Privacy Policy

1. The controller of personal data is the operator of the Lumin service – the Lumin Shield filtering shield, the client panel available on this site and the “Lumin” Minecraft server (the “Controller” or “we”).
2. Contact for all personal-data matters: contact@lumin.edu.pl. The same address is used to exercise the rights described in section 10.
3. The Controller has not appointed a data protection officer, as it is not required to do so under Article 37 GDPR.

1. In connection with a connection to a protected server we process only the following player data:
   1. the IP address of the device the connection is made from;
   2. the UUID of the Minecraft game account;
   3. the player name (nick) assigned to that account.
2. Gameplay generates gameplay data linked to the UUID (for example inventory, position in the world, statistics, penalties imposed and chat messages to the extent needed for moderation). On its own it does not identify a person, but we treat it with the same care as personal data.
3. From players we do not collect names, e-mail addresses, phone numbers, payment data or location data other than what follows indirectly from the IP address.
4. We obtain the data directly from the connection made by your game client. We do not buy data or obtain it from other sources.

1. If you create a client panel account, we process the data provided at registration: your e-mail address, display name and password, which we store only as an irreversible hash.
2. If you sign in through an external identity provider, we receive an account identifier and e-mail address from that provider. We never receive your password for that provider.
3. Using the panel generates data related to your organisation: the configuration of protected servers, domains and protection profiles, IP lists, API keys, notification settings and aggregate traffic statistics. This data is necessary to provide the service.
4. If you write to us, we process the data you include in the message solely to reply.

Each purpose has its own legal basis and its own retention period. The table below is complete – we process data for no other purpose.

1. Every connection to a protected server first reaches the filtering shield – an intermediary layer (a proxy network based on HAProxy and our own filtering software) that sits between the Internet and the actual game server.
2. The shield analyses the IP address and the course of the connection (connection rate, conformity with the game protocol, verification result) exclusively in working memory (RAM). IP addresses of legitimate connections are not written to persistent storage by the shield and are removed from memory when the connection ends or when the short time window needed for rate limiting expires. The exception is the browser verification described below.
3. If a connection is identified as part of an attack or as automated traffic, its IP address may be temporarily blocked and the event recorded in the security log together with the time and reason for rejection. The log is used solely to analyse attacks, refine filtering rules and, where appropriate, report the incident to the competent authorities.
4. The shield may use lists of address ranges known as attack sources and ranges assigned to anonymising networks (VPN, proxy) and data centres. These lists contain network address ranges, not information about specific people, and are processed locally.
5. The shield may ask a player for a browser verification: the player receives a link in the game chat to a page on our domain, where they complete a Cloudflare Turnstile challenge (section 7). This applies to players connecting from outside the country set for the server and to addresses our protection flags as suspicious (for example a VPN, a proxy or a high risk score). We determine the country of an IP address locally, from the IP to Country Lite database by DB-IP (CC BY 4.0 licence) - the address is not sent to anyone for this. To confirm that the challenge was completed by the same person who is connecting to the server, we compare the browser’s IP address with the IP address of the game connection. For the duration of the verification we record the IP address, the player name and the outcome; this record is deleted after 2 hours at the latest. After a successful verification we keep, for 7 days, a note that the given IP address has passed verification for the given server network - solely so that we do not ask again on every join. For a player from abroad that note contains neither the player name nor the UUID. For an address flagged as suspicious it also contains the player name, because many people connect from one such address (for example a VPN server) and one person's verification must not exempt the others.
6. The legal basis for this processing is our legitimate interest (Art. 6(1)(f) GDPR) in ensuring the security and continuity of the protected servers. We have carried out a balancing test: the processing is limited to the necessary minimum, takes place mainly in volatile memory and its impact on players is negligible, whereas without this protection the servers could not operate.

1. We do not sell, rent or share data with third parties for commercial purposes.
2. We do not profile players or clients for marketing purposes, do not build interest profiles and do not combine service data with data from other sources.
3. We make no decisions based solely on automated processing that would produce legal effects for a person. The automatic rejection of a connection by the shield is a technical security measure. If a connection is rejected by mistake you can contact us and a human will review the case.
4. We send no marketing messages. E-mails from the panel concern only your account and the operation of the service.

1. Data may be processed on our behalf by our server infrastructure provider (hosting), on servers located in the European Union, under a data processing agreement (Art. 28 GDPR). The provider may not use the data for its own purposes.
2. If a player uses a genuine game account, its authenticity is verified through Mojang Studios / Microsoft services, which act as an independent controller under their own privacy policy. The player name and a game session identifier are transmitted for verification.
3. If you sign in to the panel through an external identity provider, that provider processes the sign-in data as an independent controller under its own privacy policy.
4. If you set up notifications to a Discord webhook, the content of those notifications (for example information about an attack on your server) is sent to Discord Inc. at your instruction. You can disable this in the panel at any time.
5. If a player opens the browser verification page (section 5), the challenge on that page is provided by Cloudflare, Inc. (the Cloudflare Turnstile service). Cloudflare then processes the IP address and the technical browser and device data needed to tell a person from a program – on our behalf as a processor, and, as regards improving its own bot detection, as an independent controller under its own privacy policy. We do not send Cloudflare the player name or the UUID. A player who does not open that page is not connected to Cloudflare.
6. Data may be disclosed to authorised public authorities (for example the police or a prosecutor) where the law requires it, in particular in connection with attacks on the protected infrastructure.
7. Beyond the cases described above we do not share data with anyone else.

1. Our infrastructure is located in the European Economic Area and we do not transfer data to third countries on our own initiative.
2. Game account verification by Mojang Studios / Microsoft and delivery of notifications to Discord (section 7) are performed by those companies as independent controllers, under the terms and safeguards set out in their privacy policies, including standard contractual clauses. The same applies to Cloudflare, Inc. as regards browser verification: the company is based in the United States, and the transfer takes place under the terms and safeguards set out in its data protection documents, including standard contractual clauses.

1. Detailed retention periods for each purpose are set out in the table in section 4.
2. IP addresses of legitimate connections are not stored – they exist only in the shield’s working memory for the duration of the connection and shortly afterwards. The exception is the confirmation of a passed browser verification (section 5), which is kept for up to 7 days.
3. Panel account data is kept until the account is deleted. When an account is deleted, the organisation’s data is deleted with it unless the law requires longer retention.
4. Backups are overwritten cyclically and kept for no longer than 30 days. Data deleted on request disappears from backups by the end of that period at the latest.
5. After the retention period expires, data is permanently deleted or anonymised.

1. In connection with the processing of your data you have the following rights:
   1. access (Art. 15 GDPR) – information on whether and what data we process, and a copy of that data;
   2. rectification (Art. 16 GDPR) – in practice this concerns account data and gameplay data; the player name and UUID are managed by the game provider;
   3. erasure (Art. 17 GDPR) – we will delete account data and the data linked to your UUID and player name. IP addresses of legitimate connections are not stored, so they cannot be looked up and deleted on request – they are deleted automatically. We will not delete a permanent-ban record or security log entries while overriding legitimate grounds for keeping them exist (Art. 17(1)(c) in conjunction with Art. 21(1) GDPR), such as protecting the server against a repeat attack;
   4. restriction of processing (Art. 18 GDPR);
   5. data portability (Art. 20 GDPR) – for data processed on the basis of the agreement, in a commonly used machine-readable format;
   6. objection (Art. 21 GDPR) – to processing based on legitimate interest; we will comply unless we demonstrate overriding grounds (for example an ongoing attack from the address concerned).
2. To exercise your rights, e-mail contact@lumin.edu.pl and state your player name or the e-mail address of your panel account. We may ask you to confirm that you own the account – for example by performing a specified action after logging in to the server, or by writing from the e-mail address linked to the account.
3. We reply without undue delay and at the latest within one month of receiving the request (Art. 12(3) GDPR). In complex cases this may be extended by a further two months, in which case we will inform you and give the reason.
4. You have the right to lodge a complaint with the supervisory authority: the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, Poland, uodo.gov.pl.

1. We apply data minimisation: we process only what is needed to run and protect the service, and players’ IP addresses – as a rule – only in volatile memory.
2. The filtering shield is separated from the actual game servers, so they are never directly exposed to Internet traffic.
3. Only the Controller has access to the infrastructure, through authenticated and encrypted channels. Software is kept up to date.
4. Panel passwords are stored only as hashes and the connection to the panel is encrypted (HTTPS). API keys are shown in full only at the moment they are created.
5. Security logs are rotated automatically and deleted when the retention period expires.
6. Transmission between the game client and the server follows the Minecraft game protocol; for genuine accounts the game session is encrypted.

1. Minors may use the protected servers with the knowledge of their legal guardians. We do not collect data that would reveal a player’s age and we direct no marketing content at children.
2. We do not base the processing of player data on consent, so the conditions for a child’s consent (Art. 8 GDPR) do not apply. The client panel is intended for people who can enter into a service agreement on their own behalf.
3. Legal guardians may contact us about any matter concerning a child’s data at contact@lumin.edu.pl.

1. This website uses no analytics, advertising or tracking tools.
2. We use only technically necessary cookies: one that remembers the language you chose and – after you sign in to the client panel – a session cookie that keeps you signed in. They are necessary to provide the service and therefore require no separate consent.
3. The site’s fonts, scripts and images are served from our own infrastructure. During your visit we do not connect you to external content delivery networks. The exception is the player verification page, which loads the Cloudflare Turnstile script from Cloudflare’s servers (section 7).

1. We may update this Policy when the law, the way the service operates or the security measures we use change. The current version is always available on this page together with the date of the last update.
2. We will announce significant changes in the panel or on this page with reasonable notice.
3. This Policy is effective from 18 September 2026. Version 1.1 of 21 September 2026 adds the description of browser verification (Cloudflare Turnstile). Version 1.2 of 12 October 2026 describes who is asked for that verification, how the country of an IP address is determined and the player name kept for suspicious addresses.