Privacy Policy

Version 1.0 · Last updated: 2026-06-02

Scope and Policy

Lynshine Company Limited will only gather and handle your personal information when it is essential or relevant to our interactions with you. This Privacy Policy outlines our procedures for handling your Personal Data, encompassing its collection, processing, utilization, disclosure, transfer, retention, storage, and disposal when we deliver our services.

By accepting this Policy, you consent to the collection, processing, utilization, disclosure, transfer, retention, storage, and disposal of your Personal Data as described below.

"Personal Data" refers to information about you as an individual, whether accurate or not, that can identify you on its own or when combined with other information we have or may obtain access to. The Personal Data we gather and handle may include:

  1. Your first and last names;
  2. Email address;
  3. Mobile phone number;
  4. IP address;
  5. Cookies and/or statistical/analytical data, such as your browsing behavior, to the extent that it may be used to identify you;
  6. Your social media links or public profiles, along with any personal information visible there, which you may provide during customer support interactions;
  7. Account passwords you create;
  8. Any other personal information you provide while using our services.

This Policy only applies to Personal Data which is in our possession or under our control.

Collection of Personal Data

We collect your Personal Data when you use the services or communicate with us. In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our affiliates or subsidiaries, the Payment Channels, or the Publishers, pursuant to your consent given to these third parties.

(1) Lawful basis for processing

We process your personal data only where we have a lawful basis, including: performance of a contract with you (e.g., processing orders and top-ups), compliance with legal obligations, our legitimate interests (e.g., fraud prevention and service improvement), or your consent (e.g., marketing).

(2) Data subject rights

Subject to applicable law, you have the right to: access, rectify, and erase your personal data; restrict or object to processing; request data portability; and not be subject to decisions based solely on automated processing. You may exercise these rights via [email protected].

(3) Cross-border data transfer

Where your personal data is transferred outside your country/region, we apply appropriate safeguards such as Standard Contractual Clauses (SCCs) or reliance on adequacy decisions to ensure your data receives an equivalent level of protection.

(4) Retention period

We retain your personal data only for as long as necessary to fulfil the purposes described in this Policy, or for any longer period required by law (e.g., tax and transaction records). After that, we delete or anonymize the data.

(5) EU representative & Data Protection Officer (DPO)

For any questions about this Privacy Policy or your personal data, you may contact our data protection contact point: [email protected].

Data Subject Requests (DSR)

You may submit a data subject request (access, rectification, erasure, portability, etc.) via [email protected] (or the data request form). To protect your account, we may need to verify your identity first. We will respond within 30 days of receiving your request; if an extension is needed, we will inform you in advance with reasons.

Use and Disclosure of Personal Data

Your data shall be processed for the following purposes:

  1. Transaction processing and content delivery;
  2. Marketing and promotional campaigns;
  3. Other permitted uses and disclosures.

Transaction Processing and Content Delivery

In our capacity as a digital content service provider, online distributor of digital content, and supplier of associated services, we will utilize your Personal Data and may disclose it to third parties, which may include our affiliated companies or subsidiaries, payment channels, and publishers. This is done with the aim of delivering the services to you or when it is an essential aspect of conducting business with you.

Other Permitted Uses and Disclosures

You accept that we may also use your Personal Data for maintaining and securing your accounts, notifying you of matters relating to your account or transactions, processing service requests and responding to queries, complying with our internal security or risk management mechanisms, conducting statistical analysis or customer research, and improving your experience with our customer care services.

Retention and Disposal of Data

We will retain your Personal Data for as long as it is required to fulfill the initial purpose for which it was gathered and until it is no longer necessary for any additional legal or business objectives. Following that, we will securely dispose of your Personal Data to prevent any further access or processing, which may involve actions such as deletion or irreversible anonymization.

Security

We exert diligent efforts to ensure the security of your Personal Data, aiming to guard against loss, misuse, unauthorized access, alteration, accidental disclosure, or destruction. Nevertheless, it's important to note that complete security cannot be guaranteed for data transmission or storage over the Internet. However, we have implemented and consistently uphold a range of security measures to protect your Personal Data to the best of our reasonable capabilities.

Collection of Statistical Data

We gather statistical information related to your website usage and online interactions with our Platform, and we also permit third parties to collect such data using "cookies" and similar technologies. This statistical information is anonymized and does not reveal your identity. For the categories, purposes and retention periods of cookies, please refer to our Cookie Policy.

Contact Us

To get in touch with us regarding any aspect of this Policy or your Personal Data, including but not limited to actions such as withdrawing consent, unsubscribing from marketing and promotional communications, requesting access to your Personal Data, seeking updates or corrections to your Personal Data, or exercising any of your rights as stipulated in this Policy or relevant data protection laws, please contact our data protection contact point: [email protected].