Scope and Data Controller
This policy applies to the Service. Other products offered by Lumo, as well as external websites accessed by users, are governed by the policies specific to those respective products or services. The handling of information stored on a user's device, information stored on Apple’s iCloud, and information obtained by the Operator (e.g., through inquiries) may differ in each case.
The Operator’s business name is "Lumo," and the contact address for matters concerning personal information is info@lumo.tokyo. Details regarding the legal identity (name/address) of the business entity and other information required by law will be provided without undue delay upon request via the aforementioned contact address. The use of a business name does not constitute the full provision of business entity information as required by law.
In-Game Information and Local Storage
This application does not require a separate user registration. Data such as company names, game progress, in-game financial information, company history, AI model records, and settings are generally stored locally on the user's device. The Operator does not employ any mechanisms to automatically collect this data onto its own servers.
The training, evaluation, and provision of AI models within the game are purely part of the in-game simulation. Standard gameplay does not involve transmitting save data to external generative AI APIs, nor is such data used to train real-world AI models. Please refrain from entering the personal information or confidential information of others into fields such as company names.
This application does not incorporate any third-party advertising SDKs or gameplay analytics SDKs. Please note that operating systems, app stores, development engines, and similar entities may process diagnostic information in accordance with their own respective settings and terms. If the service operator receives such diagnostic information, it will be used exclusively for the purposes of investigating technical issues, ensuring security, and improving product quality.
Optional iCloud Synchronization, Deletion, and Export
iCloud synchronization is optional and is disabled by default. If enabled, your company records—including current and past company and model data—will be saved to a private CloudKit database linked to your Apple Account. The device will also store information regarding the synchronization status and an identifier used for account verification. The storage infrastructure and account management are provided by Apple.
Deleting a company record from your device removes the data saved locally on that device as well as any associated backups; however, this does not automatically delete copies stored in iCloud or files that have been exported. Disabling synchronization will not remove existing copies on your device or in iCloud. The current version of the app does not provide a feature to delete only the cloud-based data. Please refer to Apple’s iCloud storage management settings or contact us for guidance on how to delete this data.
Data export and sharing are initiated by the user and may include information such as company names and game records. You choose the destination for exported or shared data, and any subsequent handling of that data is subject to the terms and policies of the recipient. Copies stored on your device, in iCloud, in backups, or with third parties must be managed and deleted separately. The service operator does not have the ability to directly delete data from your Apple Account or from any third-party destinations with which you have shared it.
Website, Inquiries, and Purpose of Use
To facilitate website delivery, investigate technical issues, and prevent unauthorized use, our hosting provider, Vercel, may process technical information such as your IP address, request timestamp, browser type, and the specific pages accessed. When you contact us via email, we receive your return email address, the body of your message, and any device information or attachments you choose to provide, using the email service employed by our operations team.
We use this information for the following purposes: providing and maintaining our services; responding to requests that require identity verification; offering support; investigating technical issues or unauthorized activity; ensuring security; fulfilling legal obligations; and handling disputes. Should we need to change the purpose of use, we will do so in accordance with the scope and procedures permitted by law. This does not constitute blanket consent for unrelated advertising or research purposes.
Please do not send passwords, authentication codes, payment card details, the personal information of others, or complete sets of application save data, unless we have specifically requested them and provided instructions on a secure method for transmission. If our support team requires documentation, we will limit the request to only what is necessary for the specific purpose. This website does not accept purchase requests or the entry of payment card information.
Browser-based storage and optional analytics
Your privacy preferences are stored in your browser and will be retained until you change them or clear your browser's storage. Language selection for the AI Inc. website is managed via the URL. These settings are separate from any application save data.
We only enable Vercel Web Analytics and Speed Insights if you explicitly choose to "Allow analytics." This involves processing data such as the pages you visit, general information about your device and browser, page load speeds, and certain link interactions. Before any data is sent for analysis, URL query strings and fragments are removed; the content of your messages or your application save data is never included in these events. These tools do not use cookies for advertising purposes. Access logs used for service delivery and security management are separate from these optional analytics.
You may opt out of analytics by selecting "Essential features only," and you can change or withdraw your consent at any time via the "Privacy settings" menu. Withdrawing your consent will stop any further analytics data from being sent from this website, though it will not delete information that has already been processed. Choices made under previous notifications will not be carried over or treated as consent for new forms of analysis.
Outsourcing, Third-Party Provision, and Handling Outside Japan
We use Vercel for site delivery and optional analysis, Apple for optional iCloud synchronization, and email service providers for email-based support. When personal data is handled by third parties (such as service providers), we limit the scope to what is necessary for the intended purpose and implement appropriate measures, including the careful selection and supervision of these parties. For services chosen by the user—such as those provided by Apple or other third-party platforms—the terms and conditions of those respective providers also apply.
We do not sell personal information, nor do we use the content of your inquiries or your saved data for advertising or for training AI models. We do not share personal data with third parties, except in cases where we have obtained your consent, where required by law, where an exception under the law applies (such as for the protection of human life, physical safety, or property), or where data is shared with authorized service providers.
Information may be processed outside of Japan, depending on the infrastructure used by our service providers. When providing data to third parties located abroad, we ensure compliance with applicable laws by obtaining necessary consents, providing required information, and verifying that appropriate safeguards are in place. Please contact us if you would like to request information regarding our service providers or the handling of data outside of Japan. Providing links to the policies of our service providers does not absolve the operator of its own legal responsibilities.
Security Management, Retention Periods, and Response to Data Breaches
We implement organizational, personnel, physical, and technical security measures tailored to the level of risk—such as restricting access, managing the operating environment, and vetting service providers—to protect the information we collect. We can provide an overview of these security measures upon request, provided that such disclosure does not compromise the security of our operations.
Inquiries, diagnostic information, and similar data held by the operator are retained only for as long as is reasonably necessary to fulfill the intended purpose, comply with legal retention requirements, or address potential disputes. Once such data is no longer required, it will be securely deleted or anonymized. The retention period for information stored on your device, in iCloud, or with third-party sharing services depends on user actions and the terms of each respective service. We do not guarantee permanent storage or the ability to recover all information.
In the event of a data breach or similar incident, we will verify the facts, take steps to prevent further damage, investigate the cause, implement measures to prevent recurrence, report the incident to the relevant regulatory authorities as required by law, and notify the affected individuals.
Requests for Disclosure, Inquiries, and Complaints
Regarding personal data held by the operator, you may—in accordance with applicable laws—request notification of the purpose of use, disclosure, correction, addition, deletion, cessation of use, erasure, cessation of provision to third parties, or disclosure of records concerning provision to third parties. Where permitted by applicable foreign laws, we also accommodate requests regarding rights such as access, objection, restriction of processing, data portability, and withdrawal of consent.
Please contact us at info@lumo.tokyo, specifying the product in question, the nature of your request, and your contact information. We will request only the documentation necessary to verify your identity (or that of your authorized representative) and will respond without undue delay, in compliance with the law. We will accommodate your preferred method of disclosure to the extent permitted by law; if we are unable to do so, we will provide an explanation. If a fee is required, we will inform you of the amount and the reason in advance; no charges will be applied without your consent. No fees are charged for the disclosure of information regarding the business operator.
Withdrawing your consent does not invalidate the lawfulness of any processing that occurred prior to the withdrawal. For data that we do not hold or manage—such as information stored exclusively on your device—we will provide guidance on how you may manage it yourself. You may also file inquiries or complaints with the Personal Information Protection Commission or other relevant regulatory authorities.
Minors and Users Outside of Japan
If you are a minor, please obtain consent from your legal representative before using our services, if required by law. In cases where additional consent or protective measures are necessary based on your age or location, we will comply with all applicable laws. If you discover that personal information has been provided without the necessary consent, please contact us.
Where applicable law requires a legal basis for processing, we will process data based on the performance of a contract necessary for service and support, compliance with legal obligations, our legitimate interests (such as security management that does not unduly infringe upon your rights or interests), or your consent (for instance, for optional analysis). This policy does not limit any mandatory protections afforded to users in their place of residence.
Changes and Contact Information
If this policy is modified, the changes and the date of the update will be posted. Significant changes will be communicated through appropriate channels, and if new consent or similar requirements arise, the necessary procedures under applicable law will be followed. For inquiries, please contact info@lumo.tokyo.