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Privacy Policy

1. Introduction

LUMINATALES NETWORK LIMITED ("we" or "the Company") respects and protects your privacy. This Privacy Policy explains how we collect, use, disclose and protect your personal data provided through our application ("the Application"). Please read this policy carefully to understand our data processing practices.

This policy complies with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Hong Kong Personal Data (Privacy) Ordinance, and other applicable privacy laws and regulations.

2. Information We Collect

We may collect the following types of personal data:
• Identity Data: name, email address, phone number, date of birth
• Account Data: username, password, account settings
• Technical Data: IP address, device information, browser type, operating system
• Usage Data: app usage, browsing history, interaction records
• Location Data: approximate location based on IP address
• Transaction Data: purchase history, subscription details, payment information

3. How We Collect Data

We collect your data through:
• Direct Interactions: when you register an account, fill out forms, or contact us
• Automated Technologies: through cookies, server logs, and similar technologies when you use our application
• Third Parties: we may receive data from business partners, social media platforms, or public sources

4. How We Use Your Data

We use your personal data for the following purposes:
• Providing and managing our services
• Processing transactions and subscriptions
• Personalizing your experience and content recommendations
• Improving our application and services
• Communicating with you and responding to your inquiries
• Sending relevant marketing information (if you opt-in)
• Preventing fraud and ensuring security
• Complying with legal obligations

5. Data Sharing and Disclosure

We may share your personal data with:
• Service Providers: third parties who help us operate the application, process payments, or provide customer support
• Business Partners: companies we partner with to provide specific services or promotions
• Legal Requirements: when required by law or to protect our rights
• Corporate Transfer: if we are involved in a merger, acquisition, or asset sale

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:
• Encryption of data in transit and at rest
• Regular security assessments and testing
• Access controls and authentication
• Employee training and confidentiality agreements

7. Your Privacy Rights

You have the following rights:
• Right of Access: obtain a copy of your personal data that we hold
• Right to Rectification: request correction of inaccurate or incomplete data
• Right to Erasure: request deletion of your personal data in certain circumstances
• Right to Restrict Processing: limit our processing of your data in certain circumstances
• Right to Data Portability: receive your data in a structured, commonly used, and machine-readable format
• Right to Object: object to our processing of your personal data
• Right to Withdraw Consent: withdraw any consent you have previously given

8. Cookie Policy

We use the following types of cookies:
• Essential Cookies: necessary for basic application functionality
• Analytics Cookies: help us understand how users interact with our application
• Functional Cookies: remember your preferences
• Advertising Cookies: deliver relevant advertising and marketing content

9. Children's Privacy

Our application is not intended for children under 16. We do not knowingly collect personal data from children under 16. If you discover that we may have collected data from a child, please contact us immediately, and we will take steps to delete such information.

10. Contact Us

If you have any questions about this Privacy Policy or need to exercise your privacy rights, please contact us:
• Email: contact#kushort.com
• Phone: +852 95170326
• Address: RM 1202, FLAT A, 12/F,EFFICIENCY HOUSE, 35 TAI YAU STREET, SAN PO KONG, HONG KONG

Last Updated: April 28, 2025