Privacy Policy
Last Updated: April 18, 2024
Welcome to Lumin! We are committed to protecting your privacy and securing your data. This privacy policy (“Privacy Policy”) is applicable to PROMINENTWISE LIMITED (“Lumin” or “we” or “us”) and explains how Lumin collects, uses, and shares your personal data, and how you can manage this information. We handle your personal data (which shall be construed in accordance with the definition of the Privacy Ordinance) in compliance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Privacy Ordinance”).
Please read this Privacy Policy carefully to understand our policies and practices regarding the handling of personal data you provided to us on this Site. By using this site or our services or providing personal data to us, you consent to the collection, use and disclosure of your personal data in accordance with this Private Policy.
1. Information Collection
1.1 Registration and Account Information
When you create a Lumin account, we collect personal data such as your name, email address, contact number, residential address, and date of birth. Additionally, we may require you to provide a copy of your government-issued identification to meet our identity verification requirements.
1.2 Transaction and Usage Information
To provide and optimize our services, we collect information related to your Bitcoin transactions, including transaction amounts, wallet addresses, and transaction timestamps. We also record your interactions with the Lumin platform, such as access frequencies and query types.
1.3 Device and Technical Information
We gather information about the device you use to access our services, including your IP address, operating system, browser type and version, and device identifiers. This information helps us ensure the security of our platform and adapt our services to varied device displays.
2. Information Usage
We use the information collected to:
- Provide, maintain, and improve our services;
- Process your transactions and send transaction notifications;
- Verify your identity to comply with legal and regulatory requirements;
- Communicate with you, address your inquiries, and send important service and administrative notices;
- Conduct internal audits;
- Plan our business and improving the services we provide to you;
- Conduct customer service surveys, market research, statistical analysis and behavioral analysis;
- Fulfill our obligations to comply with the legal and regulatory obligations, such as requests from relevant governmental, regulatory, law enforcement, judicial and other public authorities in or outside Hong Kong or any person to whom we are under an obligation to disclose information;
- Enable us to detect or prevent fraud or crime and for other legal and administrative purposes such as enforcing or protecting our legal rights; and
- other purposes directly relating to the activities identified above.
We would not use your personal data for direct marketing purposes including sending news, offers, and promotional purposes without your consent.
3. Information Sharing
3.1 Group Companies and Service Providers
We may share your information to our affiliates (including our holding companies, subsidiaries and affiliates), and their employees who need to know this information, and any other persons under a duty of confidentiality to us, including our professional advisers.
We may collaborate with third-party service providers who help us deliver the Lumin services, such as data storage, maintenance services, analysis, and customer support. We authorize these third parties to process your information only as necessary and require them to comply with privacy protection standards.
3.2 Legal Requirements and Security
We may share your information if legally required or for security purposes (including requests from law enforcement). We may also share information with your consent, or for purposes of fraud prevention and risk reduction.
3.3 Business Transfers
In any reorganization, merger, sale, joint venture, or other business transfer, we may transfer personal data we hold.
4. Data Transfer
4.1 Cross-Border Data Transfer
The information you provided may be transferred to a place outside Hong Kong for the purpose for which it was collected or a directly related purpose if operationally necessary. Please note that the privacy protection laws of such places may differ from those of Hong Kong, i.e. your personal data may not be protected to the same or similar extent as in Hong Kong. We take appropriate steps to protect personal data held and transmitted by us from loss, unauthorized access, use, modification or disclosure in accordance with the provisions of the Privacy Ordinance.
5. Information Security
We implement multi-layer security measures to protect your personal data from unauthorized access and disclosure. This includes data encryption technologies, security protocols, and physical security measures. We also regularly review and update our security policies and measures.
You may be linked from our website to other third party websites, and these websites may collect your information and other necessary information on their own, but please note that the privacy policies of such websites are likely to be different from ours. We recommend that you read the privacy policies of these websites before disclosing your personal data to them as we have no control over, and are not responsible for, how other third party websites handle your personal data.
6. Cookies Policy
Our comprehensive cookies policy elucidates the use of cookies on Lumin. By utilizing our sites, you consent to the policies delineated.
6.1 What are cookies ?
Cookies are small text files that are used to store small pieces of information. The cookies are stored on your device when the website is loaded on your browser. These cookies help us make the website function properly, make the website more secure, provide better user experience, and understand how the website performs and to analyze what works and where it needs improvement.
6.2 How do we use cookies ?
As most of the online services, our website uses cookies first-party and third-party cookies for a number of purposes. The first-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our websites are used mainly for understanding how the website performs, how you interact with our website, keeping our services secure, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
6.3 What types of cookies do we use ?
Essential Only: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal data. For example, these cookies allow you to log-in to your account and add products to your basket and checkout securely. We do not use any advertising and/or tracking cookies whatsoever.
7. Your Rights
Under the Privacy Ordinance, data subjects have the right to:
- Check whether we hold your personal data, the types of personal data held by us and the purposes for which the personal data are collected;
- Access a copy of your personal data held by us;
- Delete your personal data held by us;
- Request us to correct or supplement your personal data where it is found to be inaccurate;
- Restrict our processing of your personal data;
- Object to our continued use of your personal data for direct marketing purposes; and
- Enquire our policies on the storage of personal data from time to time.
If you wish to exercise any of the above rights in relation to personal data submitted to us, please submit a written request to us and we will endeavor to respond to your request within one month of receipt of your request. In accordance with the Privacy Ordinance, we reserve the right to charge you a reasonable fee for the relevant data access request. Please note that we may need to verify your identity in order to process your request.
8. Retention of personal data
Unless otherwise specified, your personal data will be retained for the period in accordance with our internal policies and applicable laws. We will only retain personal data for as long as is necessary to fulfill the purposes for which it was collected and will comply with any legal requirements that require us to retain your personal data for a specific period of time.
9. Policy Updates
We reserve the right to change, amend or otherwise update this Privacy Policy at our sole discretion at any time. Any changes will be posted on our website, and if the changes are significant, we will notify you by email or through a service notification. The effective date of this version appears at the beginning of the Privacy Policy. Your continued use of our website and/or our services after we have made the updates will be deemed to constitute acceptance of our Privacy Policy.
10. Contact Us
If you have any questions or concerns about this Privacy Policy or need to exercise your privacy rights, please
contact us at:
Email Address: hello@luminbitcoin.com