Privacy Policy

Luner is incorporated under the laws of the Cayman Islands, company No. 12345, COMPANY ADDRESS and operating the website: “”, and ANY OTHER RELEVANT DETAIL.

Luner, treats privacy and data security very seriously, as so we have implemented appropriate security measures to prevent accidental loss and unauthorized use or access of your personal data. This Privacy and Cookie Policy (“Privacy Policy”) govern your access and use of any service, websites, software or applications (collectively, the "Service") and/or any associated content or material (collectively, the “Content”).

Data Collection

In order to allow us to provide our Service and Content, Luner collects information on all users (both registered and not), including individuals, or entities represented by an authorized individual, who accesses or uses any part of the Service and/or Content.

By accessing, visiting or using in any way, any part of the Service and/or Content you irrevocably agree to have your data, and the data of any entity represented by you collected, processed and stored by Luner.

Our data collection includes:

  • Personal and contact information (such as: names, dates of birth, addresses, email addresses, document serial numbers, social media accounts, relevant entity documentation, phone numbers etc.)
  • Information related to the use of the Service and/or Content (IP addresses, device information, referring URL(s), log information, geographic location, date and time, etc
  • Account Activity information.
  • Correspondence information submitted by any user, such as submitted questions, complaints or communications with customer support, or any other representative
  • Financial information provided by any user.
  • Publicly available information, including information found on websites and/or promotional material related to and relevant company or organization, information made public by media articles or by public registries, governmental agencies, regulatory authorities, fraud prevention agencies and organizations etc.
  • Aggregated and statistical data that may be derived from personal data, but is not considered personal data as it does not directly or indirectly identify anyone, in any case when aggregated data is crossed with your personal data in any way that could identify you, Luner will treat the combined data as personal data.
  • Recordings or transcripts of telephone conversations or other types of communications such as emails and chats, between you and Luner. Copies of any correspondence may be saved by Luner.
  • Information received from third parties (Luner works with third parties (including but not limited to service providers, identity verification services etc.) and may collect information about you received from them.
  • Any and all other information voluntarily provided by any of our users at any time.

Luner does not knowingly collect information about individuals under the age of 18. Luner, its Service and Content are intended for persons of 18 years or older, individuals under the age of 18 are not permitted to use the Service or Content or submit any personal information.

Purposes of Data Collection

Luner collects and stores personal information where we have a legal basis to do so, including the following:

  • In order to process registration on the Service, maintain a user database, provide information regarding the Service and Content, and send you any information regarding changes to our Terms of Service or any other policy.
  • In order to verify your identity, prevent fraud and comply with any legal or regulatory right.
  • For the purpose of providing you with any requested information in any way that may require your consent such as alerts, emails, push notifications or SMS messages.
  • In order to provide approval to third party services that you are existing customer. Third party services do not have permission to use any such data for any other purpose whatsoever.
  • For any legitimate interest by Luner or any other relevant third party, including but not limited to: identification and authentication, customer service, contacting you regarding any services features or products, our Services security, syncing user preferences between devices, enforcing compliance with our Terms of Service or any other policy, assisting relevant third parties with enforcing their rights, content tailoring, advertising and offers etc.
  • For the pursuit of Luner’s legitimate marketing and business interest.
  • In order to conduct market research surveys.
  • For the purpose of compliance with any legal and regulatory obligations, including but not limited to Anti Money Laundering and Counter Terrorist Financing legislation, and other applicable law.

If you do not wish to receive marketing information you may inform us by email at


  • Luner collects information regarding your use of Service and Content by means of Cookies.
  • Cookies are small files that are placed on your computer's hard drive at your permission. Cookies allow Luner to analyze website use and traffic, and notifies when a user visits particular sites. Cookies allow personalized communications with a website or application by gathering and storing user preferences.
  • Cookies are used to map Luner’s website use. They are used to helps us analyze web page traffic and data; this information is used solely for statistical analysis and is then deleted.
  • Cookies do not allow any access to your computer or data by anyone, other than data which you choose to share with Luner according to the Terms of Service and Privacy Policy.
  • You may choose to allow or deny any or all Cookies on your browser. Many web browsers are set to accept cookies automatically, it is the sole responsibility of the user to allow or decline some or all Cookies.
  • Cookies are required in order to make use of Luner’s Service, denying Cookies may prevent you from making use of the Service and Content.
  • Cookies help us provide better Service, by allowing us to provide services tailored to the user.
  • Luner and its ad partners may use Web Beacons (Internet/pixel tags, or clear GIFs). Web Beacons collet information such IP addresses, page URL, Browser type and time stamps, of computers who access any Service or Content containing the Web Beacon. Luner and its Ad Partners may use Web Beacons in order to identify unique cookies on your web browser.
  • Information collected and shared by Luner, by means of cookies and web beacons is anonymous, and does not contain any personal or identifiable information.

By using any of the Services you give Luner explicit and ongoing consent for the collection, use, disclosure and retention of any and all personal information that you provide, as described in this Privacy Policy and our Terms of Service.

Data Storage and Security

Luner may use third party hosting partners to provide the Service and Content. Any and all codes, databases, and all rights to any part of the Service remain the sole property of Luner. Luner implements necessary precautions to protect your personal information and store it in a secure way. Luner does not guarantee that any unauthorized person will be successfully prevented from gaining unapproved access to personal information collected, despite our best efforts and security standards.

By using the Service or Content you irrevocably consent to your information being sent over the Internet and through third parties and mobile networks which are not controlled by Luner.

Any information transmitted to other users will not be protected by Luner or this Privacy Policy in any way whatsoever. Personal or identifying information should never be sent to other users, sending or transmitting any information to other users is done at the user’s sole responsibility.

Data Transfer and Processing

Luner, its Service and Content are located in the Cayman Islands. This Privacy Policy and the Terms of Service are governed by and written in accordance with the Cayman Islands Data Protection Law 2017, without regard to any principles of conflicts of law.

Luner controls all personal information processed in relation to the Service and Content, and is considered the “data controller”' regarding your personal information

Users accessing or using the Service and/or Content in any way whatsoever acknowledge and consent to the collection, gathering, processing, and transfer of any and all data or information in and to the Cayman Islands and to any other country, territory or jurisdiction. Other countries territories and jurisdictions may have different privacy laws then the Cayman Islands or the user’s home jurisdiction.

Users agree that the Privacy Policy and the Terms of Service will remain in effect and consent to the transmission and processing any and all personal information in any whatsoever.


Luner maintains the right to change this Privacy Policy at any time with no prior notification or cause. Luner may communicate and notify you about significant changes, however it is the user’s sole responsibility to read this Privacy Policy and ensure that they are updated and agree to any changes. Any individual or entity, continuously using the Service and or Content, irrevocably agrees to this Privacy Policy and the Terms of Service.

Your Rights

Users maintain the right to access, change, download or delete their information, and may restrict or deny the processing of their information for a specific purpose or completely.

Users may instruct Luner to avoid sending marketing communications and to omit their personal data from being used for direct marketing purposes.

Users may ask Luner to amend, correct or rectify their personal data in case it is incomplete, inaccurate or outdated.

Users have the right to ask Luner to stop using their personal data for profiling (automated processing of personal data).

All such requests are must be done in writing to the following address: will comply or revert within maximum 21 days from receiving written request.

Users have the right to request a copy of your personal information, known as a ‘subject access request’ (SAR). SARs should be made in writing and provided to Luner, alongside identity and address proof. In case of requesting information in the name of another person, or as a representative of an entity, Luner will require written consent and/or relevant entity documents proving your appointment as a representative or employee of said entity in addition to the above.

Luner shall have 30 days from receiving written notification to provide requested SAR information. Luner may extend this period for complex or numerous requests. In such a case Luner will provide an explanation to the extension within the prescribed period of time.

Luner will provide a basic copy of your information with no charge. However, in the case of repetitive or excessive requests, we may charge a reasonable fee which will be based on administrative costs incurred by us in providing your information.

In case of unfounded or excessive information requests, Luner may refuse to respond to a request, in such a case Luner will provide an explanation to the refusal.

Luner maintains the right to contact Ombudsman requesting permission not to comply with any specific request, in case continuous processing of certain data is deemed necessary, (such as in order to comply with a legal obligation).


Any questions, comments, clarifications or requests, regarding this Privacy Policy, our Terms of Service, data collection or a user’s personal data, should be emailed to the following address:

Users can opt out of receiving newsletters and other marketing communications by SPECIFY PROCESS

If you feel we have not complied with your request, you have the right to complain to the Ombudsman (whose contact details are below).

Information Commissioner,

Ombudsman Cayman Islands