Privacy Policy

Summary of Key Points

This summary provides key points from our Privacy Notice. For complete details, review the full policy below.

Full Privacy Policy

1. What Information Do We Collect?

Personal Information Provided by You

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include:

• Email addresses
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data
• Menstrual cycle data (cycle start date, cycle length, phase)
• Workout data (exercises, weights, duration, intensity)
• Fitness goals and training preferences
• Health/injury history

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process:

• Health data
• Menstrual cycle and reproductive health information

Payment Data

All payment data is handled and stored by Apple App Store, RevenueCat, and Google Play Billing. Please review their privacy policies:

• Apple Privacy Policy
• RevenueCat Privacy Policy
• Google Privacy Policy

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services:

• Log and Usage Data — Service-related, diagnostic, usage, and performance information our servers automatically collect
• Device Data — Information about your computer, phone, tablet, or other device you use to access the Services

2. How Do We Process Your Information?

We process your information to:

• Facilitate account creation and authentication
• Deliver and facilitate delivery of services to you
• Respond to your inquiries and provide support
• Send you administrative information
• Fulfill and manage your orders and subscriptions
• Send marketing and promotional communications (with your consent)
• Protect our Services from fraud and security threats
• Identify usage trends
• Determine the effectiveness of our marketing campaigns
• Track cycle phase and provide personalized coaching
• Power Luna AI assistant with user data
• Manage subscriptions and billing
• Collect analytics and improve the app
• Track marketing attribution
• Detect fraud and secure user accounts
• Send engagement notifications

3. What Legal Bases Do We Rely On?

If you are located in the EU or UK:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. We may rely on:

• Consent — We process your information if you have given us permission. You can withdraw your consent at any time.
• Performance of a Contract — We process your information when we believe it is necessary to fulfill our contractual obligations to you.
• Legitimate Interests — We process your information when we believe it is reasonably necessary to achieve our legitimate business interests.
• Legal Obligations — We process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests — We process your information where we believe it is necessary to protect vital interests.

4. When and With Whom Do We Share Your Information?

Vendors and Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us. These include:

• Apple Health (for health data integration)
• Google Cloud Platform and Firebase (cloud computing and storage)
• Apple Pay and Google Play Billing (payment processing)
• Google Analytics for Firebase (analytics)
• AWS (website hosting)
• Firebase Crash Reporting (performance monitoring)
• TestFlight (beta testing)

Business Transfers — We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. Do We Offer AI-Based Products?

Yes, we offer AI-powered products including:

• AI insights
• AI predictive analytics
• Personalized recommendations
• Luna AI Chatbot

How to Opt Out

• Log into your account settings and update your preferences
• Disable Luna AI coaching and switch to non-personalized workouts in the app settings
• Request full deletion of your account by contacting privacy@getlune.app

6. How Do We Handle Social Logins?

If you choose to register or log in using your social media account details (like X/Twitter), we will receive certain profile information about you from your social media provider. This may include your name, email address, friends list, and profile picture.

Please review the privacy policies of your social media providers to understand how they collect and share your personal information.

7. Is Your Information Transferred Internationally?

Our servers are located in the United States. Your information may be transferred to, stored by, and processed in our facilities and in the facilities of third parties with whom we share your personal information.

EU-US Data Privacy Framework

We comply with the EU-US Data Privacy Framework as set forth by the US Department of Commerce. EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.

You may also correct, amend, or delete the personal information we hold about you by contacting privacy@getlune.app. If your Data Privacy Framework complaint cannot be resolved through normal channels, you may invoke binding arbitration. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

8. How Long Do We Keep Your Information?

We keep your information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. We will not keep your personal information for longer than twenty-four (24) months past the start of the idle period of your account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. Do We Collect Information from Minors?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

11. What Are Your Privacy Rights?

Depending on your location, you may have certain rights under applicable data protection laws, including:

• The right to request access and obtain a copy of your personal information
• The right to request rectification or erasure
• The right to restrict the processing of your personal information
• If applicable, the right to data portability
• The right not to be subject to automated decision-making
• In certain circumstances, the right to object to processing

You can make such a request by contacting us at privacy@getlune.app. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK: You have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland: You may contact the Federal Data Protection and Information Commissioner.

Withdrawing Your Consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of the processing before its withdrawal.

Opting Out of Marketing Communications

• Disable push notifications in iOS Settings or within the Lune app notification preferences
• Adjust notification frequency and type in account settings
• Contact privacy@getlune.app

Account Information

• Log in to your account settings and update your user account
• Delete your account and all associated data through the app settings or by contacting privacy@getlune.app

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

12. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

13. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you, correct inaccuracies, delete your personal information, or withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law.

14. Do We Make Updates to This Notice?

Yes, we may update this Privacy Notice to reflect changes in our practices, technology, legal requirements, and other factors. We will notify you of any material changes by updating the "Last updated" date at the top of this Privacy Notice.

15. How Can You Contact Us?

If you have questions or concerns about this Privacy Notice or our privacy practices, please contact us at privacy@getlune.app

16. How Can You Review, Update, or Delete Your Data?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, correct inaccurate data, or request deletion of your information. To make such a request, please contact us at privacy@getlune.app