Privacy Policy

Effective date / Last updated: 2026-11-06

1. Operator and scope

HONG KONG THOMAS TRADE LIMITED, RM C20, BLK C, 3/F, EAST SUN INDUSTRIAL CENTRE, 16 SHING YIP STREET, KWUN TONG, HONG KONG, operates lumavedosolution at lumavedo.com and acts as the data user under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (PDPO) for the account, workspace and enquiry processing described here. Jurisdiction: Hong Kong SAR. This notice does not imply that the workspace serves advertisements, collects advertising audiences or runs conversion tracking.

2. Information we handle

We handle information provided when registering, updating a profile, saving campaign plans or contacting us: email address, company and optional contact details, country, address, password credentials and message or plan content. Passwords are stored as hashes. A session identifier maintains signed-in access. Requests necessarily transmit technical information such as network address and browser request details to service infrastructure. Do not include sensitive personal information or audience lists in campaign names or enquiries.

3. Purposes and applicable requirements

We use account and workspace details to provide the requested service, enquiry details to respond, and necessary information to administer and protect the service and meet legal obligations. Under the PDPO, personal data must be collected fairly for a lawful purpose directly related to these functions, be adequate but not excessive, and be used for the original purpose or a directly related purpose unless the required consent is obtained. Required registration fields are necessary to create an account; optional profile fields are voluntary. Any future direct marketing use or provision of personal data must meet the notice, consent and opt-out requirements of Part 6A of the PDPO. You may ask us to stop direct marketing without charge. Where other applicable laws require a lawful basis or consent, those requirements also apply.

4. Recipients

Information is used for service administration and handling enquiries. If hosting or support providers are engaged, disclosure should be limited to the necessary purpose with appropriate protections. Information may be disclosed where required by law, necessary for lawful claims or directed by you. This notice does not assert an active relationship with media suppliers or advertising measurement partners.

5. Cookies and electronic communications

The service uses a necessary session cookie for authentication. Optional cookies, browser storage or electronic marketing, if introduced, must comply with applicable law and obtain consent where required. Optional technologies must not be enabled without the required choice. Manage cookies through your browser or contact privacy@lumavedo.com about preferences. Blocking necessary cookies may prevent sign-in.

6. Security and retention

Measures designed to protect personal data include password hashing and account access controls. No storage or transmission method is absolutely secure. Information should be retained only as needed to operate the service, handle requests, resolve disputes or meet legal obligations, then deleted or de-identified when no longer required. You may request account closure or deletion.

7. Your rights and complaints

Under the PDPO, you may make a data access request and request correction of inaccurate personal data, subject to applicable conditions and exemptions. Contact privacy@lumavedo.com or write to the company address above. We may need proportionate identity verification and will respond as required by law. You may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD). Where other applicable laws provide rights to deletion, restriction, portability or objection, we handle those requests in accordance with those laws.

Where other data protection laws apply to particular processing, including the EU GDPR or US state privacy laws such as CCPA/CPRA, we handle requests in accordance with those laws. This conditional statement does not claim that every law applies to every user or replace any required choices or notices.

8. International processing

This notice does not state that cross-border processing is currently taking place. If a proposed arrangement involves a restricted international transfer, it must meet applicable legal requirements before the transfer, including appropriate contractual protections, assessments or other permitted safeguards where required. Contact us for information relevant to your data.

9. Children and policy updates

The workspace is intended for business use and is not directed to children. We may update this notice to reflect the service and legal requirements with appropriate notice of material changes.

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