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General Data Protection Regulation (GDPR) Compliance

Last Updated: June 5, 2025

This GDPR Compliance Notice supplements the information contained in our Privacy Policy and applies to individuals in the European Economic Area (EEA). We adopt this notice to comply with the General Data Protection Regulation (GDPR) and to inform you about how we process your personal data and your rights under the GDPR.

1. Data Controller

For the purposes of the GDPR, the data controller for the personal data we process is:

Lunar Bay Group Limited
Room 602, 6/F, Kai Yu Commercial Building
2C Argyle Street, Mongkok, Kowloon
Hong Kong

Email: [email protected]

2. Legal Basis for Processing

We process your personal data on the following legal bases:

2.1 Consent

When you have given us explicit consent to process your personal data for specific purposes, such as sending you marketing communications or processing certain types of sensitive data.

2.2 Contractual Necessity

When processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, such as providing our Service after you have signed up for an account or processing payments for premium features.

2.3 Legitimate Interests

When processing is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include:

  • Improving and personalizing our Service
  • Ensuring the security of our Service
  • Conducting business analytics and research
  • Marketing our products and services
  • Preventing fraud and abuse

2.4 Legal Obligation

When processing is necessary for compliance with a legal obligation to which we are subject.

2.5 Vital Interests

When processing is necessary to protect your vital interests or the vital interests of another person.

3. Your Rights Under the GDPR

If you are located in the EEA, you have the following rights with respect to your personal data:

3.1 Right to Access

You have the right to request a copy of the personal data we hold about you and information about how we process it.

3.2 Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

3.3 Right to Erasure (Right to be Forgotten)

You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, you withdraw your consent, or we have processed the data unlawfully.

3.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to our processing based on legitimate interests.

3.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from us, where technically feasible.

3.6 Right to Object

You have the right to object to our processing of your personal data based on legitimate interests, including profiling. You also have the right to object to our processing of your personal data for direct marketing purposes.

3.7 Right to Withdraw Consent

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your consent before its withdrawal.

3.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data infringes the GDPR. The supervisory authority will be in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

4. How to Exercise Your Rights

To exercise any of your rights under the GDPR, please contact us at [email protected]. We will respond to your request within one month. This period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

5. International Data Transfers

We may transfer your personal data to countries outside the EEA. When we do so, we ensure that appropriate safeguards are in place to protect your personal data, such as:

  • Transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Using specific contracts approved by the European Commission that give personal data the same protection it has in Europe (Standard Contractual Clauses).
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. However, we may use automated processing, including profiling, to analyze your preferences and interests to personalize your experience with our Service and to provide you with more relevant content and features.

8. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this GDPR notice and our processing of personal data. If you have any questions about this notice or how we handle your personal data, please contact the DPO at [email protected].

9. Changes to This GDPR Notice

We may update this GDPR notice from time to time. When we make changes to this notice, we will post the updated notice on our website and update the notice's effective date. We encourage you to review this notice periodically to stay informed about how we are protecting your personal data.

10. Contact Us

If you have any questions about this GDPR notice or our privacy practices, please contact us at:

Email: [email protected]

Address: Room 602, 6/F, Kai Yu Commercial Building, 2C Argyle Street, Mongkok, Kowloon, Hong Kong

Last Updated: June 5, 2025

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Contact: [email protected]

Address: Room 602, 6/F, Kai Yu Commercial Building, 2C Argyle Street, Mongkok, Kowloon, Hong Kong