Privacy & Data Protection

Privacy Policy

How we collect, use, and protect your personal information

Last updated: January 13, 2026

1. Introduction

Lutetium Limited ("we," "our," or "us") operates the AXORA platform. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.

2. Information We Collect

We collect information that you provide directly to us and information that is automatically collected when you use our Platform:

2.1 Information You Provide

  • Account registration information (username, email address, password)
  • Profile information and preferences
  • Payment information (processed securely through third-party payment processors)
  • Communications with our support team
  • Feedback and survey responses

2.2 Automatically Collected Information

  • Device information (device type, operating system, browser type)
  • IP address and location data
  • Usage data (games played, medals earned, time spent on Platform)
  • Cookies and similar tracking technologies
  • Log files and analytics data

3. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve the Platform and our services
  • Process transactions and manage your account
  • Send you technical notices, updates, and support messages
  • Respond to your comments, questions, and requests
  • Monitor and analyze usage patterns and trends
  • Detect, prevent, and address technical issues and security threats
  • Personalize your experience and provide relevant content
  • Comply with legal obligations and enforce our Terms & Conditions

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

  • Service Providers: With third-party service providers who perform services on our behalf (payment processing, analytics, hosting)
  • Legal Requirements: When required by law, court order, or government regulation
  • Business Transfers: In connection with a merger, acquisition, or sale of assets
  • Protection of Rights: To protect our rights, property, or safety, or that of our users
  • With Your Consent: When you have given us explicit permission to share your information

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Platform and store certain information. Cookies are files with a small amount of data that may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Platform.

We use cookies for authentication, preferences, analytics, and advertising purposes. You can manage your cookie preferences through your browser settings.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal information
  • Portability: Request transfer of your data to another service
  • Objection: Object to processing of your personal information
  • Withdrawal: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at [email protected]

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will securely delete or anonymize it. Account information is typically retained until you request account deletion or the account is inactive for an extended period.

9. Children's Privacy

Our Platform is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. By using our Platform, you consent to the transfer of your information to these countries. We take appropriate safeguards to ensure your information receives an adequate level of protection.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes. Your continued use of the Platform after changes become effective constitutes acceptance of those changes.

12. GDPR Compliance

If you are located in the European Economic Area (EEA), we process your personal information in accordance with the General Data Protection Regulation (GDPR). We act as a data controller for the personal information we collect. Our legal basis for processing includes consent, contract performance, legal obligations, and legitimate interests.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: [email protected]

Address: Lutetium Limited, Flat/Office 101, Protesilaou 2, 2051 Nicosia, Cyprus

Data Protection Officer: You can contact our Data Protection Officer at the email address above.

By using the AXORA platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.