LUNA LABS LIMITED

PRIVACY POLICY

Last Updated: March 17th, 2021

  1. INTRODUCTION AND GENERAL TERMS

This privacy policy sets out how we use data relating to you that you provide to us, or that we may collect, through our website lunalabs.io and its subdomains (the “Website”).  The Website is owned and operated by Luna Labs Limited, a company registered in England and Wales under company number 11617484 and with our registered office at 1-2 Charterhouse Mews, London, United Kingdom, EC1M 6BB (“Luna”,“we”, “us” or “our”).

If you have any questions or comments about this Privacy Policy please contact us on [email protected]

This policy explains what personal information we collect from you and how that information will be processed. Where we decide the purpose or means for which personal data you supply through these online services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

This policy explains the following:

• What information we may collect about you

• How we will use information we collect about you

• Whether we will disclose your details to anyone else

• Your choices and rights regarding the personal information you have provided to us.

The Website may contain hyperlinks to websites owned and operated by third parties.  They will govern the use of personal information you submit or which is collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of them is at your own risk.

For purposes of the California Consumer Privacy Act, this Privacy Policy serves as both the Privacy Policy and Notice at Collection of Personal Information.

  1. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

  1. “Submitted Information”

You may give us information about you by filling in forms when using our services, as well as when creating your account during the registration process.  This can include:
your name
your username
your e-mail address
your password; and
your telephone number.

We may also obtain sensitive personal data about you if you voluntarily supply it through the Website.  For example, when you communicate with us via the contact page on the Website.

  1. Job Application Information

When you choose to apply for a job at Luna via the Site, we may request you to provide us with your full name, email address, phone number, link to your Linkedin page, link to your website, and your CV.

  1. Site Information

In relation to your activity on our online services, we may collect information relating to the web address that you arrive from or click through to, pages viewed, page response times, download errors, the length of time you spend on certain pages, page interaction information such as scrolling, clicks, and methods used to browse away from our Website.

We may also collect technical information about your computer and/or device that may identify you, including your IP address, operating system, browser type, time-zone and browser plug-in details through third party analytics providers.  These third party analytics providers may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notice.

  1. Information about you collected from Third Parties (“Content Information”)

We may collect information about you from third party service providers (like marketing partners or public databases) to use along with the information that we collect from you.  Other companies may set their own cookies or similar technologies when you visit the Website. This includes third parties that we have engaged to provide services on our behalf (like website analytics), as well as third parties that deliver content (like videos from YouTube).

  1. WHY WE COLLECT INFORMATION ABOUT YOU

Information Type

Use

Legal Basis under GDPR

Site Information

Operating the Site

Performance of our agreement with you

Analytics and performance measurement

Consent

Measure performance of our marketing campaigns

Consent

Show ads for our services on third party websites to visitors of
the Site (i.e. retargeting campaigns)

Consent

Improve the Site, security, and support

Our legitimate interests

Comply with legal obligations

Compliance with legal obligations to which we are subject

Submitted Information

Operating our services

Performance of our agreement with you

Send emails regarding our services

Legitimate interests

Send you newsletters

Performance of our agreement with you

Comply with legal obligations

Compliance with legal obligations to which we are subject

Job Application Information

Manage your application

Performance of our agreement with you

Offer you with additional positions

Our legitimate interests

Comply with legal obligations

Compliance with legal obligations to which we are subject

Communication Information

Provide you with response to your enquiries, and provide you with
support

Performance of our agreement with you

Manage your communication with us

Performance of our agreement with you

Comply with legal obligations

Compliance with legal obligations to which we are subject


Information to California Residents

The below table summarizes the categories of personal information of California consumers we have collected, disclosed for a business purpose and sold, as well as the purposes for such disclosures or sales and the categories of sources from which we have obtained such personal information in the past 12 months:

Categories of Personal Information 

Categories of sources from which information is collected:

Business or commercial purposes for collection, use, and
sharing:

Disclosed for business purposes to the following categories of
third parties:

Sold to the following categories of third parties:

Personal and online identifiers (such as first and last name,
email address, or unique online identifiers)

The Website

See the “Why we collect Information about you”

Corporate affiliates and service providers

Analytics and Advertising partners

Internet or other electronic network activity information (such
as browsing history, search history, interactions with a website, email, application, or
advertisement)

The Website

See the “Why we collect Information about you”

Corporate affiliates and service providers

Analytics and Advertising partners

Geolocation information

The Website

See the “Why we collect Information about you”

Corporate affiliates and service providers

Analytics and Advertising partners

Other information about you that is linked to the personal
information above

The Website

See the “Why we collect Information about you”

Corporate affiliates and service providers

Not applicable

  1. DATA SHARING

We will share your information with third parties only in the ways that are described in this privacy policy. 

Personnel, Affiliates, Suppliers or Subcontractors: We may disclose your information to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. 

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Merger or acquisition:  If we are involved in a merger, acquisition, or sale of all or a portion of its assets.

Enforcement:  We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect our rights, property or safety or those of our customers or others.

  1. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

If you do provide us with personal information we generally retain it for as long as your account on the Website is active, or as is otherwise necessary for us to provide the Website to you, or as otherwise described in this privacy policy.

  1. Information to Individuals in the European Economic Area, Switzerland, and the United Kingdom

Data subjects have the right to request us to access, rectify or erase personal data that we process, or to restrict or object to its processing in accordance with the provisions of the GDPR. A data subject can submit a request for exercising these rights by sending an email with the request to [email protected] Please note that we will process the request subject to verification of the consumer’s identity.

A data subject that chooses to withdraw consent can do that by the cookie settings available on the Site.

A data subject also has the right to file a complaint with the relevant supervisory authority (e.g. of the consumer’s country or domicile) where we have not addressed the data subject’s concerns.

  1. Information to California Residents

A consumer who is a California resident may exercise the following rights regarding his/her personal information, subject to certain exceptions and limitations:

  1. The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about the consumer, the categories of sources from which we collected the consumer’s personal information, our purposes for collecting or selling the consumer’s personal information, the categories of personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
  2. The right to request that we delete the personal information we have collected or maintain about the consumer.
  3. The right to opt out of our sale(s) of the consumer’s personal information. If a consumer opts out of certain types of sales, we will be unable to provide that consumer with the services that rely on such sales.
  4. The right not to receive discriminatory treatment for the exercise of the above privacy rights conferred by the CCPA.

How to Exercise Consumer Rights

A consumer can submit a request by sending an email to [email protected]

A consumer may also designate an authorized agent to make a CCPA request on the consumer’s behalf by verifying the consumer’s identity and providing the agent with a written permission to make the request on the consumer’s behalf.

A parent or a guardian of a child under the age of 13 may submit a request on the child’s behalf as described above.

  1. Verification Process and Required Information

We may need to request additional information from you to verify your identity or process your request. We will require you to provide, at a minimum, your email address. We will also ask you to provide us a few of your device identifiers, so that we can verify your identity. Once we verify your identity, we will request additional information necessary to authenticate the request.

For purposes of the CCPA, this section of the Privacy Policy also serves as a notice of the right to opt out of sale of personal information.

  1. CHILDREN

You should be at least 18 to use our Website and register an account on our Website.  We do not use the Website to knowingly solicit data from or market to children under the age of 18.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us via the contact details detailed at the top of this privacy policy. We will delete such information from our files within a reasonable time.

  1. INTERNATIONAL DATA TRANSFERS

We may transfer your data outside of the EEA to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

  1. COOKIES

A cookie is a text file placed onto your device when you access the Website. We use cookies and other online tracking devices such as web beacons, and flash object storage for purposes such as delivering, improving and monitoring the Website, keeping you logged in, remembering your preferences with respect to how our Website functions, for analytics and marketing purposes.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

It is easy to prohibit certain cookies. You can do so by editing your preferences through the Website’s cookie settings link. In addition, Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of the Website.

  1. CHANGES

We may make changes to this policy from time to time, and such changes will be posted on this page.  You should check this page from time to time to ensure that you are aware of any changes.  Where appropriate we may notify you of any changes by email.

  1. Contact Us

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email to [email protected], and we will make an effort to reply within a reasonable timeframe. For reporting any security-related issues, please send an email to [email protected].

Data Protection Officer

Luna Labs Limited

[email protected]

121 Menachem Begin Rd., Tel Aviv, Israel

Attn: Data Protection Officer

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