1. Controller and scope
The controller responsible for the processing described in this policy is Giuseppe Somma, operating under the name GS-Soft, in Italy. For support and privacy requests: info@gs-soft.it.
Lumen Emu is a free emulator that lets users run homebrew and other compatible content they are authorised to use. You do not need to provide payment information to use the app. The project develops optimised ports for Android, iOS and Mac with Apple Silicon; this policy covers the Android app intended for Google Play, with the features described as of the date above, and related support requests.
You do not need to register for a GS-Soft service. Any profiles or usernames within the emulated environment are local data and do not create an online account with GS-Soft.
2. Data processed on your device
To organise your library and run selected content, the app accesses or generates the following data on your device:
- Content files and metadata: homebrew content and other compatible files, folders and paths, titles, content identifiers, versions, platform and images contained in local files.
- Saved games and settings: progress, local profiles, emulator and core preferences, control and graphics settings, caches and shaders. Saved games and profiles may contain names or other data entered in the software being run.
- Controls and text: touchscreen, controller and keyboard input, and text entered in dialogs, used to interact with the app and emulated content.
- Technical information: device and Android environment characteristics, chipset, GPU and drivers, where needed to configure and run emulation.
- Local diagnostics: startup and error logs; diagnostic options may produce more detailed logs and dumps. These may include file paths, content titles or identifiers, technical information and output from the software being run.
The current Android app does not request Internet access permission and does not automatically send this data to GS-Soft. It does not include advertising SDKs, usage analytics services or automatic crash reporting services. It does not use advertising identifiers to track you. Library images are read from local content.
3. Android permissions
All files access. The current version requests Android’s special permission to manage files in shared storage, so that you can select, read and manage content folders used by the emulator. The library is built from the folder you choose. However, the permission granted by the system is broader than the selected folder alone and remains subject to Android’s protection limits.
You can deny or revoke this permission in the app’s Android settings, under special access or all files access. Without it, features that need to read or manage that content may not work.
Vibration. The app uses vibration for control feedback where supported. It does not request access to your location, contacts, camera or microphone.
4. Importing, exporting and services you choose
You can import or export saved games in ZIP archives through Android’s document picker. You choose the source or destination. If you select a cloud service or another document provider, that service may receive, store or synchronise the archive and the data it contains, according to its own settings and privacy policy.
These operations take place at your request and are not an automatic upload to GS-Soft servers. Before sharing an archive, consider that it may include progress, profiles and data entered in the emulated content. Android, Google Play and external services you choose are operated by their respective providers.
5. Support emails and website visits
If you write to info@gs-soft.it, we receive your email address, any associated name, the message content, the attachments you choose to send and the technical information needed to deliver the email. This data is used to reply, provide support and resolve the reported problem. The app does not send emails or attachments automatically.
Providing this data is optional; without contact details or the necessary information, we may be unable to reply or provide the support you request. Before sending logs or images, remove unnecessary personal data. Do not send passwords, keys, credentials or copies of games.
The gs-soft.it website and support mailbox use hosting and email services provided by OVHcloud (OVH). When you visit this page, the hosting service receives technical data such as your IP address, date and time, the requested address and information sent by your browser, needed to deliver the page and manage security and service logs. This page does not set analytics, advertising or profiling cookies and does not load third-party tracking tools. See also the website privacy policy.
6. Purposes and legal bases
Where the data described constitutes personal data, the applicable legal bases under Regulation (EU) 2016/679 (GDPR) are:
- Providing requested features and support: performance of the service requested by the user or related pre-contractual measures, to the extent necessary (Article 6(1)(b)).
- Handling other requests, protecting the website and email, and diagnosing reported problems: GS-Soft’s legitimate interest in keeping the service secure and working and responding to users, taking their rights into account (Article 6(1)(f)).
- Complying with legal obligations: where a rule requires specific processing or retention (Article 6(1)(c)). Establishing, exercising or defending rights, where necessary, is based on the corresponding legitimate interest.
Android’s file permission is a technical control over device access and does not authorise content to be sent to GS-Soft. We do not use this data for marketing or profiling, and we do not make decisions based solely on automated processing that produce legal or similarly significant effects on you.
7. Recipients and transfers
GS-Soft does not sell or rent personal data and does not send your library to advertisers. Data that remains in the emulator is not accessible to GS-Soft through a remote app service.
For the website and support, data may be processed by the controller, OVHcloud and the technical providers involved in hosting and email services, according to their respective roles and applicable agreements. It may be disclosed to authorities where required by law or to advisers where strictly necessary to protect rights. Email or document providers you choose also process data under their own terms.
The location of data and any transfers associated with hosting, email and their subcontractors depend on the OVHcloud services used. The Italian DPA published by OVHcloud governs transfers and, where provided for, the use of European standard contractual clauses. Any transfers of data processed on behalf of GS-Soft outside the European Economic Area must comply with the GDPR, based on an adequacy decision or appropriate safeguards, where applicable. You can request information about relevant recipients and safeguards by writing to info@gs-soft.it.
8. Retention and deletion
Data on your device
Local data remains available for as long as it is needed to use the app or until you delete it. You can delete saved games using the app’s dedicated feature. Removing content from the library does not automatically delete its saved games and other runtime data; deleting saved games is a separate operation.
To delete all internal Lumen Emu data, you can use Android’s option to clear the app’s data or storage, or uninstall it. Clearing the cache alone is not the same as deleting all data. Content in shared storage, exported archives and copies held by cloud services remain separate: you must delete them from their respective folders or chosen services.
The app is configured to exclude its own data from cloud backup and automatic device transfer managed by Android’s backup rules. This does not prevent voluntary exports or copies made by external tools or services you choose to use.
Email and website data
We retain support requests and attachments for as long as necessary to handle the request and any related follow-up. Further retention is limited to documented needs arising from legal obligations, security or disputes; when no longer needed, data is deleted or anonymised. Technical website and email data is retained according to the service’s retention cycles, limited to service delivery, security needs and applicable obligations.
You can request information about the retention periods applicable to your request, or ask for deletion of data received by GS-Soft, by writing to the privacy contact. There is no Lumen Emu account with GS-Soft to close. We cannot remotely delete files on your device or in cloud services you choose.
9. Data security
Preferences and internal runtime data are stored in the app’s private storage managed by Android. Access to shared files depends on system permissions. Protection of your device, cloud accounts and exported copies also depends on the settings and services you use; an exported ZIP archive is not automatically protected by an emulator password.
Access to data received for support is limited to what is needed to handle the request and to the providers necessary for email and hosting. There is no automatic upload service for emulator logs or files. Avoid emailing unnecessary confidential information.
10. Your rights
Where provided for by the GDPR, you can request access, rectification, erasure, restriction of processing and data portability. You can object to processing based on legitimate interests on grounds relating to your particular situation. To exercise your rights, write to info@gs-soft.it, stating that your request concerns Lumen Emu and providing only the information needed to identify it.
We will respond within the time limits set by law; where necessary, we may request proportionate information to verify your request. You can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or the competent supervisory authority where you live or work. These rights concern data actually processed by GS-Soft; for local data, you can use the features described in the deletion section.
11. Changes and contact details
We will update this policy when the app’s features or the processing described change, and indicate the new date. Any new data collection or sharing will be explained before it is enabled, with the information and permissions required by law and platform rules.
Giuseppe Somma · GS-Soft
Lumen Emu privacy and support: info@gs-soft.it.