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LUNAR PRIVACY POLICY

Last Modified: June 2023

This Privacy Policy ("Privacy Policy" or "Policy") applies whenever you use or interact with Lunar Run Ltd.'s (“Lunar”, “we”, “us” or “our”) website https://www.lunar.dev (the "Website") or any other site, mobile application or service we provide, and any content or material provided thereon (collectively, the "Service"). This Policy is part of Lunar's Terms of Use which are incorporated herein by reference.  

If you do not agree to this Policy, please avoid using our Service. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the best experience. 

FROM WHOM DO WE COLLECT PERSONAL DATA

This Privacy Policy applies to Lunar's collection, use, and disclosure of the Personal Data of (1) Our Website Visitors: Individuals who visit our Website and who may volunteer Personal Data; and (2) Our Customers: Those who sign up to our Service or engage with us with respect thereto.

TYPES OF DATA COLLECTED AND PURPOSES

Depending on your interaction with us, we may collect two types of data from you:

“Non-Personal Data” meaning aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Service. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device.

"Personal Data" or “Personal Information” (as defined under the CCPA) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (including “Personal Data” as defined under the GDPR).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the GDPR applies):

INFORMATION TYPE METHODS AND PURPOSE LAWFUL BASIS
Contact Information
If you voluntarily contact us, through any means of communications we make available (for example, “contact us” page), you will be required to provide us with certain information such as your name, email address, and any additional information you decide to share with us (“Contact Information”).		 We process Contact information to provide our Service, to respond to your inquiries, and provide you with the support, materials and information you have requested. We process this Contact Information subject to (a) your consent and (b) fulfilling our contractual obligation towards our Customers. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of service purposes.
Website Interaction and Marketing
When you interact with our Website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID (“Online Identifiers”).		 We collect Online Identifiers to operate the Website and enable its proper functionality, to analyze usage on our Service, improve our user experience and safety, and display relevant content.
We process such data through our or third-party cookies and tracking technologies for analytic.		 Such collection is based on (a) consent (where applicable, namely in the EU, where such data is collected through the use of Tracking Technologies, as mentioned below); (b) our legitimate interests, which in this case are operating and promoting our Service, and providing the best user experience.
Legal Matters We may use certain Personal Data to prevent potentially prohibited or illegal activities, and any other misuse of the Service, to enforce our legal terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in the Data Transfer Section is based on the same lawful basis as stipulated in the table above.

 

COOKIES AND SIMILAR TECHNOLOGIES

We use “cookies” (or similar tracking technologies) when you access or interact with the Website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, or for statistical and advertising purposes. You can find more information about cookies at http://www.allaboutcookies.org

Below is a list of useful links that can provide you with more information on how to manage your cookies:

You can turn off certain third-party targeting and advertising cookies by visiting the following third-party webpages:

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Please note that once you choose to opt out or disable cookies, some features of the Website may not operate properly, and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however it will not be targeted content or advertising.

DATA SHARING – CATEGORIES OF RECIPIENTS WE DISCLOSE PERSONAL DATA TO

We disclose your Personal Data to third parties, that help us maintain and provide our Service. 

We may transfer or disclose Personal Information to our subsidiaries and other affiliated companies. In addition, your Personal Information may be disclosed to other trusted third-party service providers or partners with whom we have contracted to provide services to us. Also, we may disclose your information when we believe disclosure is required to comply with the law, enforce our policies or protect ours or others’ rights, property or safety. 

When disclosing Personal Data to third parties, they are required to secure the Personal Data they receive and to use that Personal Data only in compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

INTERNATIONAL DATA TRANSFERS

We operate globally, and any information that we collect, disclose or share, including (but not limited to) your Personal Data, can be stored and processed in the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:

  • located in the EEA or in the UK;
  • located in non-EEA countries or UK which have been approved as providing adequate level of data protection by the European Committee; or
  • who have entered into a legal agreement ensuring an adequate level of data protection, including the Standard Contractual Clauses as approved by the European Committee.

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USER RIGHTS

Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. The following table describes all the rights you are entitled to, according to your residency. 

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EU Virginia, Colorado, Connecticut, and Utah California
Right to know or access Personal Data collected by us The right to know what Personal Information the business has collected
Deletion Rights
Correct Inaccurate Data (excluding Utah residents)
N/A Opt-Out of Sharing for Cross-Contextual Behavioral Advertising
N/A Opt-out from selling
N/A Limit the Use or Disclosure of Sensitive Personal Information (SPI)
N/A Opt-out from profiling in furtherance of decisions that produce legal or similarly significant effects concerning the user N/A
Opt-Out of the Use of Automated Decision Making N/A
N/A Non-Discrimination
Data Portability
Restriction or Objection to Processing N/A
Withdrawal of Consent N/A

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Exercising Your Rights

 

your rights may be exercised by contacting us at info@lunar.dev. Certain rights can be easily executed independently:

  • You can opt-out from receiving our emails by clicking the “unsubscribe” link available in the email itself.
  • You can opt out of interest-based advertising with some of the service providers we use, such as Google and  Google Analytics. Please note that if you opt out of interest-based advertising, some information will still be collected for other purposes such as analytics, and internal operations. You will also continue to receive contextual advertisements, but they may be less relevant to your interests.
  • You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulatory frameworks (see the 'Cookies and Similar Technologies' section of this Policy.  

DATA RETENTION

We will retain your Personal Data for as long as necessary to provide our Service, comply with our legal obligations, resolve disputes, and enforce our policies. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so. However, retention periods shall be determined, taking into account, the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

SECURITY MEASURES

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards. 

Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the Personal Data you choose to disclose.

ELIGIBILITY AND CHILDREN PRIVACY

Our Service is intended for use by persons over the age of majority (as determined by applicable laws where such persons reside in: "Minor"). We will only process such information if we are provided with a valid parental or guardianship approval and consent, in accordance with the requirements of applicable laws. Please contact us at: info@lunar.dev if you have a reason to believe that a Minor has shared any data with us.

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PRIVACY NOTICE FOR U.S RESIDENTS

This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020, and the regulations enacted thereunder (collectively: "CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy and Online Monitoring Act ("CTDPA"), the Utah Consumer Privacy Act ("UCPA"), (collectively: "US Data Protection Laws").

Most of the statements, rights and obligations under this part are common to all US Data Protection Laws and apply to you only to the extent determined in the applicable law according to your residency.


Collection, disclosure and sharing of Personal Information

In the preceding twelve (12) months, we have collected the following Personal Information:

Category of Personal Information Collected Personal Information Collected Sources of Personal Information Business Purpose for Collection
Identifiers Full name, email address, social media identifier, IP address 1. Directly and indirectly from activity on our Website
2. Indirectly from your activities across the internet
3. From third parties		 1. To provide you with and improve our Service.
2. To detect and prevent fraud or illegal activities.
3. To respond to your requests and inquiries and communicate with you.
4. Direct marketing purposes (i.e, to send you promotional offers).
5. To perform research, technical diagnostics, analytics or statistical purposes.
6. To charge our Customers for the Service provided by us.
Customer records Financial information, name, telephone number
Geolocation data IP address and device location data
Electronic network activity Users' interaction with the Service

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We do not "Sell" or "Share" personal information, as these terms are defined under the CCPA. 

In the preceding twelve (12) months we disclosed your Personal Information, as described below:

Categories of Recipients Purpose of Disclosure
Service Providers (as defined under the CCPA) Lunar's operational purposes. The disclosure of such Personal Data will be as reasonably necessary and proportionate to achieve such operational purposes. This includes:
- Auditing related to a current interaction with our Customers and Website Visitors.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair our Service.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our Service, and to improve, upgrade, or enhance our Service.


Authorized Agents

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

  • When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
  • Provide the authorized agent signed permission to do so or power of attorney.
  • Verify their own identity directly with the business.
  • Directly confirm with the business that they provided the authorized agent permission to submit the request.
  • We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

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Notice of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

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Other California Obligations

  • Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at info@lunar.dev.
  • "Do Not Track" Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

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ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS

Nevada law requires certain businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Information that the business has collected or will collect about the consumer. If you are a Nevada consumer from whom Lunar has collected Personal Information and you wish to submit a request relating to our compliance with Nevada law, please contact us at  info@lunar.dev_.  

POLICY AMENDMENTS

The updated date of this Policy will be reflected in the “Last Updated” heading, indicated at the header of the Policy. As required by the CCPA we will review this Privacy Policy every twelve (12) months and amend it as necessary. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices

CONTROLLING VERSION

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

CONTACT INFORMATION

If you have any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our "Data Protection Officer" responsible for matters relating to privacy and data protection, at info@lunar.dev.  

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Lunar Run Ltd.

Haarbaa st. 18a, Tel Aviv

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