This Privacy Policy consists of two parts: Privacy Policy Statement ("PPS"), a general statement of our policies and practices in handling personal data; Personal Information Collection Statement ("PICS"), which sets out the notifications we are required to give you on or before collecting your personal data. This Privacy Policy applies to the platform and all related websites and services (the "Platform") operated by Luminai Technology Limited ("Luminai", "we", "us").
Luminai Technology Limited is a limited company incorporated in Hong Kong. We respect personal data privacy and are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the "PDPO"), including the six Data Protection Principles set out in Schedule 1 thereto.
We collect personal data only by lawful and fair means, for purposes directly related to the functions or activities of the Platform; the data collected is necessary but not excessive for those purposes; and we use personal data only for the purposes stated at collection or directly related purposes, unless we obtain your prescribed consent or as otherwise permitted by law.
We take practicable steps to ensure that the personal data we hold is accurate, and we do not keep personal data longer than is necessary to fulfil the purposes for which it was collected. In general, we retain your data for the duration of your account and thereafter for such period as required or permitted by law; certain transaction and identity verification data may need to be retained for statutory periods after account deregistration to comply with anti-money laundering, tax, and other legal obligations.
We take all practicable steps (including encrypted transmission, access controls, and security audits) to protect personal data against unauthorized or accidental access, processing, erasure, loss, or use. However, no transmission over the Internet can be guaranteed to be absolutely secure, and you are also responsible for safeguarding your account credentials.
Under the PDPO, you have the right to request access to the personal data we hold about you and to request correction of inaccurate data. We may charge a reasonable fee for processing a data access request. Please submit requests via the contact details in Section 7; we will respond within the time limits prescribed by the PDPO.
We may revise this Privacy Policy from time to time. Revised versions will be published on the Platform; material changes will be separately notified to you by reasonable means.
If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact: Company: Luminai Technology Limited | Email: lighthouse@mangolabs.org
Account information: Twitter/X username, user ID, email address, login credentials;
Profile information: bio, social media links, avatar;
Content data: content you publish, ratings, comments, and interactions you provide;
Usage data: IP address, browser type, device information, access times, pages viewed;
Transaction data: order history, payment and refund records, settlement records, billing information, (for KOL settlement) receiving bank account details, and (for Business Buyers paying by bank transfer) remitting bank account details;
Identity verification data: government-issued identity documents, proof of residential address, selfie/liveness verification images, and other documents submitted for KYC/AML compliance purposes (and, for business Buyers, business registration and beneficial ownership information);
Risk and compliance data: sanctions screening results, politically exposed person (PEP) screening results, adverse media screening results, and fraud risk scoring data;
Device and security data: device fingerprints, approximate geolocation, login patterns, and behavioural analytics used for fraud detection and Platform security;
Communication data: messages sent through the Platform, support tickets.
Payment card data: your card number, expiry date, and verification code are collected and processed directly by our third-party payment service providers (including Airwallex) during the transaction and are subject to their privacy policies (see https://www.airwallex.com/terms/privacy-policy). We do not collect or store your full card number or card verification code.
We use the personal data collected for the following purposes:
Providing and improving Platform services, including account registration, order matching, and fulfilment;
Processing order payments, refunds, settlements, and withdrawals (through third-party payment service providers);
Conducting identity verification, anti-money laundering and sanctions compliance reviews, fraud prevention, and Platform security;
Calculating points and maintaining user rankings;
Communicating with you regarding your account, orders, and services;
Handling disputes, chargebacks, and complaints;
Analyzing usage patterns to improve user experience;
Complying with obligations under applicable laws and regulations (including lawful requests from regulators and law enforcement).
The provision of data marked as mandatory (including identity verification data and bank details required for settlement) is voluntary but necessary for the relevant services; if you do not provide such data, we may be unable to complete your registration, payment, settlement, or withdrawal.
We do not sell your personal data. Your personal data may be transferred or disclosed to the following classes of transferees:
Payment service providers: including Airwallex and its affiliated entities, for processing payments, refunds, and settlements, fraud prevention, and their own statutory compliance obligations;
Service providers assisting Platform operations: such as cloud hosting, identity verification/KYC, data analytics, and customer support vendors, who may process data solely for the purpose of providing services to us and are bound by confidentiality and data protection obligations;
Brand partners: limited to information necessary for completed promotional tasks;
Regulators, law enforcement, or other government authorities: where required by law or necessary to establish, exercise, or defend legal rights;
Professional advisers: such as legal, accounting, and audit advisers, to the extent necessary for their services;
Other users: limited to profile information you choose to make public;
Parties to corporate transactions: in the event of a merger, acquisition, or asset transfer, subject to appropriate safeguards.
Your personal data may be transferred to, stored, or processed in jurisdictions outside Hong Kong (including jurisdictions where our service providers and payment service providers are located). We will take reasonable measures (including contractual safeguards) to ensure that transferred data receives a level of protection commensurate with this Policy.
Unless we have obtained your consent (including an indication of no objection), we will not use your name and contact details to send you direct marketing communications (such as promotional emails about Platform campaigns or service updates). We will not provide your personal data to third parties for direct marketing purposes without your written consent. You may at any time, free of charge, request that we cease using your data for direct marketing by using the unsubscribe link in our communications or contacting the email address in Section 7, and we will comply with your request in accordance with the law.
We use cookies and similar technologies to maintain login sessions, remember preferences, perform security verification, and conduct statistical analysis. You may manage or disable cookies through your browser settings, but some Platform features may not function properly as a result.
Subject to the PDPO and other applicable laws, you have the right to:
Request access to, and copies of, the personal data we hold about you (a reasonable fee may apply);
Request correction of inaccurate personal data;
Request deletion of your account and associated data (subject to statutory retention obligations);
Opt out of direct marketing at any time;
Where applicable, object to certain processing or request export of your data in a portable format.
To exercise these rights, please contact us using the details in Section 7.
The Platform is not directed at persons under 18 years of age. We do not knowingly collect personal data from minors; if we become aware of such collection, we will delete the relevant data as soon as practicable.
If you have any questions or complaints about how we handle personal data, please first contact us using the details in Section 7.