1.1. lunOcto Ltd (herein referred to as “lunOcto” or “we”, or “us” or “our” or the “Company) is committed to safeguarding the privacy of its users, providing a safe online experience for everyone.
1.2. With this Privacy Policy, the Company aims to notify the website’s/application’s visitors and/or service users about their rights and to provide them with further information on how the Company collects, uses, discloses, and processes their Personal Data through the use of the website lunocto.io and the lunOcto application per the EU General Data Protection Regulation ((EU 2016/679 (“GDPR”)) and any laws or regulations supplementing or implementing the GDPR, as amended, replaced, or suspended from time to time (together with the GDPR, the “Data Protection Legislation”).
1.3. For the purposes of this policy “Personal Data” refers to any data which relates to a physical person who can be identified from such data.
1.4. This policy applies in those cases where we act as a data controller for the personal data of our Website/Application visitors and service users. This means those cases where we can decide the purposes and method of processing your data.
1.5. By accessing and/or using our Website/Application, you consent to the terms of this policy and the data practices described in this policy. You also acknowledge that you have read, understood, and agreed to be bound by the terms, conditions, and notices contained in this policy and additionally to comply with all applicable laws and regulations.
1.6. We reserve the right to update and make changes to this policy from time to time. You should check back regularly to ensure that you are up to date with any changes to this policy. Any changes posted will come into effect from the date of such posting.
1.7. If you do not consent with this Privacy Policy or any part of this Privacy Policy, you should not create a lunOcto account for lunOcto Wellness Assessment Test purposes. However, this will only enable you to use the Website/Application in a limited capacity and without enabling you to save your lunOcto Wellness Assessment Test results for later reference.
2.1. We may obtain Personal Data from you:
2.2. We may obtain anonymous Non-Personal Data, demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests, and similar information.
2.3. We do not collect any Special Categories of Personal Data, including details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, as well as genetic and biometric data. We likewise do not collect any information about criminal convictions or offenses.
2.4. We may process data about your use of our Website/Application and services (“usage data”). The usage data may include your IP address, geographic location, browser type, and version, operating system, referral source, length of visit, page views, and Website navigation paths, as well as information about the timing, frequency, and pattern of your Website/Application or service use. This usage data may be processed to analyze the use of our Website/Application and services. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely for monitoring and improving our Website/Application and services.
2.5. We may process your Personal Data to provide better services to you and ensure the security of our Website/Application and services, as well as maintenance of backups of our databases and communication with you. Specific services, which may be the subject of your Personal Data, including but are not limited to using such data for the following services, and may require your specific consent:
2.6. We may process your Personal Data for medical research purposes (in the form of lunOcto Wellness Assessment Test results) with the explicit intent to further the potential of wellness assessment tests moving forward.
2.7. We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our Website/Application (“transaction data”). The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed to supply goods or services and keep proper records of those transactions.
2.8. We may process any of your Personal Data identified in this policy where necessary for administrative purposes, including in the exercise or defense of legal claims. The legal basis for this processing is our legitimate interests, namely for administrative record-keeping, processing transactions, and maintaining business records or for the protection and assertion of our legal rights.
2.9. If you supply any other person’s Personal Data to us, you must do so only if you have the authority of such person to do so and you must comply with any obligations imposed upon you under the Data Protection Legislation.
2.10. The Company also uses your personally identifiable information to inform you of other products or services available from the Company and its affiliates.
2.11. lunOcto Ltd will NOT provide information to law enforcement agencies or regulatory authorities unless required by law with a valid court order, subpoena, or search warrant for Personal Data. lunOcto Ltd requires all law enforcement inquiries to follow a valid process. We are ready to exhaust available legal remedies to protect your privacy. If compelled to disclose any Personal Data, lunOcto Ltd will try its best to provide you with prior notice, unless we are prohibited from ding so under the law. We will not voluntarily share your Personal Data with;
3.1. We may disclose your Personal Data to insurers or professional advisors insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or exercising or defending legal claims.
3.2. We may pass your Personal Data or information to credit reference agencies or other agencies that provide services to verify your identity or for any other checks or searches required by legislation or our regulators relating to money laundering. These agencies may keep a record of any search that they do.
3.3. If you carry out financial transactions through our Website/Application, these services will be handled by our payment services providers. We share transactional data with our payment services providers to the extent necessary for processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
3.4. We may outsource or contract the provision of IT services to third parties. If we do, those third parties may hold and process your Personal Data. In these circumstances, we will require that the IT supplier only process your Personal data for us, as directed by us, and in accordance with the Data Protection Legislation.
3.5. If we sell all or part of our business, we may pass your Personal Data to the purchaser. In these circumstances, we will require the purchaser to contact you after the completion of the sale to inform you of the identity of the purchaser.
3.6. In addition to the specific disclosures of Personal Data set out in this Section 3, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your legal interests or the legal interests of another person.
3.7. We DO NOT sell your Personal Data, user information, or lunOcto Wellness Assessment Test results. All of your personal data remains solely with us. We respect your desire for privacy and are here to help facilitate your personal development without infringing on your privacy concerns. Your Personal Data, user information, or lunOcto Wellness Assessment Test results will NOT be sold to third parties.
7.1. Your principal rights under the Data Protection Law are:
7.2. You have the right to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes the details of the purposes of the processing, the categories of Personal Data concerned, and the recipient of the Personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your Personal Data.
7.3. You have the right to have any inaccurate Personal Data about you rectified and, considering the purposes of the processing, to have any incomplete Personal Data about you completed.
7.4. In some circumstances, you have the right to the erasure of your Personal Data without undue delay. Those circumstances include:
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary:
7.5. In some circumstances you have the right to restrict the processing of your Personal Data. Those circumstances are:
Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it:
7.6. You have the right to object to our processing of your Personal Data on the grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
If you make such an objection we will cease to process the Personal Data unless we can demonstrate compelling, legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
7.7. You have the right to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.
7.8. You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on the grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.9. To the extent that the legal basis for our processing of your Personal Data is:
7.10. If you consider that our processing of your Personal Data infringes on any data protection law, you have a legal right to complain to a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work, or the place of the alleged infringement.
7.11. To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12. You may request that we provide you with any Personal Data we hold about you. Provision of this information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
To exercise any rights, or if you have any other questions about our use of your Personal Data or information, please contact us via the contact form at: lunocto.io/get-in-touch.
9.1. Our Website uses cookies. For further details, please visit our Cookie Policy page at Cookie Policy.
11.1. The Website is owned and operated by lunOcto Ltd. lunOcto’s mission is to provide everyone with the platform to help guide them on their journey of self-discovery. lunOcto adopts the wellness framework known as “The Eight Dimensions of Wellness”. Its goal is to celebrate what came before and pave the way for what comes next for the wellness industry – it is a fresh new take on attaining wellness.
11.2. lunOcto features the lunOcto Wellness Assessment Test as a part of its service portfolio, enabling individuals to measure their wellness and gain higher self-awareness. lunOcto also features a White Labeling solution intended for educational and corporate entities who are looking for wellness management solutions for their stakeholders. In addition, lunOcto features referral and affiliate marketing programs designed to raise further awareness of its brand, mission, and services to anyone looking for a reliable wellness management solution.
11.3. By accepting this Privacy Policy and by consenting to the collection and processing of your Personal Data, information, and Non-Personal Data, lunOcto Ltd retains the rights to suggest solutions for your personal development and daily assistance based on the Personal and Non-Personal Data and information you are providing us with.
11.4. lunOcto Ltd is located at 124 City Road, London, EC1V 2NX.
11.5. Get in touch with us via the contact form located at Get in touch.
