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Last updated: May 2023
We at Luna Solutions, LLC (together with our affiliated companies – “Luna“, “we“, “our” or “us“) offer an integrated suite of technologies and services (the “Solutions”) to eyewear retailers, brands and doctors all around the world (the “Customer(s)”). This Privacy Policy describes our practices regarding the collection, storage, usage, and disclosure of personal data that relates to identified or identifiable individuals who:
This Privacy Policy does NOT cover our data processing practices regarding individuals who use our Solutions (collectively, “End–Users”). Such Solutions are operated and manages by our business affiliates: Ditto Technologies Inc., Premium Vision LLC, 6over6 Vision Ltd., and Rx Renewal LLC (our “Affiliates”). If you are an End-User of a Solution of one of our Affiliates, please refer to our Solutions Privacy Policy.
Specifically, this Privacy Policy describes our practices regarding –
We respect your privacy and are strongly committed to making our practices regarding your personal data transparent and fair.
Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.
You are not legally required to provide us with any personal data, but without it, we may not be able to provide you with the full range of our Services or with the best user experience when interacting with out Sites.
We may process the following categories of personal data about individuals:
Data received from you: When you request to schedule a demo through the Sites or otherwise interact with us or with our Services, or when you use our Sites, you may provide us with personal data relating to you. This typically includes your name, workplace, position, the content of your message, and contact information (such as professional e-mail and phone number).
Data received from Customers: When you engage with us on behalf of a Customer, you may provide us with certain business data that may contain your personal details, such as your name, position, business email address, and other contact information. Such data may be provided to us directly by you or by your colleagues or managers within the Customer during our business engagement.
Data automatically collected or generated: When you visit or interact with our Services, we may collect, record, or generate certain technical data about you. We do so either independently or with the help of third-party Service Providers (defined in Section 4 below), including through the use of “cookies” and other tracking technologies (in the manner further detailed in Section 5 below).
Usage data relating to the manner in which you use our Services: Such data usually consists of connectivity, technical or aggregated usage data, such as IP addresses and general locations, device and application data (such as type, operating system, mobile device ID, browser version, locale, and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and your recorded activity (sessions, clicks, and other interactions) in connection with our Sites or Services. In addition, phone calls (e.g., with our sales representatives, customer success, etc.) may be automatically recorded, tracked, and analyzed, for purposes such as analytics, service, business quality control and improvements, and record-keeping purposes.
Data received from other third parties: We may receive personal data concerning you from other sources. For example, if you participate in an event, webinar, or promotion that we sponsor or participate in, we may receive your personal data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details, and professional experience, preferences, and interests) from our business partners or service providers and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn and other similar platforms.
Data obtained through Analytics Tools: We use analytics tools (e.g., Google Analytics) to collect data about the use of our Sites. Analytics tools collect data such as how often individuals visit the Sites, which pages they visit and when, and which website, ad, or e-mail message brought them there. For more information on Google Analytics please see Section 4 below.
We use personal data as necessary for the following purposes an in reliance on the lawful basis as further detailed in the chart below:
Purpose | Lawful Basis |
To facilitate, operate, and provide our Services | · Legitimate interests · Performance of contract (to the extent applicable) |
To monitor, study and analyze the use of our Services. | · Legitimate interests · Performance of contract (to the extent applicable) |
To gain a better understanding of how individuals use and interact with our Services, and how we could improve their and others’ user experience and continue improving our offerings and the overall performance of our Services. | · Legitimate interests |
To provide customer service and technical support. | · Legitimate interests · Performance of Contract |
To support and enhance our data security measures, including for purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity. | · Legitimate interests · Performance of a contract · Compliance with legal obligations |
To comply with applicable laws and regulations. | · Compliance with legal obligations |
To contact individuals with general, personalized or services-related messages, as well as promotional messages that may be of specific interest of them. | · Legitimate interests · Performance of a contract · Consent (to the extent applicable) |
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively, including on other websites and applications. | · Legitimate interests · Consent (to the extent applicable) |
To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences. | · Legitimate interests |
To facilitate, sponsor and offer certain events, contests and promotions. | · Legitimate interests · Consent (to the extent applicable) |
To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective Services, conduct research, or for any other purpose. | · Legitimate interests · Performance of a contract · Compliance with legal obligations |
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of our Terms of Use and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@luna.io.
Data Location: Your personal data is maintained, processed and stored by us and our authorized Service Providers (defined below) in the US, the EU and Israel. We may also retain your personal data in other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Luna and its Affiliates are located in various locations such as the USA, EU and Israel. Processing of personal data in Israel is done based on Israel’s adequacy decision published by the European Commission, according to which Israel is a jurisdiction which is considered by the European Commission as offering an adequate level of protection for the personal data of EU Member State residents.
While privacy laws may vary between jurisdictions, Luna and its Affiliates and Service Providers are each committed to protecting personal data in accordance with this Privacy Policy (as well as our specific Affiliates’ privacy policies, where applicable) and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in their jurisdiction. For data transfers from the European Economic Area (EEA), the UK, or Switzerland to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into standard contractual clauses as approved by the European Commission, the UK Information Commissioner’s Office (ICO), or FDPIC. You are entitled to request a copy of the standard contractual clauses used in these cases, and may do so by contacting us at privacy@luna.io.
Data Retention: We will retain your personal data for as long as it is reasonably necessary in order to establish, maintain and expand our relationship and provide you with our Services, Sites and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at privacy@luna.io.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications, and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution, marketing and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization, social and advertising networks, content providers, e-mail, voice-mails, support and customer relation management systems, and our legal, compliance and financial advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Luna or its Affiliates, data subjects, or any members of the general public.
Luna’s Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Luna or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of any of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Sites.
For the avoidance of doubt, Luna may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use Google Analytics – a web analytics tool, which help us understand Visitors’ behavior on our Services, including by tracking page content, and click/touch, movements, and scrolls. We have implemented measures to protect our Visitors’ personal data processed by Google Analytics, such as enabling IP addresses anonymization and limiting their retention periods by default. Further information about the privacy practices Google Analytics is available at www.google.com/policies/privacy/partners/. Further information about your option to opt-out of Google Analytics is available at https://tools.google.com/dlpage/gaoptout.
For more information on our cookie and data collection technologies practices please visit our Cookie Policy. You may also use the “Cookie settings” feature available in our Services depending on your location and activity on our Services, as applicable.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, and special opportunities, or any other information we think you will find valuable. We may provide such notices through any of the contact-means available to us (e.g., phone, mobile, or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Luna at any time by sending an e-mail to privacy@luna.io, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
In order to protect your personal data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 4 above.
Individuals have rights concerning their personal data. Please contact us by email at: privacy@luna.io if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Luna, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request). We may redact from the data which we will make available to you, any personal data related to others.
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Luna is the “data controller” of personal data relating to Visitors, Prospects and Business Contacts. With respect to such personal data, we assume the responsibilities of data controller (solely to the extent applicable under the law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor.”
Luna is the “data processor” or “data controller with respect to personal data relating to End-Users. When Luna processes such data as a data processor, it does so behalf of its Customers, per their instructions and in accordance with the Data Processing Addendum we have with them. If we process End-Users’ personal data as a data controller, we will do so in accordance with our Solutions Privacy Policy.
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy which in our discretion may affect your personal data, we’ll provide you with notice as appropriate under the circumstances. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.
California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention and deletion (Sections 3 and 8) practices. We also included information about how we may process your information (in Sections 2 through 6), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 4 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 4 above.
Our Services are not designed to attract children who are minors: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person who is to be considered as a minor according to the law applicable to him is using the Services, we will attempt to prohibit and block such use and will make efforts to promptly delete any personal data stored with us with regard to such minor. If you believe that we might have any such data, please contact us by e-mail at privacy@luna.io.
Questions, concerns or complaints: If you have any comments or questions regarding this Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact Luna’s support at privacy@luna.io. If you are a GDPR/UK GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or in the UK as applicable to you.
EU & UK Representative: Prighter has been designated as Luna’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 send an email to privacy@luna.io or visit https://prighter.com/q/15084591.
Data Protection Officer (DPO): PrivacyTeam has been designated Luna’s Data Protection Officer (DPO), for monitoring and advising on Luna’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 Luna, you can contact privacy@luna.io.