Privacy Policy

Privacy Policy


1. Identification
Holder: actiMirror Corp. Ltd. (hereinafter referred to as ” actiMirror”)

CR: 2051902

Corporate address: Unit L2, 10/F, Phase 2, Kaiser Estate, 47-53 Man Yue Street, Hung Hom, Kowloon, Hong Kong


Data Protection Officer: The user can contact the Data Protection Officer by writing to the address to actiMirror to the attention of the “Data Protection Officer” or to the email

“LUNNA” is a registered trademark owned by the actiMirror group.

Our goal is to make you feel comfortable on our website. Protecting your privacy is particularly important to us. Therefore, we would like to ask you to carefully read the following summary on how our website works. You can rely on transparent and fair data processing as we strive every day to handle your data safely, carefully, and responsibly.

The following privacy policies are intended to inform you about how we use your personal information in compliance with the provisions and requirements of the European General Data Protection Regulation.


2. Information and consent
By reading this Privacy Policy, the user is informed about the way in which actiMirror collects, processes and protects the personal data that are provided to him through the forms arranged through the website (hereinafter, the “Website”), as well as the data derived from his browsing and those other data that may facilitate in the future to actiMirror.

The user should carefully read this Privacy Policy, which has been drafted in a clear and simple way, to facilitate their understanding, freely and voluntarily determining whether they wish to provide their personal data to actiMirror.


3. Obligation to provide data
The data requested in the forms provided on the Website are, in general, mandatory (unless otherwise specified in the required field) to fulfill the stated purposes.

Therefore, if such data is not provided or these data are not correct, they cannot be taken care of.


4. For what purpose will actiMirror process the user’s personal data and for how long?
The personal data collected will be processed by actiMirror for the following purposes:

Manage your contact requests with actiMirror through the channels provided for this in
Manage purchases made within the framework of the Website, including payment management and order forwarding.
Manage the subscription to the newsletter, made through the channel provided on the Website of actiMirror.
Perform analysis on the use of the Website and check the preferences and behavior of users.
Manage the sending of commercial communications about products and services actiMirror unless the user indicates otherwise by checking the corresponding box or show their opposition to such processing.
Send commercial communications (offers, promotions, etc.) to the user by electronic and / or conventional means, about products and services of third companies with which actiMirror collaborates if the user consents to do so by checking the corresponding box.
Manage the sending of satisfaction surveys based on the purchase of the product or service of actiMirror made, to improve the experience of our customers day by day.
Analyze the user’s data, using own and third-party sources, in order to develop profiles that allow to define in greater detail the products that may be of interest, if you authorize it by checking the box enabled for this purpose.
The data will be kept for the time necessary for the realization of the purposes for which they were collected, and, during the limitation period of the legal actions that may arise from it. However, the above, the user can request their withdrawal to actiMirror, opposing or revoking their consent.


5. What user’s data will actiMirror treat?

actiMirror will process the following categories of data:

Identification data: first name, surname, national identity document or foreign identity number and image.
Contact details: home, landline, mobile phone, email address.
Personal characteristics data: date of birth, age, gender, nationality.
Bank details: account number, holder, SEPA mandate.
Economic, financial and insurance data: income and income.
Other data: data provided by the interested parties themselves in the open fields of the forms provided on the Website.
Navigation data.
In the event that the user provides data of third parties, declares to have the consent of the same or with sufficient legitimacy and undertakes to transfer to the data subject, owner of such data, the information contained in the Privacy Policy, exempting actiMirror from any liability in this regard. However, actiMirror may carry out the necessary checks to verify this fact, adopting the appropriate due diligence measures, in accordance with data protection regulations.


6. Cookies, web analytics services and social networks
We use cookies, web analytics services and social media plugins on our website to improve your browsing experience. To view our cookie policy, click here.


7. What is the legitimacy of the processing of your data?
The processing of data for the acquisition of products through the Website will be necessary for the fulfillment of the contractual relationship arising between the user and actiMirror.

The processing of your data for marketing purposes, relating to actiMirror’s own goods and services and similar services for its customers, will be based on the legitimate interest recognized by the regulations when the user has purchased goods and/or services from actiMirror. In the absence of such a contractual relationship, the data processing will be based on the user’s consent contained in the current regulations. Likewise, the sending of commercial communications from third parties with which actiMirror collaborates and profiling, are based on the user’s consent.

The processing for these purposes will always be carried out with the consent of the user or on the basis of the aforementioned legitimate interest and will be necessary for the attention of your request.

Also, if you withdraw your consent to any of the treatments, this will not affect the lawfulness of the treatments carried out previously.

To revoke this consent, the User may contact actiMirror through the following channels: by letter addressed to actiMirror Data Protection Department, Unit L2, 10/F, Phase 2, Kaiser Estate, 47-53 Man Yue Street, Hung Hom, Kowloon, Hong Kong or by clicking on the automatic unsubscribe link available in each commercial communication sent by actiMirror or by email addressed to


8. Which recipients will user data be shared with?
The user’s data may be communicated to:

Companies of the group to which it belongs to actiMirror, which you can consult here, only for internal administrative purposes and / or for the purposes indicated above, based on the legitimate interest recognized in the GDPR.
Companies of the group to which it belongs to actiMirror for the sending of commercial communications about the products and services offered by the companies that form it, provided that the User has consented to it.
Public Administrations and competent national and/or European authorities, in the cases provided for by the Law.
The user accepts that all their personal data are fully transferred to Aplazame from the moment the user has started contracting the deferred payment service offered by the latter at the time of choosing the payment method. This acceptance is extended to third parties that had to access the files for the good end of the contract.
In addition, the data may be accessible actiMirror Corp., Ltd. and by suppliers of actiMirror, being said access necessary for the proper fulfillment of the legal obligations and / or the purposes indicated above. Such providers will not process your data for their own purposes that have not been previously informed by actiMirror.

The addressees indicated in this paragraph may be located within or outside the European Economic Area, the latter being duly legitimized international data transfers.


9. User responsibility
The user:

It ensures that you are over eighteen (18) years old and that the data you provide to actiMirror is true, accurate, complete and up to date. For this purpose, the user is responsible for the veracity of all the data that he/she communicates and will keep the information provided conveniently updated, in such a way that it responds to his/her real situation.

You guarantee that you have informed the third parties of the ones you provide your data, if you do so, of the aspects contained in this document. It also guarantees that you have obtained your authorization to provide your data to actiMirror for the purposes indicated.

You will be responsible for false or inaccurate information you provide through the Website and for any direct or indirect damages caused by this to actiMirror or third parties.


10. Commercial and promotional communications
One of the purposes for which actiMirror processes the personal data provided by users is to send them electronic communications with information regarding goods, services, promotions, offers, events, or news relevant to users. Whenever such communication is made, it will be addressed solely and exclusively to those users who have not previously expressed their refusal to receive them or who have expressly authorized it.

To carry out the above work, actiMirror may analyze the data obtained by the entities that form of the group of companies to which actiMirror belongs, in order to develop user profiles that allow to define in greater detail the products that may be of interest.

In the event that the user wishes to stop receiving commercial or promotional communications by actiMirror, he / she can request the unsubscribe of the service by clicking on the link enabled for such purposes in the body of such commercial communications or by sending an email to the following email address: as well as indicating his / her refusal to receive them, through the box thus arranged in the form of collection of your data or indicating it by means of the unsubscribe option provided in each of the commercial communications sent.


11. Using the chat feature “customer support”

One of the possibilities we offer you is “Customer Chat” to make our service even more enjoyable for you. Through this chat you have the opportunity to consult before buying on our website. The entire chat process is done in a completely anonymous way, without showing your name or other personal data. In order to constantly improve the quality of our customer service in chat, we record this history for analysis and improvement purposes, in a totally anonymous way. These records are deleted after they are evaluated.


12. Exercise of rights
The user may send a letter to actiMirror, to the address indicated in the header of this Policy, or by email to the address, attaching a photocopy of his/her identity document, at any time and free of charge, to:

Revoke consents granted.
Obtain confirmation as to whether personal data concerning the User is being processed in actiMirror.
Access your personal data.
Rectify inaccurate or incomplete data.
Request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes that were collected.
Obtain from actiMirror the limitation of the processing of the data when any of the conditions provided for in the data protection regulations are met.
Obtain human intervention, to express your point of view and to challenge the automated decisions taken by actiMirror.
Request the portability of your data.
Contact the DPO at actiMirror at the following address:
File a complaint regarding the protection of your personal data where the data subject considers that actiMirror has infringed the rights recognized by the applicable data protection regulations.


13. Security measures
actiMirror will process the user’s data at all times in an absolutely confidential manner and keeping the secrecy of these, in accordance with the provisions of the implementing regulations, adopting for this purpose the necessary technical-organizational measures that guarantee the security of their data and prevent their alteration, loss, treatment or unauthorized access, taking into account the state of the technology, the nature of the stored data and the risks to which they are exposed.


14. Changes to the privacy policy
To ensure that our data protection guidelines always comply with current legal requirements, we reserve the right to make changes to always be appropriate to applicable law.


15. List of companies that are part of the group actiMirror
actiMirror Corp., Ltd.

They shall also form part of this agreement, all those companies actiMirror that are incorporated in the future and which belong to the group actiMirror.


Last updated: May 2020.

All rights reserved. Any copy, distribution and/or reproduction, in whole or in part, of the contents and/or of the actiMirror website shall require the prior written authorization of actiMirror.