At Luna, we strongly believe in fundamental privacy rights and the consistent application of those rights. That is why we consider any data related to an identified or identifiable individual, or data that Luna has linked or may link to that individual, as "personal data," regardless of where that person lives. This means that both data that directly identifies you—such as your name—and data that does not directly identify you but could reasonably be used to identify you are considered personal data. For the purposes of this Privacy Policy, aggregated data is considered non-personal data.

This Privacy Policy addresses how Luna or certain affiliated companies of Luna (collectively referred to as “Luna”) handles personal data.

At Luna, we respect your ability to understand, access, correct, transfer, restrict the processing of, and delete your personal data. Luna does not sell your data.

However, there may be instances where we cannot accept your request—for example, if you request that we delete transaction data while Luna is legally required to retain records of that transaction to comply with the law. We may also refuse to accept a request if taking action would undermine our ability to use data legitimately for fraud prevention and security purposes, such as when you request the deletion of an account that is under investigation due to security concerns. Other reasons that may lead to a privacy request being denied include: the request affects the privacy rights of others, the request is frivolous, burdensome, or extremely impractical.

At Luna, we believe you can have great products while ensuring your privacy. This means we strive to only collect the personal data that we need.

We may collect various types of information, including:

• Account information. Details related to your account, including email address, registered device, account status, and age.
• Device information. Data that can identify your device.
• Contact information. Data such as your name, email address, phone number, or other contact information.
• Usage data. Data about your usage and activity on our products and services, such as launching apps within our services, including search history; interactions with products; data on crashes, performance, and other diagnostic data; as well as other usage data.
• Location information. Relative location data for security and fraud prevention purposes.
• Other information you provide to us. Details such as the content of communications between you and Luna, including interactions with customer support and contact through social media channels.

You are not required to provide the personal data we request. However, if you choose not to provide this information, in many cases, we may not be able to provide you with our products or services or respond to your requests.

Information Related to Children

By our definition, children are individuals under the age of 13 or the equivalent age under the laws of your jurisdiction.

Luna is not intended for children under 13. Luna's services are not intended to be used by children without the involvement and consent of a parent or guardian.

Luna may receive personal data about you from other individuals, from businesses or third parties acting on your behalf, from partners working with us to provide our products and services, as well as to assist us in securing and preventing fraud, and from other legitimate sources.

• Individuals. Luna may collect data about you from other individuals—for example, if that individual has sent you a product or gift card, invited you to participate in Luna's services or forums, or shared content with you.
• At Your Request. You may request other individuals or third parties to share data with Luna.
• Luna's Partners. We may also validate the information you provide with third parties for security and fraud prevention purposes.

For research and development purposes, we may use data sets. When obtaining these data sets, we will comply with applicable laws, including laws in the jurisdiction where the data set is stored. When using these data sets for research and development, we will not attempt to re-identify individuals who may appear in them.

Luna uses personal data to provide services, process your transactions, communicate with you, ensure security and prevent fraud, as well as to comply with the law. We may also use personal data for other purposes with your consent.

Luna only uses your personal data when we have a valid legal basis to do so. Depending on the circumstances, Luna may rely on your consent or the necessity of processing information to fulfill our contract with you, protect your vital interests or those of others, or comply with the law. We may also process your personal data when we believe it is in our legitimate interest or that of others, taking into account your interests, rights, and expectations.

• Providing Services. Luna collects the necessary personal data to provide services, which may include personal data collected to improve our products and services, for internal purposes such as testing or data analysis, or to troubleshoot issues. For example, if you want to access a comic book, we will collect data about the comic books you publish to provide you with the requested content and for copyright-related purposes.
• Communicating with You. To respond to correspondence, contact you regarding your transactions or accounts, market our products and services, provide other relevant information, or request information or feedback. Occasionally, we may use your personal data to send important notifications, such as information about purchases as well as changes to our terms, conditions, and policies. Since this is important information that affects your interaction with Luna, you cannot opt-out of receiving these important notifications.
• Security and Fraud Prevention. To protect individuals, employees, and Luna, as well as to prevent losses and detect fraud, including protecting individuals, employees, and Luna for the benefit of all users, and to pre-screen or scan uploaded content to detect potential illegal content, including child sexual exploitation materials.
• Personalization of Personal Data. If you choose to personalize your services or forms of communication when such options are available, Luna will use the information collected to provide you with those personalized services or forms of communication.
• Compliance with the Law. To comply with applicable laws—for example, to meet tax or reporting obligations, or to comply with legal requests from authorities.

Luna does not use algorithms or profiling to make any decisions that may significantly affect you without giving you the opportunity to review them personally.

Luna retains personal data only for as long as necessary to fulfill the purposes for which the data was collected, as described in this Privacy Policy or in the privacy notices for each service, or as required by law. We will retain your personal data for the necessary period to fulfill the purposes stated in this Privacy Policy and the privacy summaries of each service. When assessing the retention period, we first carefully check whether it is necessary to retain the collected personal data, and if retention is required, we will strive to retain personal data for the shortest duration possible according to the law.

Luna may share personal data with Luna’s affiliates, service providers acting on our behalf, our partners, or other parties at your request. Furthermore, Luna does not share personal data with third parties for their own marketing purposes.

• Service Providers. Luna may engage third parties as service providers to perform certain tasks on our behalf, such as processing or storing data, including personal data, related to your use of our services and providing products to customers. Luna's service providers are required to process personal data in accordance with this Privacy Policy and our instructions. They are not permitted to use the personal data we share for their own purposes and must delete or return personal data when they have fulfilled our request.
• Partners. Occasionally, Luna may collaborate with third parties to provide services or other products. Luna requires partners to protect your personal data.
• Other Parties. Luna may share personal data with other parties at your request or with your consent. We may also disclose information about you if we determine that the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance. We may also disclose information about you when we have a legal basis to do so, if we determine that the disclosure is reasonably necessary to enforce our terms and conditions, or to protect our operations or users, or in the event of a reorganization, merger, or sale.

At Luna, we believe that privacy is only guaranteed when there is strong security. We use administrative, technical, and physical measures to protect your personal data, taking into account the nature of the personal data and the processing involved, as well as potential threats. We continuously strive to improve these protections to help ensure the safety of your personal data.

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the "Last Updated" date at the top of this policy and posting the new Privacy Policy, as well as providing any other notifications as required by law. Your continued access to or use of Luna's services after the date the policy is updated constitutes your acceptance of the updated policy. If you do not agree with the updated policy, you must stop accessing or using Luna's services.