Privacy Policy

1. Introduction

This Privacy Policy explains how LunaVector B.V., as data controller, collects, uses, and protects your personal data when you use our platform. We are committed to processing your data lawfully and transparently in accordance with the EU General Data Protection Regulation (GDPR).

2. Data we collect

• Account data: name, email address, and login credentials.
• Verification data: information needed to confirm eligibility and prevent fraud.
• Exchange connection data: API keys (without withdrawal rights) and the balances and trades they expose.
• Usage data: device, browser, IP address, and how you interact with the platform.
• Billing data: subscription plan and payment details processed by our payment provider.

3. How we use your data

We use your data to provide and operate the service, execute and propose rebalancing trades, process subscriptions, communicate with you, ensure security, comply with legal obligations, and improve the platform.

4. Legal bases

We process personal data on the basis of performance of our contract with you, our legitimate interests in operating and securing the service, your consent (where requested, such as for non-essential cookies), and compliance with legal obligations.

5. Exchange API data

API keys are stored encrypted and used only to read balances and place trades consistent with your chosen index. They never include withdrawal permissions, and you can revoke them at any time from your exchange.

6. Cookies and analytics

We use essential cookies to operate the platform and, with your consent, analytics cookies to understand usage and improve our service. You can manage your preferences at any time through your browser or our cookie settings.

7. Sharing and processors

We share data with trusted service providers acting on our behalf, including hosting, payment processing, and index data (MarketVector Indexes GmbH). We do not sell your personal data. Providers are bound by appropriate data-processing agreements.

8. Data retention

We retain personal data only for as long as necessary to provide the service and to meet legal, accounting, or reporting requirements, after which it is deleted or anonymised.

9. Security

We apply technical and organisational measures including encryption, access controls, and two-factor authentication to protect your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your rights

Under the GDPR you have the right to access, rectify, erase, restrict, and port your personal data, to object to certain processing, and to withdraw consent. You also have the right to lodge a complaint with your supervisory authority (in the Netherlands, the Autoriteit Persoonsgegevens).

11. International transfers

Where data is transferred outside the European Economic Area, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses.

12. Children's privacy

The service is not directed to anyone under 18, and we do not knowingly collect data from minors.

13. Changes to this policy

We may update this policy from time to time. Material changes will be communicated through the platform or by email.

14. Contact

For privacy questions or to exercise your rights, contact us at support@lunavector.com or write to LunaVector B.V., Mt. Lincolnweg 40, 1033 SN Amsterdam, The Netherlands.