Privacy Policy

Effective date: 5/9/2024

At Luna, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. This Privacy Policy is meant to help individual patients (“Users”) and clinicians, healthcare specialists, professionals, providers, organizations or agents or affiliates (“Healthcare Professionals”) that access our platform and use our Services to understand how we treat their Personal Data. It also addresses how we treat the Personal Data of visitors to getluna.com (“Website Visitors,” and, collectively with Users and Healthcare Professionals, “you,” or “your”).

By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. Remember that your use of Luna's Services is at all times subject to Luna's Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

What does this Privacy Policy cover?

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Further, this Privacy Policy does not describe how we collect or use individuals’ “Protected Health Information” or “PHI” (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)).

IMPORTANT: We handle your PHI with the utmost care and only use or share it in ways that are permitted under HIPAA. You can read more about how we process your PHI and how your data is governed in Luna's Notice of Privacy Practices.

Will Luna ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on our website(s) and application(s), by sending you an email, and/or by some other means. Note that if you’ve opted not to receive emails from us, those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What information does Luna collect?

Categories of Personal Data we collect from Users/Website Visitors

This table details the categories of Personal Data that we collect and have collected from Users over the past 12 months:

IMPORTANT: This table below does not include our handling of your PHI, which is governed by Luna's Notice of Privacy Practices, and is specifically for patients of Luna.

Categories of Personal Data we collect from Healthcare Professionals:

This table details the categories of Personal Data that we collect and have collected from Healthcare Professionals over the past 12 months:

Categories of sources of Personal Data

We collect Personal Data about you from the following categories of sources:

  • When you provide such information directly to us.
  • When you create an account.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
  • Through Cookies (defined in the “Tracking Tools and Opt-Out” below).
  • If you download our mobile application(s) or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • Public Records, from the government or other sources, in order to generate a directory of Healthcare Professionals.
  • Third Parties such as vendors, as we may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

Our commercial or business purposes for collecting or disclosing Personal Data

  • Providing, customizing, and improving the Services
  • Marketing the Services
  • Creating and managing your account or other user profiles.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).
  • Corresponding with you
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Luna or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Meeting legal requirements and enforcing legal terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Luna, or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How does Luna disclose your Personal Data?

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

IMPORTANT: This list below does not include our handling of your PHI, which is governed by Luna's Notice of Privacy Practices, and is specifically for patients of Luna.

Service Providers. These parties help us provide the Services or perform business functions on our behalf:

  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services:

  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Services.

Advertising Partners. These parties help us market our services and deliver relevant advertisements to you, including:

  • Advertisers, ad agencies, and our and their advertising technology companies and partners, to show you ads that we think may interest you and measure the effectiveness of those ads.

Parties You Authorize, Access, or Authenticate, including third parties you access through the services.

Legal obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking tools and opt-out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout/.

Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking “Cookie Settings” in the footer of our website. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit www.allaboutcookies.org.

We may also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties.

Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) to you through the Services. These technologies allow advertising technology providers to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

Data security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

  • We retain your profile information/credentials for as long as you have an account with us.
  • We retain your payment data for as long as we need to process your purchase(s).
  • We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of children

We do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, or are a parent or guardian of a User that is under 13 years of age, please contact us at privacy@getluna.com.

California resident rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If you are a California resident, note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@getluna.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

  • The categories of Personal Data that we have collected about you.
  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data (if authorized).
  • The categories of third parties with whom we have shared your Personal Data.
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services, to meet specific healthcare related data retention rules, or to complete purchase transaction(s), or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data sales and sharing

IMPORTANT: This section does not apply to your PHI which, as noted above, we handle with the utmost care and only use or share in ways that are permitted under HIPAA as outline in Luna's Notice of Privacy Practices.

In this section, we use the terms ‘share’ and ‘sell’ as they are defined in the CCPA. Per the CCPA classifications, we sell and share your Personal Data, subject to your right to opt-out.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. Those Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on websites you visit. Under the CCPA, sharing your data through third-party Cookies for online advertising may be considered a “share” or a “sale” of information.

Over the past 12 months we have sold or shared the foregoing categories of Personal Data.

  • Device/IP Data
  • Web Analytics

Over the past 12 months we have shared your Personal Data with the following categories of third parties:

  • Analytics Partners
  • Advertising Partners

We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:

  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Marketing and selling the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:

  • Click “Cookie Settings” in the footer of our website to activate the following: Do Not Sell or Share My Personal Information
  • Email us at privacy@getluna.com
  • Implement Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. To our knowledge, we do not and have not sold or shared the Personal Data of minors under 16 years of age.

We will not discriminate against you for exercising your rights under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other privacy laws

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@getluna.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites, applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Colorado resident rights

If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@getluna.com.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

Deletion

You have the right to delete your Personal Data, however we may need to retain your Personal Data to provide you with the Services, to meet specific healthcare related data retention rules, or to complete purchase transaction(s).

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.

Personal Data sales opt-out and opt-in

IMPORTANT: This section does not apply to your PHI which, as noted above, we handle with the utmost care and only use or share in ways that are permitted under HIPAA as outline in Luna's Notice of Privacy Practices.

In this section, we use the term ‘sell’ as it is defined in the CPA. Per the CPA classifications, we sell your Personal Data, subject to your right to opt-out of these sales.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. Those Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on websites you visit. Under the CPA, sharing your data through third-party Cookies for online advertising may be considered a “sale” of information.

Over the past 12 months we have sold or shared the foregoing categories of Personal Data.

  • Device/IP Data
  • Web Analytics

Over the past 12 months we have shared your Personal Data with the following categories of third parties:

  • Analytics Partners
  • Advertising Partners

We sold the foregoing categories of Personal Data for the following business or commercial purposes:

  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Marketing the Services.
  • Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:

  • Click “Cookie Settings” in the footer of our website to activate the following: Do Not Sell or Share My Personal Information
  • Email us at privacy@getluna.com
  • Implement Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal.

Per the section above “Personal Data of Children”, to our knowledge, we do not sell the Personal Data of minors under 13 years of age.

Appealing a denial

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the CPA. We will respond to your appeal within 45 days of receiving your request. If we deny your appeal, you have the right to contact the Colorado Attorney General.

You may appeal a decision by us by emailing us at privacy@getluna.com or calling us at: 833-444-LUNA.

Nevada resident rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at privacy@getluna.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. We do not sell your Personal Data, per the definition of “sale” as defined in Nevada Revised Statutes Chapter 603A.

Washington state resident rights

The information contained in this document includes how we comply with the Washington State My Health My Data Act (the “MHMDA”).

Subject to certain legal limitations and exceptions, you have the following rights with respect to any consumer health data we may collect about you:

  • The right to confirm whether we are collecting, sharing, or selling your consumer health data and to access such data, including a list of all third parties and affiliates with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties.
  • The right to withdraw consent from our collection and sharing of your consumer health data.
  • The right to have your consumer health data deleted.

If you are a resident of the state of Washington, and would like to exercise your rights pursuant to the MHMDA, please contact us at privacy@getluna.com with the subject line “Washington MHMDA Request” and provide us with your name and the email address associated with your account. If your request to exercise a right under the MHMDA is denied, you may appeal that decision. If your appeal is unsuccessful, you may raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Exercising your rights

To exercise the rights described in this Privacy Policy, you or your Authorized Agent (as applicable, and defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by emailing us at privacy@getluna.com or calling us at 833-444-LUNA.

For applicable states, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add and/or update information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information will remain in our records after you suspend (or deactivate, or mark for deletion) use of your account as required by law. We may use any aggregated data derived from or incorporating your Personal Information after you add and/or update it, but not in a manner that would identify you personally.

Questions?

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us by emailing us at privacy@getluna.com or calling us at 833-444-LUNA.