Welcome to https://lunalemon.dev and/or
https://lunatag.lunalemon.dev (each a "Site"), hosted by
Lunalemon.dev ("Lunalemon", "we", "us" and/or "our"). Lunalemon provides a cloud platform for on-demand deployment, related hosting and
sharing services and analytics tools ("Services"). In order to provide our Site and Services (collectively, "Platform"), we collect personal
data from our customers ("Customers"). We also collect and/or host the personal data of our Customer's end users ("End Users") when our
"personal data" refers to any information that is unique to an inpidual, such as name, address, email address, phone number, IP address and
other information that can reasonably identify an inpidual.
Who We Are and How To Contact Us
Lunalemon is a business with following contact information:
21 Pepper Street
Cape Town, 8001
hello@Lunalemon.dev For users in the EEA and the UK, note that we may collect your personal data as a 'data controller' when we determine the means and purpose of processing, such as when we process the personal data of our Site Visitors, Event Attendees and/or Customers, or as a 'data processor' when we collect and process personal data on behalf of our Customers who use our Services and host their own websites with Lunalemon or Customers that use our analytics tools. Similarly, for users in California, we currently act as a ‘service provider’ to those ‘businesses’ that are subject to the California Consumer Privacy Act when we collect and process personal data or information on behalf of our Customers who use our Services and host their own websites with Lunalemon or Customers that use our analytics tools. This is further explained below.
To Whom Does This Policy Apply
terms, conditions, and privacy policies, and ensuring compliance with all applicable laws and regulations.
Customers: as noted above, this includes any inpidual who registers inpidually or on behalf of an entity or organization in order to use the Services.
Site Visitors: visitors to our Site, including those who may also opt in to receive commercial communications from Lunalemon. This does not include any visitors to our Customers' inpidual websites.
Event Attendees: Lunalemon hosts and/or sponsors annual conferences and is an active participant at many other conferences, summits, and additional events (collectively, "Events"), and collects personal information from inpiduals when they attend (or register to attend) Events.
Lunalemon does not knowingly collect information from children under the age of 16. If you are under the age of 16, please do not
submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children's Internet usage and to
If you have reason to believe that a child under the age of 16 has provided personal data to Lunalemon through the Platform, please contact hello@Lunalemon.dev and we will endeavor to delete that information from our databases.
rights, we will promptly notify you of those changes. Your continued use of the Platform after any changes or revisions to this Privacy
What Information Do We Collect
What personal information we collect and process depends on how and why you use our Platform. Generally, we process personal
information that we receive:
Directly from you when you provide it to us, such as in connection with our Services or Event registrations.
Indirectly, through automated technologies such as cookies, or from third parties.
On behalf of our Customers, when we process the personal data of their End Users as part of our Services.
This is all explained in more detail below.
Information We Collect Directly From You
You can generally visit our Site without having to submit any personal information. If you request more information, or sign up for
our Services, we will collect personal information as follows.
Customer Payment Information. You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. In order to process your payment Information, we use PCI-compliant third-party processors, as explained in the Section on "Payment Processing" below. This information is processed by our payment service provider and we receive a confirmation of payment, which we then associate with your Account Information and any relevant transactions.
Optional Information. We may also ask you to submit personal information if you choose to use interactive features of the Platform, including participation in surveys, promotions, requesting customer support, or otherwise communicating with us.
Information We Collect Indirectly
Device and Usage Information
When you download, use or interact with the Site, even if you do not have an account, we, or authorized third parties engaged by us,
may automatically collect information about your use of the Site via your device, some of which is considered personal information.
"Device and Usage Information" that we collect consists of:
Information About your Device: information about the devices and software you use to access the Site — primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size, and other similar technical information.
Usage Information: information about your interactions with the Platform, including access dates and times, hardware and software information, device event information, log data, crash data, cookie data. This information allows us to understand the screens that you view, how you've used the Platform (which may include administrative and support communications with us), and other actions on the Platforms. We, or authorized third parties, automatically collect log data when you access and use the Platform, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users' use of the Platform, and gather broad demographic information for aggregate use.
Note that Device and Usage Information is collected from our community boards, as well as from our Customers' End Users who visit our Customers' websites hosted by Lunalemon or that use our Services.
Based on Device and Usage Information, we are also able to determine general location information ("Location Information").
Location Information: we use a third-party database to map the general location to which each IP address corresponds ("Location Information"). The Location Information that is mapped from an IP address is limited to country and city – we do not identify precise location. We use Location Information in order to more effectively provide our Services to our Customers. In addition, as part of our Services, we also share Location Information (based on End Users’ IP addresses) to our Customers, so that they may also more effectively provide their products and services to their End Users.
Cookies and Similar Technologies
parties collect some Device and Usage Information. Some cookies are necessary to make the Site and our content available to you, while
Information from Third Parties
In some instances, we process personal information from third parties, which consists of data from our partners, such as
transactional data from providers of payment services, or information from third parties with whom we host or sponsor Events. In all such
cases, inpiduals are informed of our processing activities and/or able to choose certain preferences at the time of collection. From
time to time, we may combine information we collect as described above with personal information we obtain from third parties. For
example, we may combine information entered through a Lunalemon sales submission with information we receive from a third-party sales
intelligence platform to enhance our ability to market our Services to Customers or potential Customers.
Information We Process on Behalf of Our Customers
As noted above, we deploy and host websites and provide other analytics tools for our Customers. These Customers may collect personal
information from their End Users in connection with the products or services that they offer to End Users. Because we host our Customers'
websites and provide other analytics tools, we process End Users' information when they use our Customers' websites, web applications, and
APIs. This information may also include, but is not limited to, IP addresses, system configuration information, and other information
about traffic to and from Customers' websites (collectively, the "Log Data"), as well as Location Information derived from IP addresses.
We do not, however, collect or process End Users’ IP addresses through the use of our analytics Services. All of this information is
stored on our Platform as part of our Services, but Customers are responsible for the content transmitted across our network (e.g.,
images, written content, graphics, etc.), as well as any personal information they collect. Customers are also solely responsible for
notifying their End Users of their personal information collection, use, and disclosure. With respect to Log Data, we collect and use Log
Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data
can help us to detect new threats, identify malicious third parties, and provide more robust security protection for our Customers. It
also helps us with improving our Platform, as explained below.
With the Device and Usage Information collected by our third-party analytics services, such as Google Analytics, as well as Log Data,
we generate and process aggregated information, such as statistical or demographic data. Aggregated Information may be derived from personal
data, but may not considered personal data if it does not directly or indirectly reveal your identity. For example, we may track the total
number of visitors to our Platform, or review Log Data, or track the number of visitors to each page of our Site. We aggregate this data to
calculate the percentage of users accessing a specific feature of the Platform and analyze this data for trends and statistics.
We do not directly collect your payment information and we do not store your payment information. We use third-party, PCI-compliant,
payment processors, which collect payment information on our behalf in order to complete transactions. While our administrators are able to
view and track actual transactions via customer portals, we do not have access to, or process, your credit card information.
Interactive and Public Spaces
The Platform may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features
("Interactive and Public Spaces"). If you choose to participate in any of these Interactive and Public Spaces, please be aware that any
information that you post may be read, collected, and used by others who access it. If you wish to remove your personal information from any
of our Interactive and Public Spaces, please contact us.
How Do We Use Personal Information That We Collect
We use your personal information for a number of different reasons, as further explained below.
In addition, for users located in the EEA and the UK, we must have a valid legal basis in order to process your personal data. The main legal bases under the European Union's General Data Protection Regulation (GDPR) that justify our collection and use of your personal information are:
Performance of a contract — When your personal information is necessary to enter into or perform our contract with you.
Consent — When you have consented to our use of your personal information via a consent form (online or offline).
Legitimate interests — When we use your personal information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal obligation — When we must use your personal information to comply with our legal obligations.
Legal claims — When your personal information is necessary for us to defend, prosecute or make a claim.
Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:
- Providing you access to and use of the Platform [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims].
- Processing and completing transactions, and sending you related information, including purchase confirmations and invoices and important notices [depending on the context, performance of a contract or legitimate interests].
- Responding to your queries and requests, or otherwise communicating directly with you [depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims].
- Improving the content and general administration of the Platform, including system maintenance and upgrades, enabling new features and enhancing both Site Visitor and Customer experience [legitimate interests].
- Detecting fraud, illegal activities or security breaches [legitimate interests].
- Providing our Services to our Customers [depending on the context, performance of a contract or legitimate interests].
- Hosting or sponsoring Events [depending on the context, performance of a contract or legitimate interests].
- Ensuring compliance with applicable laws [compliance with a legal obligation].
- Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform [consent where required (e.g. 3rd-party cookies), or legitimate interests].
- Increasing the number of customers who use our Platform through marketing and advertising [consent where required, or legitimate interests].
- Sending commercial communications, in line with your communication preferences, about products and services, features, newsletters, offers, promotions, and events [consent and in some cases, depending on location, with existing customers, legitimate interests].
When We Share Information
We only disclose your personal information as described below.
Third-Party Service Providers
Lunalemon discloses users' information to our third party agents, contractors, or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:>
- Hosting and content delivery network services
- Analytics services
- CRM providers
- Lead generation partners
- Marketing and social media partners
- Customer support services
- Payment processors
- Hosting and content delivery network services
- Functionality and debugging services
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers
As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we
may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or
liquidation in bankruptcy. As part of these transactions, we may transfer your personal information to a successor entity upon a merger,
consolidation or other corporate reorganization in which Lunalemon participates, or to a purchaser or acquirer of all or a portion of
Lunalemon's assets, bankruptcy included.
When we act on behalf of our Customers (as a data processor or service provider), we may provide End Users' personal information to
our Customers in order to comply with their requests, End Users' requests and/or regulator requests, among others.
Occasionally, we will provide our Customers with aggregated information that does not identify End Users directly, in order to provide information about usage, demographics (such as location) or other general information.
If you are an Event Attendee that has registered for an Event with Lunalemon, we will provide your
personal information to the Event sponsors. Such Event sponsors may use your personal information for their own direct marketing purposes
and otherwise in accordance with the terms of the Event sponsors’ own privacy policies.
We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including
(i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding
our users' interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through
the Platform. We do not share personal information about you in this case.
Legal Obligations and Security
In addition, Lunalemon will preserve or disclose your personal information in limited circumstances (other than as set forth in this
subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to
protect the safety or security of our Platform or to prevent spam, abuse, or other malicious activity of actors with respect to the
Platform; or (iv) to protect our rights or property or the rights or property of those who use the Platform.
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
Links to Third Party Sites
Lunalemon ("Third Party Sites"). The policies and procedures we describe here do not apply to Third Party Sites, and links to such Third
Party Sites on the Platform do not imply that Lunalemon endorses or has reviewed the Third Party Sites. We suggest contacting those sites
directly for information on their privacy policies.
What You Should Know about Domain Registration
Note that if you purchase a domain name from Lunalemon, we may be required to collect registrant data for the purposes of domain
registration and listing via the WHOIS protocol. We may also be required to share this with ICANN, the relevant registrars and other such
providers with whom we contract in order to provide our domain name services, as well as when served with a legitimate request from third
parties. Registration data may include the domain name, registrant name and contact information, and information on the domain name server.
Such registration data may be made publicly available by ICANN.
"Do Not Track"
Lunalemon does not respond to Do Not Track ("DNT") browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.
How to Change Your Communication Preferences
To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update
any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications
preferences and the receipt of any commercial communication by clicking the "unsubscribe" link included at the bottom of all emails from
Lunalemon. You may also adjust your preferences through your account settings if you have a Lunalemon account, or send an email to
Access and Accuracy
Lunalemon uses reasonable efforts to keep your personal information accurate. We will provide you with online access to your personal
information so that you may review, update or correct personal information that we hold.
Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections. To access your personal information, please visit the relevant account management sections of our Platform. If you cannot access your personal information on the Platform, please send an email to hello@Lunalemon.dev.
How Long Do We Keep Your Personal information?
General Retention Periods
We use the following criteria to determine our retention periods:
- The amount, nature and sensitivity of your information;
- The reasons for which we collect and process the personal data;
- The length of time we have an ongoing relationship with you and provide you with access to our Platform; and
- applicable legal requirements.
We retain personal information for as long as needed to provide our Services. Note, however, that with respect to our Customers with
active accounts, we may retain certain essential account information, but otherwise regularly delete other information that is less
essential to the provision of our Services in order to minimize our storage of data.
We also will retain personal information that we've collected from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a "litigation hold"). In this case, the information must be retained as long as needed for exercising respective potential legal claims.
When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
For any questions about data retention, please contact hello@Lunalemon.dev.
In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we
choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.
Data Security And Integrity
We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security
measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.
We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.
Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact hello@Lunalemon.dev.
Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of
personal information relating third parties to which we have disclosed certain categories of personal information during the preceding year
for the third parties’ direct marketing purposes. To make such a request, please contact us at hello@Lunalemon.dev.
Notice to Nevada Consumers
We do not sell your personal information within the scope of, and according to the defined meaning of, a "sale" under NRS 603A.
Lunalemon is a business with primarily storage of your information in the South Africa. To facilitate our global operations, we may
process personal information from around the world, including from other countries in which Lunalemon has operations, in order to provide
If you are accessing or using our Platform or otherwise providing personal information to us, you are agreeing and consenting to the processing of your personal information in the South Africa and other jurisdictions in which we operate.
If you are a Customer, you are responsible for informing your End Users of how and where their personal data will be processed at the time of collection.
Lunalemon complies with the EU-U.S. and Swiss-U.S. Privacy Shield framework ("Privacy Shield") as set forth by the U.S. Department of Commerce in connection with the collection, use, and retention of certain personal data transferred from the EEA or the UK and Switzerland to the United States. Although the EU-U.S. Privacy Shield has been ruled invalid for the transfer of personal data, where personal information has already been transferred to the U.S. on the basis of the EU-U.S. Privacy Shield prior to being held invalid, we will continue to protect personal information from the EEA or the UK according to the standards of the Privacy Shield and applicable EU law. To learn more about the Privacy Shield program, or to view our certification, please see https://www.privacyshield.gov.
In addition to relying on our Privacy Shield certification with respect to personal data transferred from the EEA or the UK for the time period in which the EU-US Privacy Shield was valid or for data that we receive from Switzerland, Lunalemon relies on other mechanisms, including the Standard Contractual Clauses and consent, to transfer personal data that we receive from the EEA or the UK to Lunalemon in the United States.
Security. We maintain security measures to protect personal data as described in the section above entitled "Data Security And Integrity".
Access. Inpiduals in the EEA, the UK and Switzerland have certain rights to access, correct, amend, or delete personal data. Please see the section below entitled "Additional Information for Users in the EEA and the UK." for more information on the rights of users in the EEA and the UK (and, to the extent applicable, users in Switzerland). Note that when we process End Users' personal data as a data processor on behalf of our Customers, we will process such requests pursuant to our contract with our customer and our customers' instructions.
Recourse, Enforcement, Liability. With respect to personal data collected from inpiduals in the EEA and the UK (while Privacy Shield was in place) or Switzerland, , Lunalemon commits to resolve complaints about our processing of your personal data as set forth in the principles under Privacy Shield. Inpiduals in the EEA and the UK and Switzerland with inquiries or complaints should first contact Lunalemon by email at hello@Lunalemon.dev. We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. For additional information, please visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Additional Information for Users in the EEA and the UK.
If the GDPR applies to you because you are in the EEA or the UK, you have certain rights in relation to your personal data:
The right of access: your right to request a copy of the personal data we hold about you (also known as a 'data subject access request');
The right of rectification: your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your Account Settings);
The right to erasure (also known as the 'right to be forgotten'): under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you);
The right to restrict processing: your right, under certain circumstances, to ask us to suspend our processing of your personal data;
The right to data portability: your right to ask us for a copy of your personal data in a common format (for example, a .csv file);
The right to object: your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
Rights in relation to automated decision-making and profiling: our obligation to be transparent about any profiling we do, or any automated decision-making.
These rights are subject to certain rules around when you can exercise them.
Customers, Site Visitors and Event Attendees in the EEA or the UK.
If you are located in the EEA or the UK and you are a Customer, Site Visitor or Event Attendee, and wish to exercise any of the
rights set out above, you may contact us at hello@Lunalemon.dev using the term "DSR" as your
email subject line.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.
If we cannot reasonably verify your identity, we will not be able to comply with your request(s). We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Note that this is especially true when you engage a third party to assist you in exercising your rights.
We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law. In addition, we will always balance your rights against those of other data subjects in connection with any requests, and in some cases this may require us to redact our responses or deny a request.
Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at https://lunalemon.dev. We ask that Customers use this option as a first step when rectifying information.
If you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic marketing message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of providing our Services.
Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us directly first.
End Users in the EEA or the UK.
Lunalemon has no direct relationship with End Users. Our Customers are solely responsible for ensuring compliance with all applicable
laws and regulations with respect to their End Users, and this includes handling all data subject requests. We rely on our Customers to
comply with the underlying legal requirements and respond directly to End Users when End Users wish to exercise the rights set forth
above. However, if an End User sends a request to Lunalemon to access, correct, update, or delete his/her information, or no longer wishes
to be contacted by a Customer that uses our Services, we will direct that End User to contact the Customer's website(s) with which he/she
interacted directly, and cooperate with our Customers as required by applicable law in order to ensure that our Customers satisfy their
End Users' requests.
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Lunalemon has appointed European Data Protection Office
(EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:
- Using EDPO's online request form at https://edpo.com/gdpr-data-request/; or
- Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
Pursuant to the UK GDPR, Lunalemon has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK
regarding matters pertaining to the UK GDPR:
- Using EDPO's UK online request form at https://edpo.com/gdpr-data-request/; or
- Writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
Last update: August 02, 2022