Updated: May 2, 2022
Luna Solutions, LLC and its Affiliates (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. We are a business-to-business (B2B) provider offering an integrated suite of technologies and services to eyewear retailers, brands and doctors all around the world.
This policy describes the types of information we may collect from you or that you may provide when you visit the website(s) www.luna.io or www.demo.luna.io and dependent pages (our “Website“), download our Apps, or use our services, and our practices for collecting, using, maintaining, protecting, sharing and disclosing that information.
“Affiliates” means Ditto Technologies, Inc., Premium Vision, LLC, 6over6 Vision, Ltd., and Rx Renewal, LLC.
This policy applies to information we collect:
It does not apply to information collected by:
Certain of our businesses and services we provide may be governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and we adhere to HIPAA’s required privacy protections for your protected health information where applicable.
Our Website and services are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at: firstname.lastname@example.org or email@example.com
We collect several types of information from and about users of our Website, Apps or services including information:
We collect this information:
The information we collect on or through our Website may include:
You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
We collect information that you voluntarily provide to us, including when you use our Virtual Try On and other services.
Face scans: You may decide to consent to the scan, capture, processing, and storage of images of your face to use our Virtual Try On and Face Insights technologies. By clicking to proceed or agreeing to use our technology you consent to a capture of your face. Any such information shall be used by us for the sole purpose of showing virtual eyewear on your face and providing customized information and recommendations about eyewear. We use scans of your facial geometry to show you through our online services how eyewear will look and to ensure the appropriate fit. Your facial geometry may include ear junction, eye corner width, face shape, nose bridge height and width and temple length, among other measurements calculated from the face scan. We may share your measurement information with eyewear providers in order to provide our service and so that any glasses you order fit properly. Your face scans are maintained by us on our systems or those of our service providers, such as web hosting services. Service providers, such as web hosting organizations, may have had access to your facial scans for purposes of providing services to us.
Optical Data: Certain of our services enable users to measure the refraction error of their eyes (GoEyes only) or find their pupillary distance and the lens power of their glasses. This is done by using tools implemented in our Apps. For these purposes, users may be asked to provide us additional data such as their mobile phone number (as part of the download process of the App, and without retaining such number once the App is installed); glasses parameters; lens analysis and pupillary distance; depth data (which is required to measure eyes’ distance and head angle in real-time); frontal facial pictures (which are cropped and anonymized immediately thereafter); and a “Calibration Image” (which is an image with a known size such as plastic standard magnetic card to set as a reference object). Please note that when you are using our services, we may ask you to present a magnetic card in order to facilitate the service. Once this is identified in the image, we make reasonable efforts to apply an obfuscation process, so to avoid saving any recognizable details that may exist on the card itself on our systems. For 6over6 services, this Calibration Image will not be linked to any personally identifying data.
Prescription Information: We may collect your prescription information in connection with certain services.
Gender: We may collect this information in connection with certain of our technologies and services.
We retain your face scans for a maximum of three years following collection. We will permanently destroy your face scans no later than the end of the three year period.
As you navigate through and interact with our Website, Apps or services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
We use information that we collect about you or that you provide to us, including any personal information:
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to you and our advertisers’ target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
For purposes of this CCPA Notice, we refer to personal information according to the following definition given in the CCPA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CCPA. Depending on the individual circumstances, for example, certain information we collect in connection with our services may be outside the scope of the CCPA because it is your medical information or health information, or because it does not individually identify you. You may direct any questions concerning your individual information to firstname.lastname@example.org or email@example.com.
By accessing our Website, using our services or Apps, or submitting personal information to us, you consent to the collection, use and sharing of any personal information as set forth in this CCPA Notice, as it may be updated from time to time.
We may collect the following categories of personal information:
In the past twelve (12) months, depending on the individual circumstances, we have collected the following categories of personal information: Identifiers, Protected Characteristics, Geolocation and Internet History.
We do not sell your personal information.
In the past twelve (12) months, depending on the individual circumstances, we have shared the following categories of personal information: Identifiers, Protected Characteristics, Geolocation and Internet History with the following: service providers and third party businesses.
Under the California Consumer Privacy Act, you have the following rights in any personal information held by us:
You may submit verifiable requests concerning any of your rights by contacting us at firstname.lastname@example.org or email@example.com. We will use reasonable methods for verifying that the person making a request to know, data portability or a request to delete is the individual about whom we have collected information. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with written authorization to communicate with your authorized agent.
We will (i) confirm receipt of requests to know, data portability or to delete within 10 days of the request; and (ii) generally respond to requests to know, data portability or to delete within 45 days of the request. If we need additional time to respond to your request beyond the 45 days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional 45 days to respond to your request.
In certain instances, your personal information may not have been collected by us directly, but provided to us by our business customers. In such circumstances, you may contact the business directly concerning your rights, including as to any request to delete your personal information shared with us. In certain circumstances, should you direct your request to us, we may not be required to comply with a deletion request submitted by you directly to the extent that we have collected, used, processed, or retained your personal information in our role as a Service Provider or Contractor to the business.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
We have in place reasonable technical, administrative and physical safeguards to protect your information. Unfortunately, due to the nature of the Internet, unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We do not guarantee or warrant that the techniques we employ will prevent unauthorized access to information about you that we store.
For California Residents: California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personally identifiable information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person (“Data Subject”), and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Certain information we collect may not be “Personal Data” to the extent it does not identify you.
We will only process your Personal Data if we have a lawful basis for doing so including:
We will not use your Personal Data in connection with any automated decision making process or for any profiling purpose.
We may collect the following Personal Data: Name, address, email address, IP address, and identifying technical information concerning your use of our Virtual Try On and other services, such as information from your visits to our website or applications, and your device and session.
You have the following rights in your Personal Data held by Luna:
You may contact us at firstname.lastname@example.org or email@example.com concerning your rights. If are covered by the GDPR, you have the right to lodge a complaint with an EU supervisory authority.
If you wish to make a formal request for information we hold about you, you can contact us at firstname.lastname@example.org or email@example.com.
For EU residents using 6over6 products, Apps or services, PRIGHTER has been designated as 6over6’s representative in the European Union and the UK for data protection matters pursuant to the GDPR or UK GDPR, as applicable. PRIGHTER may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please visit https://prighter.com/q/15084591.
6over6 has appointed PrivacyTeam as our Data Protection Officer (DPO), for monitoring and advising on 6over6’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by 6over6, you can contact firstname.lastname@example.org.
Ditto along with 6over6, Premium Vision, and ExpressExam have joined forces to bring an integrated offering to the vision industry — rebranding as Luna.