Lune Privacy Notice
This policy was last updated on 9 June 2021
1. About this notice
Lune Climate Ltd is committed to protecting and respecting your privacy. This notice describes how we collect, use and otherwise process personal information relating to you, or that you provide to us:
(i) when you engage with us as a customer;
(ii) when you visit or use:
• our website at https://lune.co/ (the “Website”);
• any of our software applications or platforms (“Apps”) and;
• our social media pages.
Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read this notice carefully to understand our practices regarding personal information.
By engaging with us via any of the means set out above, you are accepting the practices described in this notice.
For the purposes of this notice, all references to the Website shall include a reference to the Apps, and references to “Lune”, “we”, “us” or “our” are to Lune Climate Ltd, a company registered in England and Wales under company registration number 13224979 with our registered office at 50 Holland Park Mews, London, England, W11 3SP.
For the purposes of data protection laws, the data controller is Lune. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. Our Information Commissioner’s Office registration number is ZB081091.
In this notice, the terms “personal data (or information)”, “processing”, “data controller” and “data processor” shall have the meaning ascribed to them in the UK General Data Protection Regulation.
2. What personal data do we collect?
2.1. Information that we collect from you
The type of information we collect from you will depend upon the type of interaction you have with us.
Broadly speaking, the types of personal data that we collect may include:
(i) if you are a customer of Lune: your first and last name, job title, email address, postal address, telephone number and the details of the transactions which you conduct with us (including details about your orders and the carbon credits you have bought from us, the services you have used, the payments from you and your payment account details);
(ii) if you are a visitor to our Website: “tech information” like your IP address, geographical location, browser type, length of visit and pages viewed, your unique device identifiers and other diagnostic data; and
(iii) personal data you provide to us such as when you register or create an account with us or when you communicate with us through email or our social media pages.
You are under no obligation to provide any such data. However, if you choose to withhold requested information, we may not be able to properly engage with you properly or provide our services and products to you.
3. How do we use personal data?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
(i) Where we have your consent.
(ii) Where we need to perform the contract we have with you.
(iii) Where we need to comply with a legal obligation.
(iv) Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. Our legitimate interests include the following:
• to communicate with you and respond to your queries;
• to provide you with information, products or services that you request from us;
• to understand that ways in which our Website is being accessed and used;
• to ensure that content from the Website is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep the Website safe and secure; and
• to develop and improve our products and services.
4. Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to fulfil your orders and to enable us to provide our services and products to you. We may also use your personal information to pursue legitimate interests. The situations in which we will process your personal information are listed below.
We may process personal data in the following ways:
(i) To register you as a customer and to set up your customer and user accounts with us.
(ii) To allow you to make purchases via the Website and fulfil your orders.
(iii) To store data and use data analytics and analysis to review and better understand customer behaviour and trends and to improve our Website, products/services, marketing, customer relationships and experiences.
(iv) To ensure that content on the Website is presented in the most effective and relevant manner for you and for your device and to tailor the Website’s experience and content based on the way that you use the Website.
(v) To manage our relationship with you which includes notifying you about changes to our terms of business and privacy notices.
(vi) To administer and protect our business, Website (including troubleshooting, data analysis, testing, system maintenance, security, support, reporting and hosting of data).
(vii) To deal with your enquiries, requests, complaints and claims.
(viii) To prevent fraud and criminal activity.
(ix) To notify you about changes to our Website and services.
(x) To provide you with marketing content in line with your preferences and to measure the effectiveness of the marketing communications we send you.
(xi) To store cookies on your device.
(xii) To comply with legal or regulatory requirements.
(xiii) For our business management and planning, including accounting and auditing.
If you want to learn more about what lawful bases we rely upon, or the types of data we collect, in respect of each situation in which we process your personal information, you may contact us using the contact details at the bottom of this privacy notice.
5. How do we share personal data with third parties?
We may disclose personal data relating to you to third parties in certain circumstances including the following:
(i) suppliers that we engage to help us run our business, such as IT services suppliers and third-party negative emissions and carbon offset developers or registries we have partnered with;
(ii) analytics and search engine service providers that assist us in the improvement and optimisation of the Website;
(iii) our professional advisors, including lawyers, accountants, tax advisors and auditors;
(iv) law enforcement bodies, Courts of law or as otherwise required or authorised by law; and
(v) regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies.
We may also disclose personal data to third parties:
(i) in the event that we sell our business or assets, in which case we may disclose your personal data to the prospective buyer or buyer of such business or assets;
(ii) if we restructure our business, or if we integrate our business with another group of companies, in which case personal data held by us will be disclosed to the new owner to be used in the same ways set out in this notice; and
(iii) if we are under a duty to disclose or share personal data relating to you in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions on which we supply services to you and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Before Lune discloses any personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this notice. Third parties are required to restrict their use of this information to the purpose for which the information was provided.
6. External Links
Although the Website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout the Website.
The Website may, from time to time, contain links to and from the websites of our distributors, partners, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. Social Media Platforms
Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.
8. Where do we store personal data?
The personal data that we collect from you may be transferred to, and stored at, locations outside the United Kingdom (“UK”). It may also be processed by staff operating outside the UK who work for us or for one of our suppliers or service providers. Such staff maybe engaged in, among other things, the provision of support services.
Countries where personal data relating to you may be stored and / or processed, or where recipients of personal data relating to you may be located may have data protection laws which differ to the data protection laws in your country of residence and may not have been granted “adequacy” status by the UK.
By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will use appropriate safeguards such as the EU and UK approved Standard Contractual Clauses to ensure that your personal data is treated securely and in accordance with this notice.
If you would like further information, please contact us using the contact details at the end of this privacy notice.
9. How do we protect personal data?
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to Website; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.
All information you provide to Lune is stored on secure servers. The safety and security of your information and any personal data relating to you also depends on you. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Lune takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.
10. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. Automated decision-making
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
12. Data retention
12.1 How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
13. Your rights
You have the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. You will not have to pay a fee to access personal information relating to you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We also want to make sure that personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate.
You also have the right, in certain circumstances, to:
• the erasure of personal data relating to you that we hold;
• the restriction of processing of personal data relating to you that we hold;
• object to our processing of personal data relating to you that we hold; and
• request the transfer of your personal data to another data controller.
Requests in this section should be sent by email or by writing to us using the contact details set out at the end of this notice.
We will only send you marketing material if you consent. When you have consented to marketing material, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the marketing emails we send to you. You can also exercise the right at any time by sending an email or by writing to us using the contact details set out at the end of this notice.
If you have a concern about the way we are collecting or using your personal information, we request that you raise your concern with us in the first instance. Alternatively, you can contact the UK’s supervisory authority, the Information Commissioner’s Office, at https://ico.org.uk/concerns/.
You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.
You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit a site/page and some services and functionalities may not work properly at all. You can manage/delete cookies as you wish.
15. Changes to this notice
Lune reviews and amends its privacy notice from time to time. Any changes we make to this notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check this page occasionally to review any updates or changes to this privacy notice. This helps you be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed.
16. Contacting Us
If there are any questions regarding this privacy notice, you may contact us using the information below.