A. Information we collect and process. Please note that Sections A-G of this Privacy Policy will also be considered the Notice at Collection, as defined by the California Consumer Privacy Act. 

We may collect information about the Services you use and how you use them, such as the selections you make on our Services. We collect Personal Information, DII, as each is defined below, and log information about your interactions as described below. 

Personally identifiable information (“Personal Information”) is information that can be used to identify or contact you online or offline, such as your name, address, email, phone number, photos or audio data, and payment information. The Service may collect Personal Information when it is provided to us, such as when you use our Services, attempt to contact us, submit a resume or job application, or connect with us on social media or via one of our partners.  

We may also create or collect device-identifiable information (DII), such as cookies, statistical identifiers, unique device and advertising identifiers, usernames, and similar identifiers that are linkable to a browser or device. From these platforms, we may also receive other information, such as your IP address, user agent, timestamps, precise and imprecise geolocation, sensor data, apps, fonts, battery life information, and screen size. We and our analytics service providers and advertising partners use cookies, which are small text files that help store User preferences and activity, similar technologies such as web beacons, pixels, ad tags, and SDKs, which are blocks of code provided by our partners that may be installed in our mobile and online applications, to recognize you when you visit our Services, and to collect information such as the number of visits, which features, pages, or content are popular, and to measure your browsing activities. These technologies allow us to optimize the operation of our Services, including by allowing us to help ensure our Services are functioning properly and ultimately improve the Services. 

Our Services also collect information about your interactions, including navigation paths, search queries, crashes, timestamps, purchases, clicks and shares, and referral URLs. We may combine this data with Personal Information and other DII. For efficiency’s sake, information about your interactions may be transmitted to our servers while you are not using the Services.  We may also partner with third parties that collect additional information – please see their privacy policies for more details and see below for your choices regarding these parties. 

Categories of Personal Information we Process

Google Analytics

In addition to the foregoing, we have integrated Google Analytics into the Services. 

Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website directed a User to the Services (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. We mainly use this analysis to optimize our websites and for the cost-benefit analysis of Internet advertising. 

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. 

Google Analytics uses cookies. The information generated by the cookie about your use of the Services is usually transmitted to and stored in a Google server in the United States. Google might transfer the Personal Information collected via this technical procedure to third party sub processors to accomplish the purpose for which we use Google Analytics. 

On behalf of the Company, Google will use this information to evaluate your use of the Services, compile reports on the Services, and to provide us with further services related to the Services. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google. 

You may prevent the collection of the data generated by the cookie and related to your use of the Services (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=e This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. Additionally, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs. 

Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy and https://marketingplatform.google.com/about. 

For more information on how Google uses and processes data, please visit: https://policies.google.com/technologies/partner-sites. 

 If you wish to learn more about how Google uses your data, you may click the following link: How Google Uses Information From Sites Or Apps That Use Our Services

User Generated Content

Certain information, materials, and content that you upload or share via the Services may be collected and stored by Company and may be distributed or displayed publicly, and subsequently used or shared by Company, or other Users. For the purposes of this Privacy Policy, such content will be referred to as “User Generated Content.” By consenting to this Privacy Policy, you hereby consent to Company’s use of any Personal Information contained in the User Generated Content for the reasons set forth herein and understand and agree that other users may have access to such Personal Information, by virtue of their access of the User Generated Content. 

B. How we Use your Personal Information  

We use the information we collect from our Services to provide, fulfill maintain, protect and improve our Services, to develop new Services and offerings, and to protect us and our Users. 

Personal Information is primarily used for business purposes, such as for delivering and maintaining the Services, sending you occasional communications and updates, hiring, responding to inquiries, logins, and marketing and advertising. When you contact us, we may keep a record of your communication as well as the other information to help solve any issues you might be facing. We may use your email address to inform you about our Services, such as letting you know about changes or improvements.  

Please keep in mind that comments sections, forums, and other similar areas of our Services are public.  Any information posted in those areas is viewable and usable by anyone that has access. 

We share Personal Information with companies, outside organizations, and individuals for limited reasons, outlined below: 

1. With your consent - We will share Personal Information with companies, outside organizations or individuals if we have your consent to do so. 

2. For external processing - We provide Personal Information to our affiliates, service providers, or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures. 

3. For legal reasons - We will share Personal Information with companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our Users or the public as required or permitted by law. 

4. In case of a sale or asset transfer - If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, User information, including Personal Information collected from you through your use of our Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Services. 

5. With Service Providers - We may share Personal Information with companies that provide services to us, including companies that assist us with hosting, payment processing services, providing data process services, providing analytics services, account management, technical support, marketing, measurement, and similar services.  

6. With Third Party Advertisers. We share the Personal Information outlined above with third parties for the purpose of facilitating targeted advertising, also known as cross contextual behavioral advertising or interest-based advertising (collectively “Targeted Advertising”). As a result, you may see an ad within our Services that is directed to you based on Personal Information processed hereunder. These third party advertisers may include entities known as “Data Brokers,” which means that we do not have a direct relationship with these companies.  For more information on this type of processing, including how you can opt out of the transfer of your data for the purposes of Targeted Advertising please see Section G below.  

7. In aggregated form for business purposes - We may share aggregated information and DII with our partners such as businesses with whom we have a relationship, advertisers or connected sites. For example, we may share information to show trends about the general use of our Services. 

8. With third-party analytics companies for the purpose of providing analytics to improve our Services. As part of this, we use Google Analytics.  

We use DII to operate our Services and manage User sessions, including analyzing usage of our Services, preventing malicious behavior and fraud, improving the content, to link your identity across devices and browsers in order to provide you with a more seamless experience online, and helping third parties provide relevant advertising and related metrics. We share DII with third parties primarily for advertising and analytics purposes, for external processing, and for security purposes. 

C. Disclosure of Personal Information: In the past 12 months, we have disclosed the following information to our service providers or contractors (also known as our data processors) for the purposes described above:  

1. Category 1: Identifiers 

2. Category 2: Information that identifies or can be associated with a particular individual 

3. Category 3: Commercial information  

4. Category 4: Internet or electronic network activity information  

5. Category 5: Geolocation  

6. Category 6: Inferences drawn from Personal Information to create a profile about Users’ preferences.

D. Sharing of Personal Information for the Purposes of Targeted Advertising: Beginning on August 13, 2024 and continuing thereafter, we have disclosed the following information to our service providers for the purposes of targeted or cross contextual behavioral advertising. In some jurisdictions, this may also be referred to as the “sale” or “sharing” of your Personal Information:  

1. IP Address 

2. Unified ID  

3. Zip Code  

4. Category 4: Internet or electronic network activity information 

5. Category 5: Geolocation 

6. Category 6: Inferences drawn from Personal Information to create a profile about Users’ preferences. 

This Personal Information was shared with 1) third party advertisers for the purpose of providing you with targeted advertisements that you may find beneficial, these may include Data Brokers; 2) with third party companies for the purposes of preventing ad fraud or similar; and 3) with third party analytics companies for the purpose of analyzing the effectiveness of the Targeted Advertisements and determining the advertisements that will be most beneficial to you. For more information on how to “opt-out” of the sharing of your Personal Information for targeted advertising, see Section G below.

E. Children 

We do not knowingly collect information from or for any child under the age of 13 (or 16 in some jurisdictions)  If you are under the age of 13 (or 16 in some jurisdictions), please do not use the Services. If you are the parent of a child under the age of 13 (or 16 in some jurisdictions) and have a concern regarding your child’s information on our Services, please contact us at the email provided at the end of this Policy. Additionally, we will not knowingly engage in the processing of data for Users under the age of consent as established by other applicable data protection law. If we learn we are engaged in such processing we will cease such processing and take reasonable measures to remove the applicable information. WE DO NOT KNOWINGLY SELL OR SHARE PERSONAL INFORMATION FOR CHILDREN UNDER THE AGE OF 16 FOR THE PURPOSES OF TARGETED ADVERTISING.  

F. Data Storage 

We generally store data for as long as we need it to accomplish the purpose for which such data is processed. If that purpose has been accomplished, we will delete such data, but we may store data for up to 5 years or longer if there is a valid business purpose or if we are legally required to do so.

G. Notice of Right to Opt-Out Of Sharing/Sale of Information  

We take your data privacy seriously and only want to process your Personal Information in ways that are beneficial to you. Accordingly, you have the right, at any time to object to and otherwise direct us not to share your Personal Information for the purposes of Targeted Advertising.  You can opt out of this type of advertising and information sharing by clicking here. Please note, opting out will cause you to no longer see Targeted Advertising on the Lunar Client launcher, which is the only place our Services offer Targeted Advertising. You may still see Targeted Advertising on third party websites, over which we have no control. Additionally, you can opt out by selecting the applicable settings within your browser or on your mobile device. You can also opt out of participating companies by visiting the following sites: 

• http://optout.networkadvertising.org/ 

• https://youradchoices.com/control.

• http://optout.aboutads.info/

• http://youronlinechoices.eu/ 

• https://globalprivacycontrol.org/

• https://tools.google.com/dlpage/gaoptout

• https://support.apple.com/en-us/HT202074

If you wish to similarly opt out of Targeted Advertising on mobile devices, you can enable the Limit Ad Tracking flag on the device. Enabling Limit Ad Tracking sends a flag to third parties that you wish to opt out of targeted advertising on that device, and major mobile platforms require companies to honor this flag. Screenshots on how to find these options on various devices are available here: http://www.networkadvertising.org/mobile-choices. To learn how to opt out on other devices, please visit the platform’s privacy policies for more information. 

H. Third Parties 

While we strive to work with reputable companies with good privacy practices, this Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you on the Services or to the privacy policies of third parties to whom we share Personal Information for the purposes of Targeted Advertising. We also do not control these privacy policies and your privacy settings with third parties, including social networks and ad networks. For further information, please see the relevant privacy policies for each third party and industry codes of conduct. 

Tebex Limited is an authorized reseller of Cosmetic Items and a payment processor with respect to credit card transactions. When you provide any information to Tebex, you are subjecting such information the processing activities set forth in Tebex's privacy policy. We do not control Tebex's processing of your information or their privacy policy. For more information on how Tebex processes information, please see Tebex’s privacy policy.

I. Legal Bases for Processing 

The data we process may qualify for multiple legal bases for processing under Article 6 of the General Data Protection Regulation (and similar laws that specify legal bases for processing). Below are our primary legal bases for each type of data for Users covered under such laws: 

• It is contractually necessary to process your username, email, password, cookie data, IP address, UUIDS, commercial information (including records of purchases made on the Lunar Client), lat/long coordinates, device models, and operating systems versions, and similar network activity and information to fulfill our obligations in the TOS and provide you with access to the Lunar Client, Cosmetic Items, and use of merchandise and other Services.  

• We have a legitimate interest in processing your email address, Discord ID and social media handles, if you provide it to us via communications, to communicate with you, to provide you with updates regarding the Services, and to respond to your emails and messages on our Discord server or via our social media accounts.  

• We have a legitimate interest in processing  1) Identifiers such as your IP Address, and Minecraft UUID; and 2) information that can be used to identify you for the purpose of securing our Services including the prevention of DDOS attacks. 

• We have a legitimate interest in processing 1) Identifiers such as your IP Address, and Minecraft UUID; and 2) information that can be used to identify you for the purposes of monitoring activity on the Server(s) and ensuring compliance with our TOS. 

• We have a legitimate interest in conducting analytics, measuring usage and conversions, detecting fraudulent users, implementing data security measures, and analyzing telemetrics and other data to improve our Services. We and our processors have measures in place to protect your privacy. 

• If you are a citizen of the European Union, United Kingdom, or Switzerland, we rely on your direct consent to process data for the purpose of sending you Targeted Advertisements, as well as for the purpose of creating Inferences drawn from Personal Information to create a profile about Users’ preferences. If you wish to withdraw such consent, you may do so at any time by clicking here.  

• For HR and internal operations, we rely on contractual necessity and legitimate interests bases to process the data of applicants and staff, such as for resumes and applications, payroll, internal chat and communications, and project management. 

• We have a legitimate interest in processing your Personal Information to provide customer support and answer sales questions, including data such as emails, names, and other details as necessary to answer User questions. Similarly, we have a legitimate interest in processing Personal Information (e.g., names, social media profile data, and chat data/metadata) for the purpose of responding to questions and messages on our social media accounts, including through automated bots. 

• We have a legitimate interest in processing all of the Personal Information described herein for the purposes of creating and maintaining data backups to guard against loss and data breach. 

• For HR (employment) and internal operations, we rely on contractual necessity and legitimate interests bases to process the Personal Information, including identifiers, of applicants and staff, such as for resumes and applications, payroll, internal chat and communications, and project management. 

J. Choice 

If you wish to cancel your account, you can do so by accessing the Services or contacting us for assistance with the process. Our email is included at the end of this Policy.

K. Your Rights  

If you are a California, Virginia, Colorado, Utah, Connecticut, Montana, Oregon, or Texas, resident or resident of the European Union, United Kingdom, or Switzerland,  and wish to access, update, correct, object to, opt-out of the sharing of, obtain a copy of, or delete your Personal Information, or otherwise wish to contact us regarding your Personal Information please reach out to our Data Protection Officer at [email protected]. You may make any of the following requests yourself or through a designated agent. We may ask you to verify your identity before we can act on any request regarding your Personal Information.  You must provide us with sufficient information to verify your identity, however we will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity. Additionally, if you choose to make a request through a designated agent, we may contact you to verify that you have given such agent the requisite permission. 

In some cases, we may have to keep that information for legitimate business or legal purposes and therefore will deny a request to delete the information.  

Without limiting the foregoing, in certain circumstances, if you are a resident of California, Virginia, Colorado, Utah, Connecticut, Montana, Oregon, or Texas or the European Economic Area including the European Union, the United Kingdom, or Switzerland you have the following rights with respect to your Personal Information:  

• The right to access, update or to delete your Personal Information. Regardless of how we come into contact with your Personal Information, you have the right to request access to any Personal Information we hold about you. You may request access to your Personal Information by contacting our Data Protection Officer on the details below. If at any time you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, you may request that we amend and/or update your Personal Information. If we refuse your request, we will provide you with a written notice which will outline the reasons for such refusal and the complaint mechanisms available to you.  

• The right of rectification. You have the right to have your Personal Information rectified if that information is inaccurate or incomplete. 

• The right to object. You have the right to object to our processing of your Personal Information. 

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information. 

• The right to data portability. You have the right to be provided with a copy of the Personal Information we have on you in a structured, machine-readable and commonly used format. 

• The right to withdraw consent. You also have the right to withdraw your consent at any time where Company relied on your consent to process your Personal Information. 

• The right to opt-out. You have the right to opt-out of the processing of your Personal Information for the purposes of (a) Targeted Advertising; (b) the sale of Personal Information, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. To exercise this rights, please see Section G above.  

Additionally we will disclose to you, at your request:  

You have the right to make complaint to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA, the United Kingdom, or Switzerland.

Appeal

If you wish to appeal our decision with respect to any of the above, please email us at [email protected]. In your appeal, please state that your message pertains to an appeal and include the date and subject matter of your original request.

L. Non-Discrimination  

We will not discriminate against you for exercising the foregoing rights. To that end, and unless permitted by law, we will not:  

1. Deny you goods or services, unless it is impossible to distribute or provide such goods or services without the requisite Personal Information;  

2. Charge you different prices for goods or services; 

3. Impose penalties;  

4. Provide you with a different level or quality of goods or services; or   

5. Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services. 

M. International Transfer  

Our Services are located in the United States and your Personal Information may be transmitted to or stored in the United States. The data protection laws of the United States may be different from those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate including ensuring all our processors adhere to terms and conditions set forth in the Standard Contractual Clauses, as approved by the European Commission. To the maximum extent permitted by applicable law, you hereby consent to the Company processing your Personal Information in the United States or any other locations where we operate. 

Given that our Services are globally accessible, there are times where your data may need to be transferred across different jurisdictions. However, we will not transfer your Personal Information across jurisdictions, unless: 

• You have provided your consent; or  

• It is necessary to complete a transaction related to the Services or otherwise described herein; and 

• We believe that the recipient of such information is subject to a law, contractual obligation, or a binding scheme, that has the effect of protecting your Personal Information in a way that, overall, is at least substantially similar to the way in which information is protected in the European Union, United Kingdom or Switzerland and there are mechanisms you can access to enforce that protection of the law or binding scheme; or 

• Where otherwise allowed by any applicable legislation.

N. Information Security  

We work hard to protect our Users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold and undertake reasonable security measures with appropriate confidentiality, integrity, and availability protections. However, since no software or storage system is 100% secure, we cannot guarantee the security of your information associated with the Services, or any other service for that matter. As a result, while we strive to protect your information, you agree and acknowledge that: (i) there are security and privacy limitations inherent to the Internet and wireless and mobile networks which are beyond our control; and (ii) security, integrity, and privacy of all information and data exchanged between you and us cannot be guaranteed. You can help protect your account information by using unique and hard-to-guess passwords, ensuring no one else uses your device or computer when you are logged in, logging off from the Services when they are not in use, by keeping your password and other information confidential, and by taking precautionary steps to guard the physical safety and security of your device or computer.

O. Merger or Sale  

The information collected pursuant to this Privacy Policy, including Personal Information, is considered an asset of Company. In the event Company or some or all of the assets related to the Services are acquired by another entity through a sale, merger, or some other change of ownership transaction, Company reserves the right to transfer or assign the information, collected pursuant to this Privacy Policy.

P. Contact Info for Data Protection Officer  

We welcome your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, or if you have any other questions or concerns regarding this Privacy Policy please contact [email protected].  

Contact Information for EU Residents

If you are a resident of the European Union, you may also contact our EU representative via the following: 

Osano International Compliance Services Limited 

ATTN: R76Z 

3 Dublin Landings 

North Wall Quay 

Dublin 1 

D01C4E0 

Contact Information for UK Residents 

If you are a resident of the United Kingdom,  you may also contact our UK representative via the following: 

Osano UK Compliance LTD 

ATTN: R76Z 

42-46 Fountain Street 

Belfast

Antrim 

BT1 - 5EF