Privacy Policy

This website is the responsibility of Origami Group Limited (“Origami Labs”). With this privacy policy (the “Privacy Policy”), Origami Labs offers transparency on the personal data collected and processed on the basis of this website. It follows the principle of the European Union’s General Data Protection Regulation (GDPR) that any information and communication relating to the processing of personal data should be easily accessible and easy to understand as well as formulated in clear and plain language.

Origami Labs shares your concern about the security of information you may submit to Origami Lab’s websites and the related mobile applications and services (collectively, the “Services”). This privacy policy explains the information we collect, how we use and share it, how to manage your privacy settings and your rights in connection with the Services.

Please read below to see how Origami Labs handles information. Here are our fundamental privacy principles:

  1. We aggregate and de-identify certain information about our members to use for business purposes.
  2. We provide several ways to control the privacy of your personal information and continuously seek to enhance privacy options available to you.

Origami Labs is headquartered in Hong Kong. If you are a resident of the European Union (“EU”), Origami Labs is the controller of your personal data for the purposes of EU data protection law.



Origami Labs relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  1. Where you have consented to the processing, which you can revoke at any time.
  2. Where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  3. To protect your vital interests, or those of others, such as in the case of emergencies;
  4. Where you have made the information public;
  5. Where necessary in the public interest; and
  6. Where necessary for the purposes of Origami Labs or a third party’s legitimate interests, such as those of visitors, members or partners.



We process your information in furtherance of our legitimate interests, including:

1. Providing and improving the Services, including any personalized Services. We do so as it is necessary to pursue our legitimate interests of providing personalized offerings to our members on a sustained basis; and

2. Keeping the Services safe and secure. We do so as it is necessary to pursue the legitimate interests of Origami Labs and its members in ensuring the Services are secure.



Origami Labs collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with us. We receive information when you complete activities using the Services. We also collect information about how you use the Services.

There are also several opportunities for you to share information about yourself and your activities with us. For example:

  1. We collect basic account information such as your name, email address, mailing address, username and password that helps secure and provide you with access to our Services.
  2. When you make a payment, you may provide payment information such as your payment card or other payment details. We use Stripe compliant third-party payment services and we do not store your credit card information.
  3. We collect and process location information when you sign up for and use the Services. To record your ride and to provide you with your training statistics , it is necessary to collect and record the physical location of your device including, data such as speed and direction
  4. Origami Labs allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook or Google (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences with the applicable Third-Party Account. This information is collected by the Third-Party Account provider and is provided to Origami Labs under their privacy policies. You can generally control the information that we receive from these sources using the privacy settings in your Third-Party Account.
  5. We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.



We use cookies and similar technologies on our services, including our websites and mobile applications (the “Services”).  Here we explain these technologies, why we use them, and the choices you have.

Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we partner with third-party analytics providers, like Google, which set cookies when you visit our websites. This helps us understand how you are using our Services so that we can improve them.

Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our Services may not function properly.

  1. To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
  2. Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.



The Services use log files. Stored information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs and device identifiers.



Origami Labs uses the information we collect and receive to administer and operate the Services and as otherwise described in this Privacy Policy.

We also use your information to analyze and improve the Services. To do this, we may use third party analytics providers to understand how our Services are used. We may also use your information to market the Services, accept payments, credit payments, provide support related to the Services, protect members, promote safety, and communicate with you (where you have agreed to receive such messages), and let you know about new features or updates.



Service Providers: We may share your information with third parties who provide services that support and improve the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote Lumos or display information that may be relevant to your interests on the Services or other websites or services.

Third Parties: We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking information we provide to users of our subscription services.



As the controller, Origami Labs determines the purpose and means of the processing of your personal data.


Origami Group Limited
Unit 913, 9th Floor, Tower 2, Cheung Sha Wan Plaza,
Cheung Sha Wan Road, Cheung Sha Wan,
Kowloon, Hong Kong




Visiting Website

Purpose: server logs will be used to detect of malfunctions and for security reasons (e.g. denial of service attack detection).

Legal basis: The processing of the server logs is lawful as it is within legitimate interests of the data controller.



Purpose: Personal data we collect allows Origami Labs to process your order. Collecting this information is essential to allow you to place orders and purchase products from us.

Legal basis: Based on the relationship between you and us, as a seller, processing is lawful as it is necessary to perform your order.


Account Creation

Purpose: Personal data we collect allows us to create an account for you on our Services, such as our mobile application. This enables you to use the features of our product.

Legal basis: As we require your consent prior to creating an account, the processing of your personal data, in the course of creating and operating an account for you, takes place on the basis your consent given to us when creating an account (i.e. registration). You can delete your account at any time by contacting us.


Newsletter Subscription

Purpose: Personal data we collect enables us to send newsletters and keep you updated on products and services.

Legal basis: As we require your consent prior to sending you a newsletter, the processing of your personal data, in the course of serving you with our newsletter, takes place on the basis of your consent given to us when subscribing to our newsletter. This service can be unsubscribed at any time.

Note: We do not intend to further process your personal data for purposes other as the ones stated above.


Third-party partners

To provide the Services we collaborate with third parties which are recipients of your personal data. Origami Labs will transfer personal data only if this is necessary for the fulfillment of your order, such as to payment or logistic providers. Apart from this, personal data will only be transferred to third parties on basis of written contractual agreements and to the extent permitted by law respectively if we are obliged to transfer data by statutory provisions, a court order or an enforceable administrative order.


Place of data processing and your data privacy rights

The Origami Labs website is hosted on servers located within the United States of America. When you visit our website, when you use our web shop, when you create an account on our website or subscribe to our newsletter, your data is therefore collected and processed within the United States. This takes place within a legal framework provided by the EU-US Privacy Shield. It protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States. The Privacy Shield includes strong data protection obligations on companies receiving personal data, from the EU and provides effective protection and redress for you.


How We Protect Information

We take measures to safeguard the collection, transmission and storage of the data we collect.  While we take reasonable protections for your information, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.



While we continue to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to us. Transmitting personal information is done at your own risk.




Adjust Notification and Email Preferences

Origami Labs offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preference. You may also unsubscribe by following the instructions contained at the bottom of each type of email. Any administrative or service-related emails generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.


Updating Account Information

You may correct, amend, update or delete profile or account information at any time by contacting us at We will generally respond to your request within 7-10 business days.


EU Members’ Rights

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:


Restricting or Limited Data Use

You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this, please contact us at We will generally respond to your request within 10-14 business days.


Objecting to Data Use

Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.  Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.  Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.


Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to us, such as statistics of the use of the Services.


Other Sites

(the “Other Sites”). The Other Sites maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Site.  Please be aware that any personal information you submit to the Other Sites may be read, collected, and could be used to send you unsolicited messages.  If you interact with the Other Sites, your information may be stored, processed, or shared.  Origami Labs is not responsible for the personal information you choose to submit via the Other Sites.


Privacy Policy Information

Origami Labs reserves the right to modify this Privacy Policy at any time, please review it occasionally. Any updated Privacy Policy will be posted on the Services in a timely manner.  Should we make material changes to the Privacy Policy we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you may stop using the Services and delete your account.



Our Analytics partners help us improve the quality of our site, and improve the relevance and frequency of advertisements you receive. Our Analytics Partners use a variety of techniques to collect de-identified information about your visit to our website.

In order to make sure you understand how our Analytics Partners handle your information please visit their terms of use pages, as Origami Labs has no ability to control or monitor our Analytics Partners’ data collection or data use practices.
Google Analytics —
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©2019-2020 Origami Group Limited

If you still have questions that are not addressed here, please submit them to us by:
Sending an email to:
Writing to: 
Origami Group Limited Limited
4th Floor, The Mills,
45 Pak Tin Par Street,
Tsuen Wan, Hong Kong

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.


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