Privacy Policy

1. Interpretation and Definitions

1.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.2 Definitions

For the purposes of this Privacy Policy:

• Company(referred to as either “the Company”, “we”, “us”, or “our” in this Agreement) refers to Lunere Digital.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Personal Data means any information that relates to an identified or identifiable individual. This includes, but is not limited to, name, email address, phone number, IP address, device identifiers, browsing data, and any other data that can directly or indirectly identify you.
• Service refers to the website located at luneredigital.com, all associated landing pages, advertisements, forms, client portals, AI-powered tools, and any related digital services or platforms operated by Lunere Digital.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the 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, the duration of a page visit, pages viewed, links clicked, and similar analytical 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 several different types of information for various purposes to provide and improve our Service to you:

2.1 Personal Identification Information

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. This may include, but is not limited to:

• First name and last name
• Email address
• Phone number (including mobile number for SMS communications)
• Business name and industry
• Mailing address, city, state, ZIP/postal code, and country
• Social media profiles or handles

2.2 Technical Information

We automatically collect certain technical information when you visit our website, including:

• IP address
• Browser type and version
• Device type and operating system
• Device identifiers (advertising IDs, cookie IDs)
• Screen resolution and language preferences
• Referring website or source

2.3 Usage Data

We collect Usage Data automatically when you interact with our Service. Usage Data may include information such as:

• Pages visited and time spent on each page
• Links clicked and navigation paths
• Date and time of your visit
• Frequency and recency of visits
• Form submissions and interactions with page elements
• Scroll depth and engagement metrics

2.4 Transaction Information

If you make a purchase or engage our services, we may collect transaction-related data including billing address, payment method details (processed securely through our payment processor), purchase history, and service subscription information.

2.5 Other Information

We may also collect information you voluntarily provide, such as preferences, notes, or messages submitted through our contact forms, chat widgets, AI-powered assistants, surveys, or direct communications with our team.

3. How We Use Your Information

We use the collected data for various purposes:

3.1 Lawful Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we rely on the following lawful bases to process your Personal Data:

• Article 6(1)(a) - Consent: You have given clear consent for us to process your Personal Data for a specific purpose, such as receiving marketing communications or SMS messages.
• Article 6(1)(b) - Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g., delivering our web design and marketing services).
• Article 6(1)(c) - Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject (e.g., tax and accounting requirements, responding to lawful requests from authorities).
• Article 6(1)(f) - Legitimate Interest: Processing is necessary for the purposes of legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms (e.g., improving our services, preventing fraud, ensuring network security).

4. Information Sharing and Disclosure

We do not sell or rent your Personal Data to third parties. We may share your information in the following circumstances:

4.1 Service Providers

We may share your Personal Data with third-party service providers who perform services on our behalf, including but not limited to:

• GoHighLevel: CRM, email marketing, SMS communications, pipeline management, and client portal services.
• Stripe: Secure payment processing and billing management.
• Whop & Skool: Community platform management and digital product delivery.
• Retell AI: AI-powered voice and conversational agent services.
• Meta & Google: Advertising, analytics, and audience targeting services (including Meta Pixel and Google Analytics).
• Slack: Internal team communications and client collaboration notifications.
• Make / Zapier: Workflow automation and integration services connecting our various tools and platforms.

These service providers are contractually obligated to use your Personal Data only as necessary to provide their services to us and in accordance with this Privacy Policy.

4.2 Business Transfers

If Lunere Digital is involved in a merger, acquisition, asset sale, or other business transaction, your Personal Data may be transferred as part of that transaction. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

4.3 Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

4.4 Legal Requirements

We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court, government agency, or regulatory body). We may also disclose your data to:

• Comply with a legal obligation
• Protect and defend the rights or property of Lunere Digital
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

4.5 Explicit Consent

We may share your Personal Data for any other purpose with your explicit consent.

Important: We do not share, sell, rent, or trade your mobile phone number or any personal information collected through SMS opt-in with any third parties for promotional or marketing purposes. Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.

5. Retention of Your Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

• General business and transactional records: Retained for up to 6 years after the end of the business relationship, in accordance with applicable tax and commercial law requirements.
• SMS consent records: Retained for a minimum of 5 years from the date consent was obtained, in accordance with TCPA and carrier requirements.
• Marketing consent records: Retained for the duration of the consent plus 5 years after consent is withdrawn or the marketing relationship ends.

Usage Data is generally retained for a shorter period, except when it is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

6. Transfer of Your Personal Data

Your information, including Personal Data, may be processed at our operating offices and in any other places where the parties involved in the processing are located. This means that your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we will ensure that any transfer of your Personal Data to countries outside these regions is protected by appropriate safeguards, including:

• Transfers to countries that the European Commission has deemed to provide an adequate level of data protection.
• Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office (ICO).
• Other legally recognized transfer mechanisms as appropriate.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to such transfers.

7. SMS Messaging and Consent

7.1 Types of SMS Messages

We may send the following types of SMS messages:

• Transactional messages: Appointment reminders, service updates, account notifications, delivery confirmations, and other messages directly related to your use of our Service.
• Marketing messages: Promotional offers, discounts, new service announcements, event invitations, and other commercial communications.

7.2 Consent Mechanism

We obtain your explicit, affirmative consent before sending you SMS messages. Marketing SMS opt-in checkboxes are never pre-selected. Consent is obtained through clear, conspicuous opt-in mechanisms such as web forms, text-to-join keywords, or paper forms. Consent to receive SMS messages is not a condition of purchasing any goods or services from Lunere Digital.

7.3 Required Disclosures

At the point of opt-in, you will be informed of the following:

• The identity of the business sending the messages (Lunere Digital)
• That you are consenting to receive recurring automated text messages
• That message and data rates may apply
• The frequency of messages (e.g., “Message frequency varies”)
• How to opt out (e.g., “Reply STOP to unsubscribe”)
• How to get help (e.g., “Reply HELP for help”)
• A link to our Privacy Policy and Terms of Service

7.4 Time-of-Day Compliance

We will not send marketing SMS messages before 8:00 AM or after 9:00 PM in the recipient's local time zone, in accordance with TCPA regulations and industry best practices. Transactional messages may be sent outside of these hours when they are time-sensitive and directly related to your requested services.

7.5 Do-Not-Call (DNC) Compliance

We maintain an internal Do-Not-Call list and honor all opt-out requests. We scrub our contact lists against the National Do-Not-Call Registry and applicable state DNC lists prior to sending marketing communications. Numbers on these lists will not receive marketing SMS messages from us.

7.6 One-to-One Consent

Consent is specific to Lunere Digital and will not be shared with or used by any other company or brand. Each opt-in applies only to the specific message campaign or program described at the time of consent. We do not bundle consent across unrelated messaging programs.

7.7 Content Restrictions

Our SMS messages will not contain:

• SHAFT content (Sex, Hate, Alcohol, Firearms, Tobacco)
• Illegal cannabis-related content
• Misleading or deceptive claims
• Phishing links or malicious URLs
• Content that violates carrier acceptable use policies

7.8 Record Retention

We retain records of SMS consent (including the timestamp, source of opt-in, and the exact language presented at opt-in) for a minimum of 5 years from the date consent was obtained. These records are maintained for compliance with TCPA, CTIA, and carrier requirements.

7.9 Opt-Out

You may opt out of receiving SMS messages at any time by replying STOP to any message you receive from us. Upon receipt of your opt-out request, we will send you a single confirmation message and remove you from our messaging list within a reasonable time frame. You may also contact us directly at luis.johnson@luneredigital.com to request removal from our SMS list. Opting out of SMS messages will not affect your ability to use our other services.

Message and data rates may apply. Message frequency varies.

8. Data Security

The security of your Personal Data is important to us. We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption of data in transit using TLS/SSL
• Secure storage of data with access controls
• Regular security assessments and vulnerability testing
• Employee training on data protection and security practices
• Use of reputable third-party service providers with strong security track records

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and affected individuals in accordance with applicable data protection laws.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Tracking technologies used may include beacons, tags, pixels, and scripts to collect and track information and to improve and analyze our Service.

Types of Cookies We Use

• Essential Cookies: These cookies are necessary for the website to function properly. They enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
• Performance / Analytics Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and anonymous.
• Marketing / Targeting Cookies: These cookies may be set through our site by our advertising partners (such as Meta Pixel and Google Analytics). They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They are based on uniquely identifying your browser and internet device.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

10. Your Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your Personal Data:

• Right of Access: You have the right to request copies of your Personal Data that we hold.
• Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete any information you believe is incomplete.
• Right to Erasure: You have the right to request that we erase your Personal Data, under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
• Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Object: You have the right to object to processing of your Personal Data where we are relying on legitimate interests as the lawful basis, and there is something about your particular situation which makes you want to object to processing on this ground.
• Right to Opt-Out of Marketing: You have the right to opt out of receiving marketing communications from us at any time by clicking the unsubscribe link in our emails, replying STOP to our SMS messages, or contacting us directly.

10.1 Exercising Your Rights

To exercise any of these rights, please contact us at luis.johnson@luneredigital.com. We may need to verify your identity before processing your request. Please provide sufficient information to allow us to verify your identity (we will match information you provide to information we already have on file).

We will respond to your request within 30 days. If we need more time (up to an additional 60 days), we will inform you of the reason and the extension period. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.

11. Disclosure Requirements

We may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

12. Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Children's Privacy

Our Service is not directed to anyone under the age of 18 (“Children” or “Minors”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers promptly.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top of this Privacy Policy. If we make material changes, we will provide a more prominent notice (such as adding a statement to our homepage or sending you a notification). You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: luis.johnson@luneredigital.com
• By visiting our website: luneredigital.com

Address: Fliederstr. 10A, Weiden i. d. Opf., 92637, Germany

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of Weiden in der Oberpfalz, Bavaria, Germany, without regard to conflict of law principles. For additional governing law provisions and dispute resolution procedures, please refer to our Terms and Conditions.

17. Additional Disclosures

16.1 California Residents - CCPA/CPRA

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information. These rights include:

• Right to Know: You have the right to request that we disclose what categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collecting or selling it, and the categories of third parties with whom we share it.
• Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.
• Right to Correct: You have the right to request that we correct inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information. We do not sell your personal information. However, some of our use of cookies and tracking technologies for advertising purposes may be considered “sharing” under CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information to what is necessary for us to perform our services.

To submit a request under the CCPA/CPRA, please contact us at luis.johnson@luneredigital.com. We will verify your identity before fulfilling any request. You may designate an authorized agent to make a request on your behalf. We will respond to verifiable requests within 45 days.

16.2 Virginia Residents - VCDPA

If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) provides you with specific rights regarding your personal data, including:

• Right to Access: You have the right to confirm whether we are processing your personal data and to access that data.
• Right to Correct: You have the right to correct inaccuracies in your personal data.
• Right to Delete: You have the right to delete personal data you have provided to us or that we have obtained about you.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and readily usable format.
• Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

To exercise your rights under the VCDPA, please contact us at luis.johnson@luneredigital.com. We will respond to your request within 45 days. If we decline to take action on your request, you may appeal that decision by contacting us. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

16.3 Colorado Residents - CPA

If you are a Colorado resident, the Colorado Privacy Act (CPA) grants you the following rights:

• Right to Access: You have the right to confirm whether we are processing your personal data and to access that data.
• Right to Correct: You have the right to correct inaccuracies in your personal data.
• Right to Delete: You have the right to delete personal data you have provided to us or that we have obtained about you.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
• Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling.

To exercise your rights under the CPA, please contact us at luis.johnson@luneredigital.com. We will respond to your request within 45 days. If we decline to take action, you may appeal that decision by contacting us. If your appeal is denied, you may contact the Colorado Attorney General to submit a complaint.