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Privacy Policy

Last updated: April 2026

Effective for all users of the Lunavia platform operated by Sea You Travel JSC

Table of Contents

1.Introduction & Scope2.Data We Collect3.KYC/KYB Identity Verification4.How We Use Your Data5.Data Sharing & Disclosure6.Marketplace Privacy Controls7.Data Retention & Deletion8.Security Measures9.Your Rights10.Contact & DPO

1Introduction & Scope

Lunavia ("Platform", "we", "us") is a tour operations and guide marketplace platform operated by Sea You Travel JSC. This Privacy Policy describes how we collect, use, store, and protect the personal information of all users, including Tour Operators, Tour Agencies, Tour Guides, and Administrators.

By registering on our platform and using our services, you consent to the practices described in this policy. This policy applies to all data collected through the Lunavia web application, APIs, and associated services.

2Data We Collect

We collect the following categories of personal data:

Account Information

Name, email address, password (hashed), role selection (Tour Operator, Tour Guide, etc.), and subscription plan.

Profile Data

Profile photo, bio, languages spoken, operating cities, specialties, experience years, date of birth, and professional certifications.

Business Information (Operators & Agencies)

Company name, business registration number (ĐKKD), travel license number (Giấy phép lữ hành), company address, company email, and company logo.

🔒 Sensitive Verification Documents

Government-issued identification (CCCD/Passport), business registration certificates, travel licenses, proof of address, real-time selfie photographs, and representative ID for organizations. See Section 3 for detailed handling.

Transaction & Financial Data

Wallet balances, payment history, withdrawal requests, bank account details (for withdrawals), and tour compensation records.

Platform Activity Data

Tour applications, assignments, reviews, trust scores, reliability scores, audit logs, messaging history, and real-time tour execution data (check-ins, GPS waypoints).

3KYC/KYB Identity Verification

⚠️ Important: Identity Verification Data Handling

Lunavia requires identity verification (KYC — Know Your Customer for Tour Guides, KYB — Know Your Business for Tour Operators/Agencies) to ensure platform safety and regulatory compliance. This section specifically addresses how these sensitive documents are handled.

3.1 — Tour Guide (KYC)

Tour Guides are required to submit the following for identity verification:

  • Government-Issued ID — CCCD (Căn cước công dân) or Passport
  • Real Photo — A real-time selfie for facial verification
  • Tour Guide License — Professional guide license or certification (if applicable)
  • Proof of Address — Utility bill, bank statement, or equivalent document

3.2 — Tour Operator (KYB)

Licensed Tour Operators must submit:

  • Business Registration Certificate — Giấy đăng ký kinh doanh (ĐKKD)
  • Travel License — Giấy phép kinh doanh lữ hành (quốc tế/nội địa)
  • Representative ID — CCCD/Passport of the authorized representative
  • Proof of Business Address

3.3 — Travel Agency (KYB)

Travel Agencies must submit:

  • Business Registration Certificate — Giấy đăng ký kinh doanh (ĐKKD)
  • Representative ID — CCCD/Passport of the organizational representative
  • Proof of Business Address

3.4 — How We Handle Verification Documents

✓

Secure Storage

All verification documents are stored in encrypted cloud storage with restricted access. Only authorized platform administrators can view submitted documents during the review process.

✓

Purpose Limitation

KYC/KYB documents are used exclusively for identity verification and regulatory compliance. They are never used for marketing, analytics, or shared with third parties for commercial purposes.

✓

No Public Exposure

ID numbers, document images, and sensitive data from verification are never displayed on your public marketplace profile. Only your verification status (Verified / Not Verified) is shown to other users.

✓

Admin-Only Review

Verification documents are reviewed exclusively by trained administrators with appropriate permissions. Review decisions are logged in an audit trail for accountability.

4How We Use Your Data

We process your personal data for the following purposes:

  • Account Management — Creating, maintaining, and securing your user account
  • Identity Verification — Processing KYC/KYB submissions to ensure platform safety
  • Trust Score Calculation — Computing trust and reliability scores based on verified activity
  • Marketplace Matching — Connecting Tour Operators with qualified Tour Guides based on skills, location, and availability
  • Payment Processing — Managing wallet transactions, tour compensation, and withdrawal requests
  • Platform Safety — Monitoring for fraud, policy violations, and emergency reporting
  • Communications — Sending essential notifications about tours, applications, payments, and account security
  • Platform Improvement — Analyzing aggregated, anonymized usage patterns to improve service quality

5Data Sharing & Disclosure

🛡️ We do NOT sell your personal data.

Lunavia does not sell, rent, or trade your personal information to advertisers, data brokers, or any third parties for commercial purposes.

We may share limited data only in these circumstances:

  • Working Partners — When a Tour Guide is assigned to or accepted by a Tour Operator for a specific tour, limited contact information (such as phone number) becomes visible to facilitate tour coordination. See Section 6.
  • Legal Compliance — When required by Vietnamese law, court orders, or government regulatory bodies
  • Platform Safety — When necessary to protect the safety of users, investigate fraud, or enforce our Terms of Service
  • Service Providers — Cloud hosting, payment processing, and communication services that process data under strict contractual obligations

6Marketplace Privacy Controls

Lunavia implements tiered privacy controls on the marketplace to protect your sensitive contact information until a working relationship is established:

🔍 Before Working Together

✓Name & Avatar
✓Trust Score & Reviews
✓Languages & Specialties
✓Operating Region
✓Verification Status
✗Phone Number — Hidden
✗Email — Hidden (Free plan)

🤝 After Working Together

When an operator approves a guide application or assigns them to a tour:

✓All public information
✓Phone Number — Visible
✓Email Address — Visible

This ensures that your personal contact information is only shared with partners you have mutually agreed to work with, preventing unsolicited contact from the marketplace.

7Data Retention & Deletion

  • Active Accounts — We retain your data for as long as your account is active and for a reasonable period afterward to fulfill legal and accounting obligations.
  • Verification Documents — KYC/KYB documents are retained for the duration of your account plus 5 years after account closure, as required by Vietnamese financial compliance regulations.
  • Transaction Records — Financial transaction records are retained for a minimum 10 years in compliance with accounting laws.
  • Account Deletion — You may request complete account deletion. Upon verified request, we will delete or anonymize your personal data within 30 days, except where retention is legally required.

8Security Measures

We implement industry-standard security practices including:

🔐

Encryption

All data transmitted via HTTPS/TLS. Passwords hashed using bcrypt.

🛡️

Access Control

Role-based permissions (RBAC) restrict data access to authorized personnel only.

📋

Audit Logging

All administrative actions on sensitive data are logged with timestamps and user IDs.

🔒

Secure Storage

Verification documents stored in encrypted, access-controlled cloud infrastructure.

9Your Rights

Under applicable data protection laws, you have the right to:

  • Access — Request a copy of all personal data we hold about you
  • Rectification — Request correction of inaccurate or incomplete data
  • Erasure — Request deletion of your personal data (subject to legal retention requirements)
  • Portability — Request your data in a structured, machine-readable format
  • Objection — Object to specific processing activities
  • Withdraw Consent — Withdraw consent at any time (this does not affect previous processing)

To exercise any of these rights, contact us at the address below.

10Contact & Data Protection Officer

For privacy-related inquiries, data access requests, or to report a concern:

Company: Sea You Travel JSC

Platform: Lunavia

Email: privacy@lunavia.com

Address: Ho Chi Minh City, Vietnam

We aim to respond to all privacy requests within 30 business days.

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