Effective Date: September 15, 2026
Welcome to Luckimo (hereinafter referred to as "Luckimo", "Platform", or "Services"), operated and controlled by GATHERJOY PTE. LTD. (hereafter referred to as "we", "us", or "our").
This Privacy Policy (hereafter referred to as "Policy") describes how we collect, use, store, share, protect, and process your personal information across our mobile applications, websites, games, and related services that link to this Policy.
Please read this Policy carefully to understand our privacy practices. By downloading, accessing, or using Luckimo, you acknowledge that you have read and understood how we process your personal data as described herein. Where required by applicable data protection laws, we will obtain your explicit, affirmative consent prior to processing specific categories of personal data or accessing device permissions. If you do not agree with this Policy, please do not access or use our Services.
If you have any questions, comments, or requests regarding this Policy or our privacy practices, please contact us at:
We process personal data that you voluntarily provide, data collected automatically during your usage, and data received from authorized third parties, strictly in accordance with principles of necessity, lawfulness, and proportionality.
1.1 Information You Voluntarily Provide
1.2 Information Obtained from Third Parties
When logging in via authorized third-party platforms (e.g., Apple ID, Google), we receive your third-party user ID, basic profile name, and avatar URL to generate a unique Luckimo Account ID. Processing by these third parties remains subject to their respective privacy policies.
1.3 Information Automatically Collected During Usage
To maintain service stability, platform security, and feature performance, we automatically collect specific technical parameters:
We process your personal information strictly in accordance with applicable data protection laws. Depending on how you interact with our Platform and Services, we rely on specific legal bases—including the performance of a contract, compliance with legal obligations, your explicit consent, and our legitimate business interests—to process your data for the following purposes:
| Processing Purpose | Legal Basis | Description |
| Core Service Provision | Performance of a Contract | Account authentication, matchmaking, voice channels, social networking, and text communication. |
| Audio Routing & Gameplay Feedback | Legitimate Interests / Contract | Optimizing audio routing (e.g., earpiece, speaker, Bluetooth), managing stream quality, and delivering haptic vibration interactions. |
| Anti-Cheat, Security & Fraud Prevention | Legitimate Interests / Legal Obligation | Safeguarding accounts against unauthorized takeovers, detecting emulators, memory injections, or illegal plug-ins to ensure game fairness. |
| Financial Transactions & Record Keeping | Performance of a Contract / Legal Obligation | Processing top-ups, delivering virtual inventory, handling refunds, and fulfilling statutory accounting, tax, and audit rules. |
| Customer Support & System Alerts | Contract / Legitimate Interests | Sending critical service notifications, resolving customer service tickets, and executing security alerts. |
| Analytics & Marketing Attribution | Consent / Legitimate Interests | Measuring marketing campaign effectiveness, crash analysis, and serving personalized content. iOS cross-app tracking relies strictly on your affirmative opt-in via the App Tracking Transparency (ATT) framework. |
| Legal & Regulatory Compliance | Legal Obligation | Complying with administrative warrants, court orders, or enforceable law enforcement requests. |
We DO NOT sell, rent, or trade your personal information to third parties for monetary consideration. We share your data only under the following limited circumstances:
3.1 Sharing Your Personal Information with Service Provider
We entrust other companies, agents, or contractors ("Service Providers") to perform services on our behalf or to assist us in providing services to you. For example, we engage (i) Cloud and Infrastructure Service Providers to provide cloud hosting, data storage, network acceleration, and IT infrastructure management, (ii) Content Moderation Service Providers to assist with text, audio, image, and video content moderation, anti-fraud prevention, cybersecurity monitoring, and risk management, (iii) Marketing, Advertising, and Analytics Service Providers to deliver marketing campaigns, user acquisition advertising, and push notifications, as well as to customize, personalize, and optimize our services, and (iv) Data Analysis and Optimization Service Providers to analyze and enhance information, including users' interactions with our service, system performance, and error or crash logging.
We grant our Service Providers access to your personal information only to the extent reasonably necessary for them to perform the authorized tasks on our behalf. All Service Providers are bound by strict contractual confidentiality obligations. They are required to implement adequate technical and organizational security measures, and process your personal data strictly in accordance with our official written instructions and applicable privacy laws and regulations.
3.2 Share Your Personal Information with Our Affiliates
We may share your personal information with our parent company, subsidiaries, joint ventures, or other companies under common control ("Affiliates") to facilitate global operational workflows, streamline account management, provide unified customer support, and conduct joint analytics or service improvements.
Our Affiliates are bound by this Privacy Policy and internal corporate privacy policies. They are required to handle your personal information with the same level of data protection and security as described herein.
3.3 Share Your Personal Information with with Other Third Parties
We may share your personal information with independent third parties in the following legally permitted circumstances:
4.1 Data Storage and Cross-Border Transfers
The personal information we collect for platform services is primarily hosted and processed on secure servers located in Singapore.Because we operate globally, our operational, technical, customer support, and development teams around the world may access your personal information from outside your jurisdiction of residence to provide, maintain, and support our services.
When transferring your personal information across international borders, we ensure compliance with applicable data protection laws in your jurisdiction. Where required by law, we will explicitly inform you of the transfer details (such as the purpose, category of data, and identity/location of the recipient) and obtain your prior consent. We implement appropriate cross-border data transfer mechanisms—such as the European Commission's Standard Contractual Clauses (SCCs), adequacy decisions, or equivalent contractual protections—to guarantee that data recipients provide a level of data protection equivalent to that required in your home country. You may request details regarding our international transfer safeguards by contacting us using the information provided in Section 9 ("How to Contact Us").
4.2 Data Retention and Anonymization
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as set forth in this Privacy Policy, or as required by applicable laws, regulations, or statutory retention periods (such as tax, accounting, or litigation hold requirements).
Upon the expiration of the retention period or once the purpose of collection is achieved, we will promptly and securely delete or anonymize your personal information. "Anonymization" refers to the process of irreversibly de-identifying data such that the individual data subject cannot be re-identified, directly or indirectly, through any technical or analytical means. Anonymized data is no longer classified as personal information.
We may retain certain personal information even after you delete your account, request erasure, or after we cease providing services to you, if retention is reasonably necessary to:
4.3 Technical and Organizational Security Measures
We implement robust administrative, technical, and physical security safeguards—aligned with recognized industry standards—to protect your personal information against unauthorized access, disclosure, alteration, destruction, or loss.
Our technical safeguards include data classification frameworks, strong encryption for data at rest and in transit (such as TLS/SSL protocols), de-identification, multi-factor authentication, and regular data backups. For organizational controls, access to your personal information is strictly restricted to authorized personnel on a "need-to-know" basis. Additionally, our employees, contractors, and agents are bound by strict confidentiality obligations and undergo regular privacy and security training.
While we take all commercially reasonable precautions, please note that no method of internet transmission or electronic storage is 100% secure. To help protect your personal information, we strongly recommend that you safeguard your account password and login credentials and refrain from sharing them with anyone.
【NOTE: The availability, scope, and implementation of the data subject rights set forth below are strictly subject to and governed by the applicable data protection laws and regulations of your country or region of residence. If there is any conflict between the terms of this Privacy Policy and the statutory privacy rights granted by your local laws, your local laws shall prevail.】
Subject to applicable local data protection laws and statutory exceptions in your jurisdiction, you may exercise the following rights regarding the personal information we hold about you:
5.1 Right of Access/Know
You have the right to request access to your personal information we hold about you, how we use it, and who we share it with. We may not fulfill access requests if doing so would adversely affect the rights and freedoms of others (e.g., revealing another individual's trade secrets or confidential data) or conflict with our legal retention obligations.
5.2 Right to Correction
You have the right to correct that information if it is inaccurate or incomplete.You can access and correct your personal information by logging into your account at any time.If you want us to correct your personal information that you are unable to correct using your account, please contact us as described in Section 9 ("How to Contact Us").
5.3 Right to Data Portability
You have the right to request access to the personal information we hold about you, how we process it, and who we share it with. Where required by law, you may also request a copy of your personal information in a structured, commonly used, and machine-readable format.
5.4 Right to Erasure (Deletion)
You have the right to request the deletion of your account at any time. This allows you to exercise control over your personal information and supports your right to be forgotten.We provide the following methods for you to exercise this right:
We may retain the personal information if there are valid legal grounds for us to do so (e.g., for the defence of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.If you have requested that we erase your personal information that we have made public and there are valid legal grounds for erasure, we will use reasonable steps to inform any third party to whom we have disclosed the relevant personal information so that they can erase it too.
Please be aware that the deletion of your account is a permanent action and cannot be reversed. We will not be able to restore your account or retrieve any data associated with it once deleted. After your account is deleted, your personal information will be removed from Luckimo, except the personal information that must be retained by us as clearly stipulated by laws (such as the information related to your transactions in Luckimo, and the data that should be retained as clearly stipulated by the government or laws).
5.5 Right to Withdraw Consent
Where our processing of your personal information is based on your consent, you may withdraw your consent at any time:
NOTE: Withdrawing consent will not affect the lawfulness of any processing conducted prior to your withdrawal, but it may limit your ability to access certain feature-dependent services.
5.6 Right to Object & Restrict Processing
In some service functions, we may make decisions based solely on non-manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to object to or request the restriction of our processing of your personal information under certain circumstances (such as processing based on legitimate interests or for direct marketing purposes).
5.7 Right to Opt-Out of Targeted Advertising / Sale or Sharing of Personal Data
We do not sell your personal information for monetary value. However, we may share non-sensitive personal information with third-party advertising or analytics networks to deliver personalized ads. You have the right to opt-out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising by modifying your privacy preferences in the app or enabling recognized Global Privacy Control signals on your browser.
5.8 Right to Non-Discrimination
We will not discriminate against you for exercising any of your data protection rights. Unless permitted by applicable law, we will not deny you services, charge you different prices or rates, or provide you with a different level or quality of service simply because you exercised your privacy rights.
5.9 Right to Designate an Authorized Agent or Legal Successor
Depending on your jurisdiction, you may designate an authorized agent to make privacy requests on your behalf. Where provided under applicable local law, upon a user's death, their close relatives may exercise certain rights (such as access, correction, or deletion) over the deceased user's relevant personal information, unless the deceased user expressed a contrary instruction prior to their death.
5.10 Right to Lodge a Complaint
If you believe our processing of your personal information infringes upon applicable privacy regulations, you have the right to file a complaint with the competent Data Protection Authority in your country, region, or jurisdiction of residence.
5.11 Identity Verification
In addition to the self-service options provided within the platform, you may exercise any of your privacy rights by submitting a formal request to us via email at support@gatherjoypte.com. To expedite the processing of your request, we strongly recommend titling your email subject line as "Privacy Request - [Type of Request]" (e.g., "Privacy Request - Account Deletion" or "Privacy Request - Data Access").
To protect the security and privacy of your personal information and prevent unauthorized access, identity theft, or fraudulent requests, we must verify your identity before fulfilling any privacy rights requests you submit. Verification Methods is depending on the nature, scope, and sensitivity of your request, we may require you to verify your identity by:
If we cannot reasonably verify your identity based on the information provided, or if we suspect malicious, fraudulent, or unauthorized activity, we reserve the right to decline your request. We will notify you of the refusal and the underlying reasons in a timely manner.
5.12 Applicable Processing Fees
In principle, you do not need to pay any fee to access your personal information or to exercise any of your statutory privacy rights.However, to the extent permitted by applicable law, we reserve the right to charge a reasonable administrative fee (based on our actual operational costs) or to decline to act on your request under the following circumstances:
If we determine that a request warrants an administrative fee, we will notify you of the estimated costs and the justification for the charge, and obtain your explicit authorization before proceeding with the request.
Please note that your rights are not absolute. Under certain circumstances, we may be legally restricted or prohibited from fulfilling your request in whole or in part, particularly where fulfillment is constrained by applicable laws, regulations, court orders, or compulsory governmental demands.If we determine that we cannot fulfill your request due to any of the legal or judicial reasons, we will inform you of the decision and explain the statutory or factual basis for the restriction, unless prohibited from doing so by law, court order, or regulatory directive.
Cookies are small text files placed on your computer or mobile device when you visit a website or access an application. They enable us to recognize your browser or device, preserve your preference settings, and maintain session safety.
We classify the Cookies used on our platform into the following functional categories:
These Cookies enable enhanced functionality and personalization, such as remembering your language preferences, display settings, and login credentials across sessions.
These Cookies collect aggregated, non-personally identifiable information about how users interact with our platform (e.g., page visit counts, crash logs, and error reporting). This data helps us measure, analyze, and optimize our platform’s overall performance and user interface.
Most web browsers and mobile operating systems allow you to manage or block Cookies through their settings menu. You may configure your device to notify you when a Cookie is being sent, or block Cookies entirely. If you choose to reject, disable, or block Strictly Necessary or Functional Cookies, you may still access our platform, but certain functions, personalized features, or service areas that rely on Cookies may not operate properly.
Our services are not directed to children. We define a "Child" as any individual under the age of 16, or under the higher minimum age mandated by applicable local data protection laws in their jurisdiction of residence.We do not knowingly solicit, process, or collect personal information from any Child without verifiable parental or legal guardian consent.
If you are a minor under the applicable age of majority in your jurisdiction, you may only access or use our services with the active involvement, guidance, and explicit prior consent of your parent or legal guardian.Parents or legal guardians must carefully read and review this Privacy Policy together with their minor child. By permitting your child to use our platform, you agree to this Privacy Policy on both your own behalf and on behalf of your child, accepting full responsibility for their online activities and compliance with our Terms of Service.
We take stringent technical and organizational measures to safeguard the security and confidentiality of children's and minors' data. If we discover or have reason to believe that we have collected personal information directly from a Child without prior verifiable parental consent, we will immediately initiate procedures to restrict access to the account and delete or anonymize the relevant data from our servers as quickly as possible.As a parent or legal guardian, you have the right to review, update, or request the deletion of the personal information we have collected from your child at any time, or to revoke previously granted consent and request the immediate termination of your child's account.
If you are a parent or legal guardian and believe that your child has submitted personal information to us without your knowledge or consent, or if you have any questions or concerns regarding our children's privacy practices, please contact us immediately via email at support@gatherjoypte.com.Please title your email subject line as "Child Privacy Inquiry / Request". To protect your child's security, we will take steps to verify your identity as the legal guardian before responding to or fulfilling your request.
We reserve the right to modify, update, or revise this Privacy Policy from time to time to reflect changes in our legal, regulatory, operational, or technical environment. For minor, administrative, or non-material updates (such as fixing typographical errors or updating contact details), we will post the revised Privacy Policy directly on this page along with an updated "Last Updated" or "Effective Date" at the top of the policy. If we make material or significant changes to this Privacy Policy (such as altering the types of personal information collected, expanding processing purposes, or changing data sharing practices), we will provide you with prominent advance notice prior to the changes taking effect.
If you continue to access or use our platform or services after the effective date of the updated Privacy Policy, you acknowledge that you have read and understood the revised policy. If you do not agree to any modified terms, you must immediately stop using our services and may request account cancellation in accordance with Section 5.4.
For questions, requests, or privacy complaints, reach out to our privacy officer at support@gatherjoypte.com.