Effective Date: January 4, 2026
Company: Lunere Digital
Contact Email: [email protected]
1. Interpretation and Definitions
Company ("Lunere Digital", "the Company", "we", "us", or "our") refers to Lunere Digital.
Device means any device that can access the Service, such as a computer, mobile phone, or digital tablet.
Personal Data means any information relating to an identified or identifiable natural person.
Service refers to our website, advertisements, landing pages, forms, applications, and any related services offered by the Company.
Service Provider means any natural or legal person who processes data on behalf of the Company, including third-party companies or individuals who facilitate the Service, provide services on our behalf, or assist us in analyzing how our Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, page response times, pages visited, and interaction data).
You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
2. Information We Collect
We may collect and process the following categories of information:
Personal Identification Information
First and last name
Email address
Phone number
Location details such as address, city, state, country
Technical Information
IP address
Browser type and version
Device identifiers and device type
Operating system
Referring URLs and exit pages
Usage Data
Pages and content viewed
Time and date of visits
Time spent on pages
Clicks, interactions, and navigation paths
Transaction Information
Payment-related details (processed via third-party processors)
Records of services purchased or subscribed to
Other Data You Provide
Personal preferences
Requirements, notes, or comments submitted via forms, chat, or email
Any additional information you choose to provide voluntarily
3. How We Use Your Information
We process your Personal Data for the following purposes:
To provide and maintain the Service:
Operating, hosting, and delivering our website, ads, funnels, and related services; monitoring usage and performance.
To manage your account and relationship with us:
Setting up and managing user accounts, client records, and communication history.
To perform and fulfill contracts:
Fulfilling obligations arising from contracts between you and us, including provision of purchased services.
To communicate with you:
Contacting you by email, telephone, SMS, or other electronic means for transactional updates, confirmations, security notifications, service-related information, and customer support.
For marketing and promotional purposes:
Providing you with news, special offers, and information about services similar to those you have purchased or inquired about, unless you opt out.
To process payments and prevent fraud:
Facilitating payments and preventing or detecting fraudulent transactions.
To manage your requests:
Responding to inquiries, support tickets, and exercise of privacy rights.
For business transfers:
Evaluating or conducting mergers, acquisitions, restructuring, asset sales, or similar transactions, where Personal Data may be part of the transferred assets.
For analytics and improvement:
Conducting data analysis, identifying usage trends, measuring campaign performance, and improving our Service, products, and user experience.
To comply with legal and regulatory obligations:
Fulfilling record-keeping, tax, and other statutory obligations.
3.1. Lawful Basis for Processing
We process your Personal Data only where we have a lawful basis under applicable law. Depending on the purpose, our lawful bases are:
Consent (GDPR Article 6(1a)):
For SMS marketing and promotional messages, email newsletters and marketing communications, and non-essential cookies. You provide explicit, separate consent for each category. You may withdraw consent at any time by contacting us.
Contract (GDPR Article 6(1b)):
For payment processing, service delivery and account management, transactional SMS (appointment reminders, confirmations, payment notifications), and fulfilling obligations under any agreement between you and us.
Legitimate Interest (GDPR Article 6(1f)):
For analytics, understanding usage trends, preventing fraud and security threats, website improvement and service optimization, and business operations management. These interests are balanced against your privacy rights. You have the right to object to this processing.
Legal Obligation (GDPR Article 6(1c)):
For tax records and accounting, compliance with laws requiring data retention (such as telemarketing and communications laws), and responding to lawful requests from governmental authorities.
4. Information Sharing and Disclosure
We do not sell or rent your Personal Data to unaffiliated third parties. We also do not share mobile information (phone numbers, opt-in data, consent records) with third parties or affiliates for their own marketing or promotional purposes.
We may share your information in the following limited circumstances:
With Service Providers:
With vetted third-party vendors who provide services such as hosting, analytics, SMS delivery platforms, email service providers, CRM systems, payment processors, or customer support tools, solely to support or enhance the Service and customer experience. All Service Providers are bound by data protection agreements.
For Business Transfers:
In connection with any merger, sale of Company assets, financing, acquisition, or similar transaction, where Personal Data may be transferred as part of the business assets.
With Affiliates:
With our affiliates, subsidiaries, or parent entities, provided they are bound to honor this Privacy Policy or substantially similar protections.
For Legal Requirements:
Where required to do so by law or in response to valid legal process, including court orders, subpoenas, governmental or regulatory requests.
With Your Explicit Consent:
Where you have expressly authorized us to share your information for a specific purpose.
Important: Mobile information (including phone numbers, SMS opt-in data, and consent records) will not be shared with third parties or affiliates for their own marketing or promotional purposes under any circumstance.
5. Retention of Your Personal Data
We retain your Personal Data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, including:
To fulfill the purposes for which the data was collected
To comply with applicable legal, tax, accounting, and regulatory requirements
To resolve disputes and enforce our agreements
To defend against legal claims
By way of example, we may retain:
General customer and transaction records for up to six (6) years or longer where required by tax and commercial laws.
SMS opt-in and consent records (including timestamp, phone number, consent text, IP address, and method of collection) for at least five (5) years or as otherwise required under applicable telemarketing and communications laws (TCPA).
Marketing consent records for the duration of your relationship with us plus five (5) years after opt-out to defend against disputes.
When Personal Data is no longer required, we will delete it or anonymize it so that it can no longer be associated with you. Where deletion is not possible due to legal requirements, we will restrict access to such data.
6. Transfer of Your Personal Data
Your information, including Personal Data, may be transferred to and processed on servers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.
For Users in the European Economic Area (EEA), United Kingdom, or Switzerland:
If your data is transferred outside of these regions, we will implement appropriate safeguards, such as:
Standard Contractual Clauses (SCCs) approved by the European Commission, or
Other lawful transfer mechanisms, adequacy decisions, or binding corporate rules, as applicable.
By using the Service and submitting Personal Data, you acknowledge and agree to such transfers, subject to applicable law.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
7. SMS Messaging and Consent
We offer SMS messaging services as part of our Service. Consent to receive SMS messages is managed according to the following categories:
7.1. Types of SMS Messages
We distinguish between two types of SMS messages, each with different consent requirements:
Transactional/Informational SMS (Implied or Contractual Consent)
These messages are essential to the service and include:
Appointment confirmations and reminders
Service updates and security alerts
Payment confirmations and billing notifications
Customer support responses
Account status updates
These can be sent based on contractual necessity or implied consent.
Marketing/Promotional SMS (Explicit Written Consent Required)
These messages are promotional in nature and include:
Special offers and promotions
New service announcements
Upsells and cross-sells
Campaign communications
Recurring marketing campaigns
These messages require prior express written consent with clear disclosure of marketing intent.
7.2. Consent and Opt-In Mechanism
For Marketing SMS:
We obtain your explicit, written consent through clear and conspicuous opt-in mechanisms, such as:
An online form with an unchecked checkbox and explicit SMS consent language
An SMS keyword opt-in (e.g., texting "YES" to confirm subscription)
Double opt-in flow (submit number + confirm via SMS reply)
Before you consent, we present clear language that states:
"I agree to receive recurring automated marketing and promotional text messages from Lunere Digital"
"Message and data rates may apply, depending on your mobile carrier plan"
"Message frequency varies depending on our campaigns"
"I can opt out anytime by texting STOP to the number I receive messages from"
"Consent is not a condition of purchase or service"
Checkboxes are never pre-selected. You must actively and affirmatively opt in.
For Transactional SMS:
Consent may be implied when you provide your phone number in the course of using our Service (e.g., during checkout or account setup). However, we still provide notice that we may send transactional SMS.
7.3. Required Disclosures and Terms
Each SMS Message:
Will identify Lunere Digital as the sender
Will include the number to contact for assistance (HELP)
Will include the number to opt out (STOP)
Message Frequency and Costs:
Message frequency varies depending on your interactions with us and the campaigns you've opted into
Message and data rates may apply, depending on your mobile carrier plan
Assistance and Opt-Out:
Text HELP for assistance regarding SMS messaging
Text STOP at any time to opt out of receiving further SMS messages from us
After you send STOP, we may send one final message confirming your opt-out request
Your opt-out request will be honored within ten (10) business days or sooner
Consent is Not a Condition of Purchase:
You may use our Service without consenting to receive marketing SMS
Declining marketing SMS will not affect your ability to purchase or access services
7.4. Time-of-Day and Time Zone Compliance
To comply with TCPA requirements, we will:
Send all marketing SMS only between 8:00 AM and 9:00 PM in the recipient's local time zone
Adjust for daylight saving time changes in the recipient's jurisdiction
Honor stricter state-specific time restrictions where applicable (e.g., Florida, Oklahoma, Washington)
Use automated systems and technical controls to prevent sending outside these windows
Never send marketing SMS on Sundays or federal holidays in the recipient's jurisdiction without express prior consent to do so
For transactional SMS (appointment reminders, payment confirmations, account alerts), we may send messages outside these hours if:
The message is non-promotional in nature
You have provided consent to receive such messages
Permitted by applicable law
7.5. Do Not Call and Number Validity Compliance
We are required by law to compare our contact lists against applicable registries before sending marketing SMS:
National Do-Not-Call (DNC) Registry
Reassigned Number Database (RND)
Internal do-not-contact lists maintained by Lunere Digital
State-specific registries (as applicable)
We will not send marketing SMS to numbers on these registries unless the recipient has provided express prior consent that overrides their registry status.
Carrier Registration:
We maintain compliance with carrier and industry registration requirements, including proper registration of our SMS sending phone numbers and messaging protocols with major U.S. carriers (such as 10DLC or Short Code registration).
7.6. One-to-One Consent (Effective January 26, 2026)
Your consent to receive SMS from Lunere Digital applies specifically to the phone number from which you receive our messages.
If our sending number changes (due to carrier changes, infrastructure updates, or other reasons), we will:
Send you a new opt-in request from the new number
Not automatically send messages from a new number without your fresh consent
Maintain your opt-out status across all numbers we use
You are not obligated to re-consent to messages from a new number unless you choose to do so.
7.7. Content Restrictions and Compliance
Our SMS messages will not contain:
Content related to sex, hate speech, or illegal drugs
Unsubstantiated health claims or medical advice
Lottery, gambling, or prize-related content
Illegal content or activity
Our SMS messages related to alcohol, firearms, tobacco, or high-risk products will:
Only be sent to recipients who have explicitly consented and where legally permitted
Comply with all applicable state and federal regulations
Include appropriate disclaimers where required
7.8. Consent Record Retention
We maintain detailed records of all SMS opt-in consents for a minimum of five (5) years, including:
Exact timestamp of consent
Phone number provided
Exact consent text presented to user
IP address and device information
Method of collection (web form, SMS keyword, double opt-in, etc.)
Identity of consenting party (individual name or business entity)
These records are maintained to:
Defend against disputes or legal claims
Comply with TCPA recordkeeping requirements
Demonstrate lawful basis for SMS communications
7.9. Opt-Out and Revocation of Consent
You may opt out of receiving SMS messages at any time by:
Texting STOP to the number from which you are receiving our messages
Contacting us at [email protected] with your request
Replying "STOP" to any marketing SMS message
We will:
Honor all opt-out requests within ten (10) business days or sooner
Send one final confirmation message (non-promotional) acknowledging your opt-out
Remove you from all marketing SMS lists immediately
Continue to send transactional messages if necessary for your account
After opting out:
You will no longer receive marketing or promotional SMS from us
We may still send transactional SMS (account confirmations, appointment reminders, security alerts) where permitted by law
Your request will remain in effect even if you later re-use our Service
8. Data Security
We implement appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
Such measures may include, where appropriate:
Encryption in transit (SSL/TLS) and/or at rest
Access controls and multi-factor authentication mechanisms
Regular review and limitation of access rights
Secure data backup and recovery procedures
Regular security assessments and penetration testing
Employee training on data protection and privacy
However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
You acknowledge that transmission of data over the Internet carries inherent security risks, and we cannot be held liable for breaches occurring through no fault of our own or through causes beyond our reasonable control.
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect and store certain information when you visit or interact with our Service.
We use these technologies to:
Recognize your browser or Device
Store your preferences and settings
Analyze usage, traffic patterns, and performance
Improve the functionality and user experience of the Service
Prevent fraud and protect security
Measure the effectiveness of marketing campaigns
Types of Cookies:
Essential cookies: Required for the Service to function (no consent needed)
Performance cookies: Measure usage and improve the Service (consent required in EU)
Marketing cookies: Track behavior for personalized advertising (consent required)
You may configure your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Service may become unavailable or may not function properly.
Where required by law, we will request your explicit consent before placing non-essential cookies on your device. You can withdraw cookie consent at any time through your browser settings.
10. Your Rights
Depending on your location and applicable law, you may have some or all of the following rights regarding your Personal Data:
Right of Access:
To request confirmation as to whether we process your Personal Data and, if so, to obtain a copy of that data in a portable, human-readable format.
Right to Rectification:
To request correction of inaccurate, incomplete, or outdated Personal Data.
Right to Erasure ("Right to be Forgotten"):
To request deletion of your Personal Data, subject to legal or contractual retention requirements or where we have a legitimate ongoing basis for processing.
Right to Restrict Processing:
To request restriction of processing where you contest the accuracy of the data, object to processing, or where processing is unlawful.
Right to Data Portability:
To request that we provide your Personal Data in a structured, commonly used, and machine-readable format (such as CSV), where technically feasible, and to transmit that data to another controller.
Right to Withdraw Consent:
Where processing is based on your consent, you may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
Right to Object:
Where we rely on legitimate interests for processing, you may object to such processing. We will assess your objection and stop processing unless we have compelling legitimate grounds to continue or a legal obligation to retain the data.
Right to Opt-Out of Marketing:
You may opt out of receiving marketing emails by clicking the unsubscribe link in our emails, and may opt out of SMS marketing by texting STOP as described in Section 7.
10.1. Exercising Your Rights
To exercise any of these rights, please contact us at [email protected] with:
Your full name
The email address or phone number associated with your account
A clear description of your request
Any additional information to help us locate your data
We may need to verify your identity before responding to your request to ensure data security.
Response Timeline:
We will respond to your request within thirty (30) days of receipt
We may extend this period by two additional months if the request is complex or if we receive multiple requests
We will inform you of any extension and the reasons for the delay
11. Disclosure Requirements
We may disclose Personal Data where we reasonably believe such disclosure is necessary to:
Comply with any applicable law, regulation, legal process, or governmental request (including court orders, subpoenas, and regulatory investigations)
Enforce our agreements and terms, including for billing and collection
Protect the rights, property, or safety of Lunere Digital, our customers, or others
Investigate, prevent, or take action regarding suspected illegal activities, fraud, unauthorized access, security threats, or violations of this policy
Protect against legal liability
Comply with subpoenas or other legal process
When we disclose Personal Data in response to legal requests, we will:
Provide notice to the affected individual where legally permitted
Limit disclosure to the extent required by law
Maintain records of such disclosures
12. Links to Other Websites
Our Service may contain links to third-party websites or services that are not owned or controlled by Lunere Digital.
We are not responsible for the content, privacy policies, or practices of any third-party websites or services. We strongly advise you to review the privacy policy of every website you visit.
This Privacy Policy applies only to information collected through our Service. Once you leave our Service via a third-party link, you are subject to that third party's privacy policy, and we have no control over or responsibility for their data practices.
13. Children's Privacy
Our Service is not directed to, and we do not knowingly collect Personal Data from, individuals under the age of 18.
If we become aware that we have collected Personal Data from a child under 18 without verifiable parental consent, we will take appropriate steps to delete such information as soon as reasonably practicable.
If you believe a child has provided Personal Data to us, please contact us immediately at [email protected], and we will delete the information.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we do, we will:
Revise the "Effective Date" at the top of this page
Notify you of material changes via email or by posting a prominent notice on our website
Require your consent to material changes where required by law
Your Continued Use:
Your continued use of the Service after the posting of changes constitutes your acceptance of such changes, to the extent permitted by applicable law. If you do not agree with any changes, you may discontinue your use of the Service.
We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.
15. Contact Us
If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our data practices, you may contact us at:
Lunere Digital
Email: [email protected]
We will respond to all inquiries and complaints in accordance with applicable law, typically within thirty (30) days of receipt.
If you are located in the European Union and have concerns about how we process your data, you have the right to lodge a complaint with your local data protection authority.
16. Additional Disclosures for Specific Jurisdictions
16.1. California Residents (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
Right to know what personal information is collected, used, shared, or sold
Right to delete personal information collected from you (with certain exceptions)
Right to opt-out of the "sale" or "sharing" of personal information
Right to correct inaccurate personal information
Right to limit use and disclosure of sensitive personal information
Right to not be discriminated against for exercising your privacy rights
We do not "sell" your personal information. We do not "share" personal information for cross-context behavioral advertising.
To submit a request, contact us at [email protected].
16.2. Virginia Residents (VDPA)
If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act (VDPA):
Right to access personal data
Right to correct inaccurate personal data
Right to delete personal data
Right to opt-out of targeted advertising, sales of personal data, and profiling
To exercise these rights, contact us at [email protected].
16.3. Colorado Residents (CPA)
If you are a Colorado resident, you have rights under the Colorado Privacy Act (CPA):
Right to access personal data
Right to correct personal data
Right to delete personal data
Right to opt-out of targeted advertising, sales of personal data, and profiling
To exercise these rights, contact us at [email protected].