Privacy Policy

Section 1: Introduction

Hey there! Welcome to Luna’s Privacy Policy. Our goal here is to provide you with all the necessary details regarding your data, how we use it, and how we keep it safe. Let's get started!

First things first, Luna is managed by MyAlchemy.AI LTD, located at Ground Floor, Cromwell House, 15 Andover Road, Winchester, England, SO23 7BT. As the entity responsible for your data, we take privacy seriously and are committed to ensuring your data is handled with care.

This Privacy Policy applies to all services operated under the Luna brand, including our apps, live chats, websites, and events. Whenever you interact with any Luna service, you are covered by this policy. For any specific service requiring a different privacy policy, we will make it available to you.

Section 2: Information Collection

In order to provide our matchmaking services and improve your dating experience, we need to get to know you better. This includes data you provide directly, data generated through your activity in the app, and data from third-party sources. Below is a comprehensive breakdown of the data we collect for the curious:

Account Data: Basic information such as your name, date of birth, phone number and email address provided when creating your account.
Profile Data: Information you provide to complete your profile, including gender, interests, and preferences, some of which may be sensitive data like sexual orientation.
Geolocation Data: With your permission, we may collect your device’s geolocation (latitude and longitude) to be able to introduce you to suitable matches in your location. If you choose not to allow this, certain features that require precise location may be unavailable.
Content: Any photos, videos, or messages you post, as well as your interactions with other members.
Customer Support Data: We collect data when you reach out to us for assistance, such as inquiries or reports you submit. Additionally, other individuals may provide queries or reports that reference you. Where permitted by law, we may also obtain information from third parties about individuals suspected or convicted of misconduct, as part of our commitment to maintaining the safety and security of our members.
Marketing and Research Data: Data from surveys, promotions, and market research studies you participate in.
Transaction Data: Information on transactions you make, including the item purchased, date, and payment details.
Third-Party Data: Information you share with us about other people (e.g. when you share the contact details of a friend or report a member)
Usage Data: We collect data on your activity within the service, such as login times, feature usage, interactions with others, and engagement with ads both on our platform and on third-party sites or apps.
Technical Data: We gather technical data from your device(s) when you access our service, including details like IP address, device ID, software settings, app performance, advertising identifiers, and unique identifiers from cookies or similar technologies; see our Cookie Policy for more details.
Face Geometry Data: You may choose to use features such as Selfie Verification, which collect face geometry data. This may qualify as biometric information in certain jurisdictions.
ID Data: You may provide a government-issued ID to verify your identity.

Section 3: Data Usage

We use your data primarily to provide you with the best matchmaking experience that is personalised for you. By leveraging the information we collect, we continually enhance our recommendations and ensure the safety and security of all our members while using our services.

If you’re interested, here’s a detailed overview of how and why we use your data, the basis for each type of processing, and the categories of data involved:

To enable use of service: This includes creating and maintaining your account, providing access to features, introducing you to other members, responding to your requests, monitoring of our service.
Grounds: Performance of a contract; consent (where sensitive data is processed).
Data categories: Account Data, Profile Data, Content, Purchase Data, Marketing Survey Data, Customer Support Data, Usage Data, Technical Data, Geolocation Data.

To keep you safe: Preventing fraud, detecting violations of our Terms, verifying identity, and protecting user security.
Grounds: Performance of a contract, legitimate interest, compliance with legal obligations, consent.
Data categories: Account Data, Profile Data, Content, Purchase Data, Technical Data, Face Geometry Data, ID Data.

To enable your purchases: Processing payments, customizing offers, and providing discounts.
Grounds: Performance of a contract.
Data categories: Account Data, Purchase Data, Profile Data, Usage Data, Technical Data.

For advertising and marketing campaigns: Running marketing campaigns, promotions, and analyzing their effectiveness.
Grounds: Legitimate interest, consent (where required).
Data categories: Account Data, Profile Data, Usage Data, Marketing Survey Data, Technical Data.

To improve our services on an ongoing basis: Running market studies, analyzing usage data, and testing new features.
Grounds: Legitimate interest, performance of a contract, consent (where required).
Data categories: Account Data, Profile Data, Content, Purchase Data, Marketing Data, Third-Party Data, Usage Data, Technical Data.

To comply with applicable laws: Preserving data to comply with legal obligations or to support investigations.
Grounds: Legitimate interest, compliance with legal obligations.
Data categories: Any necessary categories as required by the specific legal context.

Section 4: Data Sharing Practices

Luna’s goal is to make introductions to build meaningful connections, which requires making certain information about you visible to other members on our platform. We also share data with trusted service providers and partners who support our operations, and, in specific cases, we may share information to comply with legal obligations. Here is a detailed overview of how your data is shared and with whom.

Sharing with Other Members

When you voluntarily provide information on the platform, such as through your public profile, this data becomes visible to other members. In cases where a member submits a report about you (for example, alleging a violation of our Terms of Use), we may inform the reporting user about any actions we took as a result. Similarly, if you submit a report about another user, we may inform you of any resulting actions.

The types of data shared in these cases may include:

Profile Information
Content You Share
Social Media Data
Data from Third Parties
Customer Support Data

Sharing with Our Partners and Service Providers

We work alongside trusted vendors and partners who assist in operating, promoting, and enhancing our platform. These partners deliver key services, including data storage, analytics, customer support, marketing, advertising, payment processing, legal guidance, and security solutions.

The type of data shared with these providers can vary depending on the service they provide and may include:

Account Information
Profile Information
Shared Content
Purchase Information
Marketing, Survey, and Research Data
Data from Third Parties
Customer Support Information
Social Media Data
Usage Data
Technical Information
Geolocation Data
Biometric Information (such as face geometry)
Identification Information

Sharing with Advertising Partners

We may promote our services on third-party websites and apps. To make our ads more relevant, we may provide certain information to third-party advertising partners or allow them to gather data from our platform through technologies such as cookies or SDKs. Some advertising partners help us convert your email address, phone number, or advertising ID into an anonymized code that can't be used to identify you personally. This code may be used to exclude you from certain marketing campaigns or to target ads to audiences with similar characteristics to you.

For users in the United States, some of these activities may fall under the definitions of "targeted advertising," "sharing," or "selling" under applicable laws. You have the right to opt out of these practices as outlined in Section 6.

Data shared with advertising partners may include:

Account Information
Profile Information
Usage Data
Technical Information

Sharing with Law Enforcement Authorities

We may disclose your data to law enforcement agencies or government authorities in certain circumstances, such as when required to comply with legal processes (e.g., court orders, subpoenas, or investigations), to assist in preventing or detecting criminal activity, to protect the safety of individuals, or to assert or defend against legal claims.

The categories of data shared in such situations depend on the specific request but may include:

Account Information
Profile Information
Shared Content
Purchase Information
Customer Support Information
Data from Third Parties
Social Media Data
Usage Data
Technical Information
Geolocation Data
Identification Information

Data Sharing in the Context of Mergers and Acquisitions

In the event of a merger, acquisition, sale, restructuring, or other changes in ownership or control of the company, your data may be transferred to the new owners. The scope of the data shared depends on the specifics of the transaction and could involve all collected data or a subset, such as purchase information.

Section 5: Cross-Border Data Transfers

Your data may be transferred across borders to countries with different data protection laws. We use standard contractual clauses and other safeguards to ensure your data is protected.

Section 6: Exercising Your Rights

Access, Portability, or Right to Know

You have the right to be informed about the personal data we collect and process, and you may request a copy of this information. Some of your data can be accessed and reviewed directly by logging into your account. To obtain a full copy of your data, you can contact us.

Rectification or Correction

You have the right to correct or update any of your personal data that is inaccurate or incomplete. You can easily make updates to certain information, like your profile, through the service. For other corrections, you can reach out to us for assistance.

Opt-out or Restriction

You have the right to object to our processing of your personal data or request that we stop processing it, either temporarily or permanently. If you wish to object to any of the data processing activities outlined in this Privacy Policy, you can contact us.

Consent Withdrawal

You have the right to withdraw any consent you’ve previously given for us to process your personal data for specific purposes.

If you want to withdraw consent, you can do so by contacting us or by adjusting the permissions in your device settings (such as access to contacts, photos, location services, or advertising identifiers, as well as push notifications). Keep in mind that withdrawing consent may affect the functionality of certain services.

Deletion or Erasure

You have the right to request the deletion of your personal data. Some of your data can be deleted directly from within the service, and you may close your account as described in this Privacy Policy, after which your data will be removed according to the policy. You can also contact us at any time if you wish to request the deletion of your data.

Section 7: Retaining Your Data

We retain your personal data for as long as necessary for legitimate business purposes, as outlined in Section 3, and in accordance with applicable laws.

If you choose to discontinue using our service, you have the option to close your account, after which your profile will no longer be visible to other users. Additionally, if your account remains inactive for two years, it will be automatically closed.

Once your account is closed, your personal data will be deleted as described below:

At Luna, we prioritize your privacy and give you the right to request the deletion of your Personally Identifiable Information (PII). When this request is made, we will dissociate your PII—such as your name, email, and phone number—from other data. However, non-identifiable information, including any content you shared (e.g., texts, images, videos), will be retained to help improve our models, enhance the service, and support future developments. By using Luna, you agree to this data retention practice. If you have any questions about how your data is handled, feel free to reach out to our support team.

For the safety of our users, we enforce a security retention period of three months after an account is closed or up to two years after an account has been banned. During this time, we retain data to investigate any potentially harmful or unlawful behavior. This retention is based on both our legitimate interests and the safety of potential third-party victims.

We also keep certain data for legal compliance purposes. For instance, transaction records are kept for 10 years to meet tax and accounting requirements. Credit card information is stored as long as needed for any transaction disputes, and “traffic data” logs are retained for one year to fulfill legal obligations. Additionally, we store records of consents provided by members for five years to demonstrate compliance with applicable laws.

For other legitimate business reasons, we keep customer service records, including location data related to downloads or purchases, for five years to assist in our safety efforts, resolve customer support issues, and protect our rights in case of legal claims. Profile data may be retained for one year in anticipation of potential litigation or for legal claims. Furthermore, data on banned users is retained as long as necessary to prevent those individuals from rejoining, ensuring the ongoing safety of our community.

Lastly, data may be retained if there are unresolved or potential disputes, claims, or legal issues requiring its preservation. This includes situations where we receive a legal subpoena or a formal request to retain data, in which case we must comply to fulfill our legal responsibilities.

Where allowed by law, we may also retain and use anonymized data that cannot be linked back to you for purposes such as improving our service, developing new features, and maintaining a safe and secure environment for all users.

Section 8: Children’s Policy

Luna’s services are only available to individuals aged 18 and above. We actively prevent individuals under 18 from joining the platform. If we suspect someone underage is using Luna, we take action to remove them.

Section 9: Changes to This Policy

As Luna evolves, we may update this Privacy Policy to reflect new features or changes in the law. We will notify you before significant changes take effect.

Section 10: How to Contact Us

If you have any questions or concerns about this policy or your data, feel free to contact us at MyAlchemy.AI LTD, Ground Floor, Cromwell House, 15 Andover Road, Winchester, England, SO23 7BT.