Privacy Policy

Introduction

LunarShifting SARL ("we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our financial services. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

Data Controller Information

LunarShifting SARL is the data controller for the purposes of the General Data Protection Regulation (GDPR). We are registered in Luxembourg under company registration number RCSB462891, with our registered office at Avenue de la Liberté 66, 4270 Differdange, Luxembourg.

Data We Collect

The data collection we undertake includes various types of personal information that you provide to us directly or that we collect automatically when you use our services. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: First name, last name, title, date of birth, and other identification information
• Contact Data: Email address, telephone numbers, billing address, and delivery address
• Financial Data: Bank account details, payment card details, investment information, income details, and financial objectives
• Transaction Data: Details about payments to and from you and other details of services you have purchased from us
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system and platform
• Usage Data: Information about how you use our website and services
• Marketing Data: Your preferences in receiving marketing from us and your communication preferences

How We Use Your Information

We will only use your personal data when the law allows us to. How we use your information depends on the service you use and how you use it. Most commonly, we will use your personal data in the following circumstances:

• To provide and maintain our financial advisory services
• To process and manage your investments and financial planning
• To comply with legal and regulatory requirements
• To communicate with you about your account and services
• To improve our website and services
• To send you marketing communications (with your consent)
• To detect and prevent fraud and other financial crimes

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our cookie usage, please refer to our Cookie Policy.

Legal Basis for Processing

Under GDPR, we will only process your personal data where we have a lawful basis to do so. The legal bases we rely on include:

• Contract: Processing is necessary for the performance of a contract with you
• Legal Obligation: Processing is necessary for compliance with a legal obligation
• Legitimate Interest: Processing is necessary for our legitimate interests (or those of a third party)
• Consent: You have given clear consent for us to process your personal data for specific purposes

Data Sharing and Disclosure

We may share your personal information with third parties in the following circumstances: with service providers who assist us in delivering our services, with regulatory authorities as required by law, with our professional advisors including lawyers and auditors, and with other third parties where we have your consent or where permitted by law. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

International Transfers

Some of our external third parties are based outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: adequacy decisions, appropriate safeguards such as standard contractual clauses, or binding corporate rules.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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 unauthorised use or disclosure, the purposes for which we process your personal data, and applicable legal requirements. In some circumstances, we may anonymise your personal data for research or statistical purposes.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Right to access: Request access to your personal data
• Right to rectification: Request correction of inaccurate personal data
• Right to erasure: Request deletion of your personal data
• Right to restrict processing: Request restriction of processing of your personal data
• Right to data portability: Request transfer of your personal data
• Right to object: Object to processing of your personal data
• Right to withdraw consent: Withdraw consent where we rely on consent to process your personal data

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise any of your rights, please contact us using the following details:

Complaints

You have the right to make a complaint at any time to the Commission Nationale pour la Protection des Données (CNPD), the Luxembourg supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the CNPD, so please contact us in the first instance.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on our website and updating the "Last updated" date at the top of this policy. Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.