PRIVACY POLICY

1. Introduction

Lunara Partners Limited ("Lunara Partners," "we," "us," or "our") is committed to safeguarding your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website (lunarapartners.com) or otherwise interact with us (the "Services").

By accessing the Services, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with this Privacy Policy, please discontinue use of the Services.

2. Data Controller

For the purposes of the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the Cayman Islands Data Protection Act:

Data Controller:

Lunara Partners Limited

Incorporated in the Cayman Islands

For all privacy-related inquiries:

Email: [email protected]

3. Information We Collect

3.1 Personal Information You Voluntarily Provide

We may collect personal data you choose to provide, including:

• Name and contact details (email, phone number, mailing address)
• Professional information (company name, job title, business profile)
• Investment-related preferences (areas of interest, accreditation status if voluntarily disclosed)
• Communications and interactions with us
• Newsletter subscription details

3.2 Information Automatically Collected

When you use our Services, we may automatically collect:

• Log data (IP address, browser type, pages visited, date/time of access)
• Device information (device type, operating system, identifiers)
• Cookies, pixels, and other tracking technologies
• Analytics, usage patterns, and browsing behavior

3.3 Information We Do Not Collect Through the Website

We do not collect via this website financial information, payment details, government-issued IDs, AML/KYC documentation, or sensitive personal data. Any such information, if required during a fund subscription process, is collected offline or through secure investor portals, not through this website.

4. Legal Bases for Processing (GDPR)

We process personal data under the following legal bases:

• Consent - e.g., when you subscribe to newsletters or marketing updates
• Legitimate Interests - including improving our website, analytics, preventing misuse, responding to inquiries, maintaining business relationships
• Performance of a Contract - when responding to requests you initiate
• Compliance with Legal Obligations - e.g., sanctions screening, record-keeping

5. How We Use Your Information

We use personal data for:

• Providing, maintaining, and improving the Services
• Responding to inquiries, requests, or communications
• Sending newsletters and updates (with your consent)
• Understanding website usage and improving user experience
• Detecting or preventing security incidents or misuse
• Complying with laws and regulatory obligations
• Facilitating information flows relating to potential investment opportunities for qualified investors

6. Cookies and Tracking Technologies

We use cookies, pixels, tags, and similar technologies to:

• Understand how users interact with the website
• Improve functionality and performance
• Personalize content
• Support analytics and marketing

You may manage your cookie preferences through your browser settings or through our Cookie Policy.

Our Services do not currently respond to "Do Not Track" signals.

7. Marketing Communications

Where you have provided consent, we may send you newsletters or updates.

You may withdraw consent at any time by clicking "unsubscribe" or by emailing us at [email protected].

Withdrawal does not affect the lawfulness of processing prior to withdrawal.

8. Disclosure of Your Information

We may share personal data with:

• Service Providers: Including hosting providers, analytics tools (such as Google Analytics or similar), email service providers, and IT support.
• Business Partners: Strictly as needed to explore or facilitate potential investment opportunities.
• Legal and Regulatory Authorities: If required by law, regulation, or legal proceedings.
• Corporate Transactions: In the event of a merger, reorganization, or asset transfer.
• With Your Consent: When you direct us to share information.

9. International Data Transfers

Your data may be transferred to and stored in jurisdictions including the Cayman Islands, UAE, EU, UK, and the United States.

Where required, transfers are made using appropriate safeguards, including:

• Standard Contractual Clauses (SCCs)
• Equivalent legal protections
• Contractual obligations with third-party processors

10. Data Security

We implement technical and organizational measures to protect personal data. However, no system is completely secure, and we cannot guarantee absolute security.

11. Data Retention

We retain personal data only as long as necessary for the purposes described or as required by applicable law.

12. Your Rights Under GDPR

Depending on your location, you may have the right to:

• Access your personal data
• Request correction
• Request deletion
• Object to or restrict processing
• Data portability
• Withdraw consent

To exercise these rights, contact us at [email protected].

We may request identity verification and may refuse requests where legally justified.

13. Third-Party Links

The website may link to third-party websites, including portfolio companies. We are not responsible for their privacy practices.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Material changes will be communicated through email or prominent notice on the website.

15. Contact Us

For any privacy inquiries: