LUNAVI PRIVACY POLICY

Last updated: November 10, 2025

Controller: Lunavi Agency — Espoo, Finland

Contact: support@lunavi.app

This Privacy Policy explains how Lunavi (“we”, “us”, “our”) collects, uses, and protects personal

data through the Lunavi mobile application and related services.

Lunavi complies with the EU General Data Protection Regulation (GDPR) and Finnish data

protection law.

1. Overview

• Lunavi collects only the personal data necessary to operate and manage the influencer platform.

• We do not collect or store any technical or analytical data such as IP addresses, device

identifiers, app versions, or error logs.

• Only influencers register in the app.

• Clients do not create accounts through the app.

• Influencers may see a client’s business name and event location related to collaborations — no

other client data is shared.

2. Information We Collect

When you register or use the Lunavi app as an influencer, we collect the following personal data:

• Full name

• Username

• Email address

• Phone number (required for verification and communication)

• Country and city

• Date of birth (DOB)

• About me (short biography)

• Allergies (optional)

• Social media accounts or links

• Chosen interest categories

Information visible to clients:

• Name

• About me

• Allergies

• Social media accounts

• Chosen interest categories

All other details — such as email, phone number, username, date of birth, country, and city —

remain private and are not visible to clients.

3. Purpose of Processing

We process influencer data strictly for:

• Creating and managing user accounts.

• Facilitating collaborations and displaying limited influencer details to clients.

• Displaying client business names and event locations to influencers during collaborations.

• Communicating with influencers about their accounts or related events.

• Meeting legal or contractual obligations.

4. Legal Basis for Processing

Format: Purpose, Legal Basis

Account creation and management

Contract (Art. 6(1)(b) GDPR)

Displaying influencer details to clients

Legitimate interest (Art. 6(1)(f) GDPR)

Showing client business name and event location to influencers

Legitimate interest (Art. 6(1)(f) GDPR)

Phone verification and communication

Contract / Legitimate interest

Legal compliance

Legal obligation (Art. 6(1)(c) GDPR

5. Data Sharing

We only share influencer data when necessary to operate Lunavi, with:

• Hosting providers maintaining secure cloud infrastructure.• Payment providers (if used), such as Paytrail, MobilePay, Stripe, or PayPal. Lunavi does not

store payment card data.

We do not sell or share personal data for advertising or unrelated marketing purposes.

6. Data Retentionr

• Personal data is retained for as long as your influencer account is active.

• If you delete your account, all personal data is permanently erased unless retention is required

by law (e.g., for accounting).

7. Your Rights

Under the GDPR, you have the right to:

• Access your personal data.

• Request correction or deletion.

• Restrict or object to processing.

• Request data portability.

• File a complaint with the Data Protection Ombudsman in Finland.

Requests may be sent to support@lunavi.app.

8. Data Security

Lunavi uses secure servers, encryption, and restricted access to protect stored information.

Because we do not collect technical or tracking data, the risk of profiling or hidden monitoring is

minimized.

9. Children

Lunavi is designed for users aged 18 years and older.

We do not knowingly collect or store data from minors.

10. International Data Transfers

If any data is transferred outside the European Economic Area (EEA), Lunavi applies EU Standard

Contractual Clauses (SCCs) or equivalent safeguards to ensure lawful and secure processing.

11. Updates to This Policy

Lunavi may update this Privacy Policy periodically.

All updates will be published in the app and on the Lunavi website, with an updated “Last

updated” date.

12. Contact Information

Lunavi Agency

Espoo, Finland

Email: support@lunavi.app