and security

While we cannot guarantee that loss, misuse or alteration to Your data will not occur; we implement appropriate technical and organizational measures to prevent such occurrences. We do not warrant or represent that Your account or any of Your information or Customer Data will be protected against, loss, misuse, or alteration by third parties. We will retain Your information and Customer Data for no longer than is necessary and for the duration of the agreement with You and for up to 36 months following expiry or termination of this agreement.

6. International transfer

The submission of Personal Data by You or Your Customer via the Service may involve the transfer of Personal Data to countries located outside the EEA which do not provide a similar or adequate level of protection to that provided by countries in the EEA. We will take all steps reasonably necessary to ensure that any Personal Data are treated securely and in accordance with this Privacy Policy.

7. Children

The Services are intended for general audiences and Lulu Lab does not knowingly collect any Personal Data from anyone including children.

If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at data@lululab.org. We will delete such information from our files within a reasonable period of time if there is any.

Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the apps developed by developers. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.