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Policy Background

Privacy Policy

Last Updated: February 10, 2026

Download Privacy Policy

5. PRIVACY POLICY

5.1. Introduction

HANGUKVERSE (PRODUCT BY LUMANTARA LTD) ("we," "our," "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.

Legal Basis for Processing:

  • India: Information Technology Act, 2000 and Digital Personal Data Protection Act, 2023
  • EU: General Data Protection Regulation (GDPR)
  • UK: UK GDPR and Data Protection Act 2018
  • US: Various federal and state privacy laws including COPPA, CCPA/CPRA

5.2. Data Controller

For users in India:

Data Fiduciary: LUMANTARA PVT LTD

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: fans@hangukverse.com

For users in the United Kingdom:

Data Controller: LUMANTARA LTD

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: fans@hangukverse.com

For users in the European Union:

Data Controller: LUMANTARA LTD

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: fans@hangukverse.com

For users in the United States:

Data Controller: LUMANTARA LTD

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: fans@hangukverse.com

For users in all other regions:

Data Controller: LUMANTARA LTD

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: fans@hangukverse.com

5.3. Information We Collect

Personal Information You Provide:

  • Name, email address, phone number
  • Username and password
  • Payment information (processed by third-party payment processors)
  • Profile information (photo, bio, preferences)
  • Communications with us (support tickets, emails)
  • User-generated content (posts, comments, reviews)

Automatically Collected Information:

  • Device information (device type, operating system, unique device identifiers)
  • Log data (IP address, browser type, pages visited, time stamps)
  • Usage data (features used, actions taken, session duration)
  • Location data (with your permission)
  • Cookies and similar technologies (see Cookie Policy)

Information from Third Parties:

  • Social media platforms (if you connect your account)
  • Authentication services
  • Analytics providers
  • Payment processors

5.4. How We Use Your Information

We use your information for the following purposes:

Service Provision:

  • To create and manage your account
  • To provide, maintain, and improve our services
  • To process transactions and send transaction notifications
  • To provide customer support

Legal Basis (EU/UK): Performance of contract, legitimate interests

Communication:

  • To send service-related announcements
  • To respond to your inquiries
  • To send marketing communications (with consent)
  • To send notifications about your account or activity

Legal Basis (EU/UK): Contract performance, legitimate interests, consent (for marketing)

Improvement and Analytics:

  • To analyze usage patterns and trends
  • To improve user experience and Platform functionality
  • To develop new features and services
  • To conduct research and analytics

Legal Basis (EU/UK): Legitimate interests

Security and Legal Compliance:

  • To detect, prevent, and address fraud and security issues
  • To enforce our Terms and policies
  • To comply with legal obligations
  • To protect our rights and the rights of users

Legal Basis (EU/UK): Legal obligation, legitimate interests

5.5. Legal Basis for Processing (EU/UK)

We process your personal data based on:

  • Consent: When you have given clear consent
  • Contract: To fulfill our contract with you
  • Legal Obligation: To comply with legal requirements
  • Legitimate Interests: For our business interests that don't override your rights
  • Vital Interests: To protect life or safety

5.6. Data Sharing and Disclosure

We may share your information with:

Service Providers: Third-party vendors who perform services on our behalf (hosting, analytics, payment processing, customer support)

Business Transfers: In connection with a merger, acquisition, or sale of assets

Legal Requirements: When required by law, court order, or government request

Protection of Rights: To protect our rights, property, safety, or that of users or the public

With Your Consent: When you authorize us to share information

We do not sell your personal data to third parties.

US Users (CCPA/CPRA): We do not "sell" or "share" personal information as defined under California law.

5.7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence.

EU/UK Users:

Transfers outside the EU/UK are protected by:

  • Standard Contractual Clauses (SCCs)
  • Adequacy decisions
  • Other approved transfer mechanisms

India Users: Transfers comply with DPDP Act requirements for cross-border data transfers.

5.8. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy or as required by law:

  • Account data: Until account deletion + legal retention period
  • Transaction records: 7 years (or as required by tax/financial regulations)
  • Marketing data: Until consent is withdrawn + reasonable period
  • Cookies: As specified in our Cookie Policy

Deletion Requests: You may request deletion of your data subject to legal and contractual obligations.

5.9. Your Privacy Rights

All Users:

  • Right to access your personal data
  • Right to correct inaccurate data
  • Right to request deletion of data (subject to legal exceptions)
  • Right to object to processing
  • Right to withdraw consent

EU/UK Users (Additional Rights):

  • Right to data portability
  • Right to restriction of processing
  • Right not to be subject to automated decision-making
  • Right to lodge a complaint with supervisory authority

California Users (CCPA/CPRA Rights):

  • Right to know what personal information is collected
  • Right to delete personal information
  • Right to opt-out of sale/sharing (we don't sell/share)
  • Right to correct inaccurate information
  • Right to limit use of sensitive personal information
  • Right to non-discrimination

India Users (DPDP Act Rights):

  • Right to access and correction
  • Right to erasure and data portability
  • Right to grievance redressal

To Exercise Your Rights: Contact fans@hangukverse.com or use in-app privacy controls.

Response Time:

We will respond within:

  • EU/UK: 1 month (extendable to 3 months for complex requests)
  • US: 45 days (extendable to 90 days)
  • India: As required by DPDP Act

5.10. Children's Privacy

Our Platform is not intended for children under 13 (or 16 in EU). We do not knowingly collect personal information from children under these ages.

If we become aware that we have collected data from a child without parental consent, we will delete it promptly.

COPPA Compliance (US): We comply with the Children's Online Privacy Protection Act.

GDPR Compliance (EU/UK): Additional consent requirements for users aged 13-16.

5.11. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security assessments
  • Employee training on data protection
  • Incident response procedures

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

5.12. Automated Decision-Making

We may use automated decision-making for:

  • Fraud detection and prevention
  • Personalized content recommendations
  • Service optimization

EU/UK Users: You have the right not to be subject to solely automated decisions with legal or significant effects, and you may request human review.

5.13. Do Not Track Signals

We do not currently respond to Do Not Track (DNT) signals. You may control cookies through browser settings (see Cookie Policy).

5.14. Third-Party Links

Our Platform may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies.

5.15. Changes to Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via:

  • Email notification
  • Prominent notice on the Platform
  • In-app notification

Continued use after changes constitutes acceptance.

5.16. Contact Information

If you have any questions, concerns, or requests regarding privacy, data protection, or this Policy, you may contact us using the details below:

Please mention 'Privacy Request', 'DPO Request', or 'Grievance' in the subject line to help us process your request faster.

General Privacy & Data Protection Inquiries:

Email: fans@hangukverse.com

(Product operated by Lumantara Ltd)

Data Protection Officer (EU & UK):

Email: fans@hangukverse.com

Grievance Officer (India):

Email: fans@hangukverse.com

We will make reasonable efforts to respond to all legitimate requests within the timeframes required by applicable law.

Supervisory Authorities:

  • European Union: Your local/national Data Protection Authority
  • United Kingdom: Information Commissioner's Office (ICO) – www.ico.org.uk
  • India: Data Protection Board of India