PRIVACY POLICY

Effective Date: February 2, 2024

This privacy policy explains how we, Loóna Inc. of 8 The Green, Ste B, Dover, DE, 19901, USA  or any of our affiliated entities  (“Loóna”, “we”, “us”, “our”) process your personal information (“you”, “your”) when you use our website, game or other services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY 

By using the Loóna, spatial computing application for Apple Vision Pro (the “Game”) or the website located at https://loona.vision/ (the “Website”) (Game and Website individually referred to as a “Loóna Service” or collectively as the “Loóna Services”) or otherwise indicating your acceptance (e.g. by clicking tick-box or bottom “agree” or “continue”), you agree to the following terms of our Privacy Policy, which will bind you at all times and in whatever manner you use the Loóna Services.

Please note:

  1. Individuals in the European Economic Area (EEA) and the United Kingdom (UK) should also read our section about “Your EEA & UK Data Privacy Rights”.

  2. Individuals in California, Virginia, Colorado, Utah, or Connecticut should also read our section about “Your California, Virginia, Colorado, Utah, and Connecticut Privacy Rights”.

  3. Individuals in Nevada should also read our section about “Your Nevada Data Privacy Rights”

  1. WHERE THIS PRIVACY POLICY APPLY TO

This Privacy Policy applies to all Loóna Services. 

  1. WHAT TYPES OF INFORMATION DO WE COLLECT?

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.

  • Information You Provide Directly: We collect personal data only when shared voluntarily by you.

  • Information Collected Automatically: Automatically collected data helps us enhance Loóna's service. This includes transaction details such as purchase date, currency, amount, payment type, and the last four digits of your card number. We also use third-party analytics tools like Amplitude to help us measure traffic and usage trends, performance and various metrics related to Loóna and your usage of the Loóna Services.

  • Information from Third Parties: Apart from direct inputs, we receive information from:

    • Social Media: You may share interactions, posts, and profiles via social media platforms.

    • Suppliers: Information may come from partners, such as analytical or advertising providers.

  1. WHAT PURPOSES DO WE COLLECT YOUR INFORMATION FOR?

Generally, we will use your personal information to (i) provide Loóna Services and enable you to use our service features, (ii) respond to your queries, (iii) improve and develop Loóna Services; (iv) develop and promote our organisation and services; (v) ensure the security and technical availability of Loóna Services; and (vi) comply with the law.

  1. NO PROCESSING OF PAYMENT DETAILS

We will not receive or store any of your payment details, this is fully handled by the relevant payment service provider. If/when you make any purchases, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details or personal data related to the payment. We only keep the data concerning transaction dates, currencies, value, the last four digits of your card number and the subject of the transaction.

  1. SHARING YOUR INFORMATION WITH THIRD PARTIES

We will generally not share your information except with (i) our third party service providers and advisors who may process personal information on our behalf for the purpose of operation of the Loóna Services (e.g., cloud providers), (ii) our advertising, marketing and analytics partners, as explained below, (iii) our group companies for the purposes set out above, (iv) persons or authorities where we are compelled by law, (v) to the relevant entity in case of a merger, acquisition or collaboration, and (vi) other third parties where you have provided your consent. 

We also use third-party analytics tools like Amplitude to help us measure traffic and usage trends for Loóna and for other purposes. Such analytics tools collect information via third-party SDKs incorporated into Loóna, which includes information about features of Loóna you visit or use, your actions in Loóna, and information about your subscription. Such information may be used to provide content, advertising, or functionality or to measure and analyze ad performance on Loóna or other websites or platforms. Third parties may also use such information for their own purposes. 

For users in the European Economic Area, United Kingdom and United States. You can opt-out from processing of Personal Data via cookies, SDKs and other tracking technologies by clicking sending a request to privacy@loona.app.

  1. LINKS TO OTHER SITES

For the convenience of our visitors and clients, Loóna Services may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.

  1. HOW LONG IS YOUR INFORMATION KEPT?

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. 

  1. HOW DO WE SECURE YOUR INFORMATION?

We maintain appropriate organizational and technological safeguards to help protect against unauthorized use, access to or accidental loss, alteration or destruction of the personal information we hold. We also seek to ensure our third-party service providers do the same.

We will endeavour to use the least amount of personal information as is required for each purpose. 

Our staff will access your personal information on a “need to know” basis.

Unfortunately, the transmission of personal data through the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to or stored on our IT system, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.

  1. WHERE IS YOUR INFORMATION PROCESSED?

We may transfer your personal information to our group companies, suppliers and other third parties in countries different to your country of residence.

In addition, data may be transferred to our subsidiaries or processors in third countries or subcontractors of our processors in third countries.

We and certain of our service providers are incorporated in the United States. Accordingly, your Personal Data may be transferred to and stored in the United States.

Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.

For further information please contact privacy@loona.app

  1. OUR POLICY REGARDING CHILDREN

General age limitation. Loóna is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to use Loóna. If you are under 13, do not: (i) Use or provide any information in Loóna or through any of its features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. If you are a parent or guardian and believe we have collected information from your child who is under the age of 13, please contact us at privacy@loona.app.

Age limitation for EEA/UK individuals. Age limitation for EEA/UK individuals. You must be at least 16 years old in order to use Loóna Services. We do not allow use of Loóna by EEA individuals younger than 16 years old. If you are aware of anyone younger than 16 using Loóna, please contact us by e-mail: privacy@loona.app, and we will take the required steps to delete the information provided by such persons.

  1. CONTACT US

Please email us if you have any queries or concerns about how we use your personal information. We will try to resolve your query without undue delay.


E-mail: privacy@loona.app  

  1. UPDATES

This Privacy Policy may change from time to time, and we encourage you to review it periodically. The date this Privacy Policy was last revised is indicated at the top of the page. We may modify or update this Privacy Policy from time to time. Some changes do not require your consent. However, if we determine that the changes may pose risk to your rights and freedoms, we will ask for your consent to those changes separately from this Privacy Policy.

  1. YOUR EEA & UK DATA PRIVACY RIGHTS

This section provides further disclosures and describes the rights in relation to your personal data that you may have under GDPR if you are an individual in the EEA or UK GDPR if you are an individual in the UK.

  1. Personal data
    “Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.

  2. How do we process your information and why?
    We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above. We will update you about any new purposes of processing your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so by law.

  3. Data subject rights
    Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:

  1. Right to information about matters set out in this policy. You may also contact us for further details about our retention policy and international data transfers.

  2. Right to make an access request to receive copies of personal data, as well as to share your personal data with other parties.

  3. Right to rectification of any inaccurate or incomplete personal data.

  4. Right to withdraw consent previously provided, without affecting the lawfulness of our processing based on consent before its withdrawal.

  5. Right to object to our processing of personal data for direct marketing purposes, or that is based on our legitimate interests, and any automated decision-making and profiling.

  6. Right to erasure of personal data, in certain circumstances. Please note that the erasure of some of your personal data may affect your ability to use Loona Services.

  7. Restriction on the processing of personal data in certain circumstances.

  8. Right to data portability from one service provider to another, where applicable. In this case, we will provide you with a copy of your personal data in a machine-readable format in accordance with industry standards so that you can pass this information to another data controller.

  9. Right to lodge a complaint with your country’s supervisory authority. Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period, we will explain why and extend the period by up to two months where necessary, taking into account the complexity and number of requests. You can exercise these rights directly with us by submitting a request at privacy@loona.app. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

14. YOUR CALIFORNIA, VIRGINIA, COLORADO, UTAH, AND CONNECTICUT DATA PRIVACY RIGHTS

​​Residents of California, Virginia, Colorado, Utah, and Connecticut may have statutory rights under state comprehensive privacy law including the rights specified below. You can exercise these rights by contacting us (for contact information, please, see Contact Us Section).

A “resident” is a natural person who resides in a specific state, even if the person is temporarily outside of the state.

Loona uses and discloses personal information for business purposes only as set forth in its Privacy Policy. All collection, use and disclosure of personal information is described in this Loóna’s Privacy Policy.

  1. Right to request the categories of Personal Information collected about you. Loóna will provide, where relevant and required by law, the types of data we collect.

  2. Right to request the categories of sources from which your Personal Information is collected. Loóna will provide, where relevant and required by law, the types of tools and organizations we use to collect data.

  3. Right to request the business or commercial purpose for collecting your Personal Information. Loóna will provide, where relevant and required by law, the purposes to collect data.

  4. Right to request the categories of third parties to whom Personal Information is disclosed, and the categories of Personal Information disclosed. Loóna will provide, where relevant and required by law, information regarding the other organizations that may receive your Personal Information.

  5. Right to request the specific pieces of Personal Information collected about you. Loóna will provide, where relevant and required by law, your Personal Information.

  6. Right to request that Personal Information collected about you be deleted. We may keep Personal Information for legal reasons but will accommodate deletion requests when required. Please be aware that erasing some Personal Information may affect your ability to use Loóna.

  7. Request that your inaccurate Personal Information be corrected. If you believe your Personal Information is not correct you may provide Personal Information to replace the erroneous data.

  8. Request that Loóna does not sell or share your Personal Information. However, please know we do not currently sell or share data triggering these opt-out requirements.

Please keep in mind that in case of a vague request to exercise any of the aforementioned rights we may engage with you in a dialogue to ask for more details if so needed to complete your request. In case this is impossible, we reserve the right to refuse granting your request.

If you have a question about Loóna`s privacy practices or to the extent you wish to exercise your privacy rights, you may contact us at: privacy@loona.app. In the request, please specify which right you are seeking to exercise and the scope of the request. Loóna reserves the right to request additional information from you to help us verify your identity and process your request.

Please note that we will process your request within 45 days after receiving it. We may extend to a total of 90 days where necessary, taking into account the complexity and number of the requests. If we extend the response period, we will let you know within the first 45 days. We will not discriminate against you for exercising your rights under the law.

15. YOUR NEVADA DATA PRIVACY RIGHTS

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@loona.app. However, please know we do not currently sell data triggering that statute’s opt-out requirements.