Effective Date: March 28, 2019
The Services provide software tools for users to access and manage various features and functions related to digital assets including tokens, cryptocurrencies, virtual currencies or any other digital assets you own (collectively, “Digital Assets”), including interfacing with certain third party sources for certain information relating to the Digital Assets.
- What information we collect, how we collect it, and why
- How we use that information and with whom we share it
- How you can access and update that information
- The choices you can make about how we collect, use, and share your information
- How we protect the information we store about you
Information We Collect and How We Collect It
We collect certain information in the following ways:
Information You Give Us Directly
We collect some information from you directly. This information may be provided via an online form or when you talk to a member of our team. For example, you may provide:
- Your name, age or birthday, email address, username, address, password, telephone number;
- Your current employer and place of work;
- Account preferences;
- Security questions and answers;
- Information linking your account to third-party service providers, including information necessary to track the value of your Digital Assets if you sign up for a Digital Wallet (as described in our Terms of Service);
- Information linking your account to your personal accounts such as Google and Github
- Demographic details and information in response to questions or surveys about our products or information to enter a contest, promotion or sweepstakes;
- The contact information you give in connection with any customer service query, and any communications, information, data or history in relation to any query. We may monitor or record interactions with our customer service team for training purposes and to ensure a high level of service;
- Information, insights or responses to questions provided if you respond to any of our surveys. You may choose whether to participate in any survey; and
- Your mobile telephone number, if you choose to sign up and receive SMS messages or notifications.
- Certain information that you provide us directly will become public information if you elect to provide it to us, for example we may use customer reviews for marketing purposes and we may aggregate demographic information about individuals who use the Services and disclose this aggregate information.
Information We Collect Automatically When You Use the App or access or use the Services.
We collect other information about the Services you use and how you use them, including when and how often you use the Services, what features you used, how you view and interact with our other content and the devices you use to access the Services. This information is collected automatically using Cookies and Similar Technology as described below. This information includes;
- IP address (including country), which will provide general information about your geographic location;
- The type of computer or mobile device you are using (including your device’s unique identifier);
- Device-specific settings and other hardware settings, including operating system and other software settings, browser type, browser language, time zones, and certain cookies or other technologies that may associate your device information with your Lunie account;
- Browser information including your browser type and the language you prefer;
- Referring and exit pages, including landing pages and pages viewed;
- Information on your wireless and mobile network connection, like your service provider and signal strength;
- Information about your use of the Services, including the date and time you log in, search queries, the date and time of requests and any referral URLs;
- Device event information, including crash reports, request and referral URL’s and system activity details (e.g., whether the error occurred on the App or you lost internet access); and
- We collect other information with your consent.
We also may collect and store information locally on your device using mechanisms like cookies, browser web storage and application data caches.
Information we get from Third-Parties.
Third parties that assist us with our business operations also may collect information through the Services.
We engage service providers to collect information to help us secure the Services, detect and prevent fraud, provide a better user experience and ensure the Services are working as expected. Some of this information is collected through Cookies and Similar Technologies as described below.
We do not currently have advertising in the Services, we may have advertising in the future in which case we may receive information about you from our advertising partners, such as when advertising campaigns are published through the Services.
Information we get from Cookies and Similar Technologies.
We and service providers acting on our behalf store log files and use tracking technologies such as:
- Cookies are bits of electronic information that are sent to or transferred from your web browser or hard drive to customize a person’s use of a product or online site, keep records of a user’s access to an online site or product, or store information needed by the user on a regular basis. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of a cookie (or when it expires) and a randomly generated unique number or similar identifier. A cookie may also contain information about your computer, such as user settings, browser history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org
- We may link information from cookies with other personal information we hold about you.
The Services use the following Cookies:
- Cookies that are strictly necessary for the operation of the Services.
- Analytical/Performance cookies, which allow us to recognize and count the number of visitors, learn how visitors navigate the Service and to help us improve the way the Services function. For example, When you sign in to the App, we store your user id and a combination of your IP address and time of login as a cookie on your hard drive. This cookie allows you to move from page to page without having to sign in again on each page.
- Functionality Cookies, which recognize you when you return to the Services.
- Cookies tied to Google Analytics, which is a Google service that collects information about use of the Services. Google Analytics does not identify individual services.
- Cookies tied to sentry.io, Appzi and similar services that provide information and analytics on the the App’s performance and user experience.
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You are not required to accept cookies or mobile device identifiers, but if you elect to block or reject them you may not have access to all of the Services.
Our Policy on Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that response to a particular DNT signal, the browser can block that website from collecting certain personal information about the browser’s use. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many websites, including our website and App do not respond to DNT signals. To learn more about DNT signals go visit allaboutdnt.com. You may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.
Third Party Advertising
We do not currently have third-party advertising on the App; however, we may have advertising in the future.
Third Party Information Sources
We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers. We use information from these companies primarily to deliver optimized content to you and to understand your approximate geolocation via your IP address to customize certain services to your location.
Storage of Information on Your Device
We store certain information that is required for the use of the Services on your hard drive or device when you download the App. This information includes:
- Information regarding your Digital Wallet, your internet connection and our software, which is uploaded to the server when you access your account in connection with your use of the Services
- Meta Data files, which optimize the speed and performance of the Services
- Plug-ins necessary for the App to operate on the web browser of your choice, such as a Chrome plug-in
- When the App is available on mobile devices, native apps will be stored
How We Process The Information We Collect
We process your personal and non-personal information, both individually and aggregated, in the following ways:
To administer your account and provide the Services to you:
- Set up and maintain your account and Digital Wallet
- Communicate with you
- To respond to your questions and to try to resolve any problems with the Services
- To complete transactions you initiate
- Identify, fix and troubleshoot bugs and service errors;
- Provide software updates;
- Enable third-party service providers to deliver information and updates
To improve the Services and develop new ones:
- Administer surveys
- Analyze and understand our visitors and users, improve our Services (including our user interface) and optimize content and/or feature selection, recommendations and delivery
- Develop new features and services
- Measure the health of the Services
To prevent, detect and fight fraud or other illegal or unauthorized activities:
- Address ongoing or alleged misbehavior
- Research and analyze data to better understand and design countermeasures against these activities
- Retain data related to fraudulent activities to prevent recurrences
To enable legal compliance:
- Comply with legal requirements
- Enforce or exercise our rights
To personalize our communication with you, including to:
- Respond to your requests and inquiries
- Communicate with you regarding the Services
- Make recommendations to you
To process your information, as described above, we rely on the following:
- Provide the Services to you: We process your information to perform the contract (Terms of Service) that you have with us
- Legitimate interests: We use your information for legitimate business interests when permitted by law. For example, we analyze users’ behavior on the Services to improve them and for administrative, fraud detection and legal purposes. In the future, we may use your information for direct marketing purposes.
How We Share Your Information
We may share information collected through the Services as follows:
Third Party Service Providers
We share information with our third-party service providers that help us operate the Services, such as by providing customer service, IT services, product support or testing, and strengthening security measures. In the course of providing such services these service providers may have access to your personal information. We do not authorize service providers to use your personal information except in connection with providing services.
Protection of Lunie and Others
We and our third party service providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to:
- Satisfy any law or regulation
- Respond to a lawful request from a public authority, including law enforcement or national security authorities, or legal process
- Detect, prevent or otherwise address illegal or suspected illegal activities (including to report such activity), security or technical issues
- Protect against harm to the health and/or safety of you, another person or the public generally
- Protect the rights or property of Lunie, its users or the public as required or permitted by law
Corporate Transactions / Business Transfers
In connection with any business transition (including a proposed transaction), like a merger or sale, acquisition by another company, reorganization, restructuring or transfer of assets, bankruptcy, dissolution or other change of ownership or control we may disclose or transfer all of your information, including personal information.
Other lawful disclosure
We may share your information if (i) disclosure could mitigate Lunie’s liability in an actual or threatened lawsuit, (ii) as necessary to protect legal rights of our users, customers, business partners or other interested parties, (iii) to pursue available remedies or limit the damages, (iv) to enforce our agreements (including the Terms of Service) and (v) to respond to an emergency.
With your consent
Aggregated and Anonymous Information
We may process aggregated personal information about you (information about you and other users that is aggregated with information about other users that is not intended to specifically identify you) and anonymous data (aggregated or not) about you in order to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. We may share this information with third parties without limitation on such third parties’ use of the information. We may disclose or publish this data (aggregated or not) for industry analysis demographic profiling, marketing, analytics, advertising, and other business purposes.
Cross Border Data Transfers
Sharing information sometimes involves cross-border transfers. Your personal information may therefore be transferred to, stored and processed in the United States and other countries where we and our partners and service providers operate. For example, if the Services are available to users in the European Economic Area (“EEA”), these users’ personal information is transferred to countries outside of the EEA to the US or other jurisdictions. Please be aware that these countries may have data protection laws that are more or less protective than the laws of the country where you live. We use safeguards approved by the European Commission to legitimize data transfers from the EEA to other countries.
How to Access Manage and Update Your Information
When we begin promotional communication, we will give you the option to receive promotional email communications from us. Users will be able to opt-out of these communications. If you do not want to receive these non-transactional communications you will be able to opt-out of the communications by selecting “unsubscribe” on any email. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or email preference change will be processed promptly, and in no event longer than ten business days.
If we begin sending promotional SMS messages, you will be able to opt-out of receiving SMS messages (for example text messages) by texting back STOP to the number we send the text from for that particular SMS message program. In some cases, we will include a preferences management page. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
When you install our App on a mobile device, you will be able to choose to receive push notifications, which are messages an app sends you on your mobile device when the app is not on. You will be able to turn off notifications by visiting your mobile device’s “settings” page.
Opting out of Geolocation
If you would like to stop allowing us to access your geolocation data, you can stop making geolocation available to us on your mobile device by changing the settings on your mobile device. We may still be able to get some location information using your IP address and other information provided to us by third- parties.
Opting out of Cookie Tracking
Corrections, Updates and Removal of Personal Information
If you are concerned about the accuracy or legality of personal information we maintain or wish to review, access, supper, amend or correct it, would like your personal information removed from our records or otherwise deactivated, or would like to receive an electronic copy of your personal information of transmitting it to another company (if this right to data portability is provided to you by law) you can:
- Change your settings on your device to either consent or withdraw consent to the collection of certain information. As discussed above, if you do this you may lose some or all functionality related to the Services
- Delete your account
- Contact us at email@example.com with your request.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed form our database, or other limitations you would like to put on the use of your personal information. For your protection, we will only fulfill requests for personal information associated with the email address associated with your account. We may need to verify your identity before fulfilling your request.
We will consider all such requests in accordance with applicable law. We may decline requests that are unreasonably repetitive, require disproportionate technical effort or expense, or jeopardize the privacy of others.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion, our databases also may have residual data which we do not remove. We will not allow you to review certain data for legal, security or other reasons.
If you are an EEA resident, you have the right to lodge a complaint with the data protection authority firstname.lastname@example.org about how we process your personal information,
If you are a California resident, California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at email@example.com.
The Services are not directed or intended for use by minors and we will not knowingly collect personal information from any person under the age of 13. Children under the age of 13 should not use the App or access or use the Services at any time. Consistent with the requirements of the Children’s Online Privacy Protection Act, if we learn that we have inadvertently gathered personal information from a child under 13 without his or her parent’s or legal guardian’s verified consent, we will take reasonable measures to promptly remove that information from our records and will use that information only to respond to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the App or access or use the Services.
Parents or legal guardians who are concerned about the transfer of personal information from their children may contact us at firstname.lastname@example.org.
Privacy Policies of Linked Third-Party Services and Advertisers
Storage and Security of Personal Information
We take precautions intended to protect the information we collect and store, no website or internet transmission is completely secure. This means we cannot guarantee the security of your information transmitted to or through the Services and do not assume any responsibility for the unauthorized access to your information under our control. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.
You are responsible for maintaining the security of your account and your Digital Wallet, including the device on which your store your Digital Wallet. Access to the Services through your account is treated as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.
We keep your personal information in identifiable form only (i) as long as we need it for lawful purpose for which we collected it, or if longer, (ii) to comply with law, or (iii) to resolve disputes and to enforce agreements with you.