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Legal · Privacy

Privacy policy.

Last updated: April 26, 2026

LUNVEXIS LIMITED, operating atlaspayment.org under the AtlasPayment brand (“AtlasPayment”, “we”), provides payment infrastructure consulting and orchestration services for high-risk operators. This notice explains what personal data we process when you use the site or engage us for advisory work, why we process it, and the rights you hold over it.

Who we are

LUNVEXIS LIMITED is the data controller for personal data processed through this site and during client engagements. Registered office: Room 511, 5/F, Ming Sang Ind Bldg, 19-21 Hing Yip Street, Kwun Tong, Hong Kong.

For any privacy question, write to hello@atlaspayment.org. We respond within one calendar month and acknowledge sooner.

What we collect

We process the minimum data needed to operate the site safely and to deliver advisory work. Specifically:

  • Site visitors: server-level access logs (IP, user-agent, requested URL, timestamp) generated by our hosting platform.
  • Inbound contacts: any information you choose to share when you message us on Telegram or email — typically name, role, company, and the substance of the request.
  • Engaged clients: contracting details, project notes, and the artefacts produced under engagement (scoping documents, structuring memos, vendor selection write-ups).
  • Operational records: invoicing and accounting data tied to client engagements.

AtlasPayment is not a payment processor and does not collect cardholder payment data through this site.

Other than the Google Ads tag described in the cookie notice, we do not run behavioural retargeting, fingerprinting, or session-replay tooling on this site.

How we use your data

We use personal data only for the purposes that make the site and the engagement work:

  • To respond to inbound messages and qualify whether an engagement makes commercial sense.
  • To deliver and document advisory work under signed engagement letters.
  • To coordinate introductions or application materials for third-party financial providers when a client instructs us to do so.
  • To meet our regulatory, accounting, and AML duties under English law.
  • To operate the site safely — server log retention, abuse triage, and incident response.

Sharing and recipients

We disclose personal data to a small set of providers acting under written processor agreements:

  • Hosting and CDN — the platform that serves this site.
  • Email and document infrastructure — Google Workspace.
  • Advertising and conversion measurement — Google Ads / Google tag, used to measure ad performance and site conversions.
  • Bookkeeping and tax counsel — for the records we are legally required to keep.
  • Third-party banks, EMIs, acquirers, PSPs, processors, or other financial providers — only when coordinating an introduction or application at a client’s explicit instruction.

Those third-party providers make their own onboarding, pricing, reserve, and account decisions under their own terms and privacy notices.

We do not sell personal data.

International transfers

Some of the providers above are based outside the UK. Where they are, we rely on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, the UK Adequacy Regulations where they apply, and additional technical measures (encryption in transit and at rest) appropriate to the data being transferred.

Retention

We retain data for the shortest period that meets the purpose:

  • Server access logs: 90 days.
  • Inbound messages that do not lead to an engagement: 12 months, then deleted.
  • Engagement records: for the life of the engagement and 7 years after, to meet accounting and AML obligations.
  • Anything you ask us to delete sooner: deleted on request unless we are legally required to keep it.

Your rights

Under UK GDPR you have the right to:

  • access the personal data we hold about you,
  • correct it if it is inaccurate or incomplete,
  • ask us to erase it, subject to the retention obligations above,
  • restrict or object to processing,
  • request portability of data we hold under contract or consent,
  • complain to the Information Commissioner’s Office (ico.org.uk) if you believe we have handled your data poorly.

Exercise any of these by writing to hello@atlaspayment.org.

How to contact us

Email: hello@atlaspayment.org. Telegram: see the CTA on the home page. Postal: LUNVEXIS LIMITED, Room 511, 5/F, Ming Sang Ind Bldg, 19-21 Hing Yip Street, Kwun Tong, Hong Kong.