California Consumer Privacy Act (CCPA) Compliance

This California Consumer Privacy Act (CCPA) Compliance Statement explains how LUNARBAY GROUP (HONGKONG) LIMITED ("Lunarbay Group," "we," "us," or "our") complies with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) with respect to the personal information of California residents.

1. Information We Collect

In the past 12 months, we have collected the following categories of personal information from consumers:

• Identifiers: Such as name, email address, postal address, IP address, account name, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute: Such as name, address, telephone number, credit card number, debit card number, or any other financial information.
• Commercial information: Such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information: Such as browsing history, search history, and information regarding a consumer's interaction with our website, application, or advertisement.
• Geolocation data: Such as physical location or movements.
• Inferences drawn from other personal information: Such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive personal information: Such as account login credentials, payment information, and precise geolocation if you provide or enable it. We use sensitive personal information only as reasonably necessary to provide the Services, process transactions, maintain security, prevent fraud, comply with law, or for other purposes permitted by California law.

2. Sources of Personal Information

We obtain the categories of personal information listed above from the following sources:

• Directly from you: For example, from forms you complete or products and services you purchase.
• Indirectly from you: For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
• Third parties: For example, third-party service providers, payment processors, advertising and measurement partners, app stores, analytics providers, and other third parties with whom we have an ongoing business relationship.

3. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide you with information, products, or services that you request from us.
• To fulfill the reason for which you provided the information.
• To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news that may be of interest to you.
• To improve our website and present its contents to you.
• To deliver, personalize, measure, and improve advertising and marketing campaigns, where permitted by law.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and debug or repair errors.
• For testing, research, analysis, and product development.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. Sharing of Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the past 12 months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers
• California Customer Records personal information categories
• Commercial information
• Internet or other electronic network activity information
• Geolocation data

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers
• Advertising networks, mediation platforms, attribution providers, analytics providers, and media buying partners
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

5. Sale, Sharing, and Targeted Advertising

We do not sell personal information for money. However, some advertising, analytics, attribution, and measurement activities may be considered a "sale," "sharing," or processing for cross-context behavioral advertising under the CCPA/CPRA and other U.S. state privacy laws.

In the past 12 months, we may have sold or shared the following categories of personal information with advertising and measurement partners for advertising, attribution, campaign measurement, fraud prevention, frequency capping, and similar commercial purposes:

• Identifiers, such as IP address, mobile advertising ID, cookie ID, or similar device identifiers
• Internet or other electronic network activity information, such as interactions with our Services, apps, websites, or advertisements
• Commercial information, such as purchase events or subscription status where relevant to measurement or attribution
• Approximate geolocation derived from IP address or device settings
• Inferences used for advertising or campaign measurement

You have the right to opt out of the sale or sharing of personal information and targeted advertising. You may exercise this right through available privacy controls in our Services, by using device-level advertising settings, by enabling a browser-based opt-out preference signal such as Global Privacy Control where supported, or by contacting us at bd@lunarbaygroup.com with the subject line "Do Not Sell or Share My Personal Information."

We do not knowingly sell or share the personal information of consumers under 16 years of age without affirmative authorization.

6. Your Rights Under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

6.1 Right to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

6.2 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of processing.

6.3 Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

6.4 Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information and the use of your personal information for cross-context behavioral advertising. See Section 5 above for how to exercise this right.

6.5 Right to Limit Use of Sensitive Personal Information

You have the right to limit certain uses and disclosures of sensitive personal information. We do not use sensitive personal information to infer characteristics about you or for purposes outside those permitted by California law without providing any required right to limit.

6.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by:

• Emailing us at bd@lunarbaygroup.com
• Using available privacy controls in our Services
• Visiting our Privacy Policy

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

8. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9. Changes to This CCPA Compliance Statement

We reserve the right to amend this CCPA Compliance Statement at our discretion and at any time. When we make changes to this CCPA Compliance Statement, we will post the updated notice on our website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

10. Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

LUNARBAY GROUP (HONGKONG) LIMITED
Room 602, 6/F, Kai Yu Commercial Building
2C Argyle Street, Mongkok, Kowloon, Hong Kong
Email: bd@lunarbaygroup.com

Last Updated: May 22, 2026

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