Lunos Platform Privacy Policy

Policy version: 2026-02-13

Lunos.ai and all our subdomains and integrations (our Platform) is provided by Lunos Inc trading as “Lunos” (we, our or us). We are responsible for deciding how and why personal data collected through our Platform is used and processed.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our Platform. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use, and are responsible for certain personal data about you. When we do so, we are subject to applicable U.S. data protection laws, including the California Consumer Privacy Act (CCPA) and other relevant state or federal privacy regulations, in relation to personal data collected from individuals within the United States. If you are based in the UK we are subject to the UK General Data Protection Regulation (UK GDPR) and in the EU, the EU General Data Protection Regulation (EU GDPR).

This privacy policy is divided into the following sections:

What this policy applies to
Personal data we collect about you
How your personal data is collected
How and why we use your personal data
Marketing
Who we share your personal data with
How long your personal data will be kept
Transferring your personal data out of the US, UK and EEA
Cookies and other tracking technologies
Automated decision-making technology
Your rights
Keeping your personal data secure
How to complain
Changes to this privacy policy
How to contact us

What this policy applies to

This privacy policy relates to your use of our Platform only.

Throughout our Platform we may link to other websites owned and operated by certain trusted third parties to allow you to access data in those systems more easily and to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our Platform. We may collect and use the following personal data about you:

your name, address and contact information, including email address and telephone number
the name and contact details of your company
your communication history with the Platform, including, but not limited to, the contents of emails and phone calls about accounts and balances
your billing information, transaction and payment card or other payment method information
bank account and payment details
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your account details, such as username and login details
your activities on, and use of, our Platform
your responses to surveys, competitions and promotions
your professional online presence
information about the services we provide to you
your responses to surveys, competitions and promotions

You must provide this personal data to use our Platform and the services on it unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our Platform or any of the services on it.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our Platform, use our Platform, post material to our Platform and complete customer surveys or participate in competitions via our Platform, and
indirectly, such as your browsing activity while on our Platform; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.

We may also collect personal data about you from other sources as follows:

API integrations with other software we use in our Platform. This includes:
- Account, invoicing and billing software
- Communication and email software, including Slack and Google Workspace (Gmail)
- Customer Relationship Management and Customer Support
- Payment providers

Our collection, use, and transfer of information received from API integrations, including Google APIs, will adhere to the specific policies of the API provider, including the Google API Services User Data Policy.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

Lunos is an AI accounts receivable worker. The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	To perform our contract with you or to take steps at your request before entering into a contract.
Providing products and services to you	To perform our contract with you or to take steps at your request before entering into a contract. Providing our service includes, but is not limited to: Using contact information to communicate via email and other means to help you to manage your receivables Using third-party APIs to take actions on your behalf, with your approval. For instance, sending emails on your behalf from your Gmail account or updating records in your accounting software Storing data obtained from API integrations, including emails, in order to display them within our Platform as well as analyzing them to help you to manage your receivables Displaying information within our Platform to help you to manage your receivables. For instance, displaying emails and other communications you have had with your customers and colleagues, as well as the status of your receivables Our use and transfer of information received from third-party APIs, such as Google, will adhere to the specific policies of the API provider.
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
Enforcing legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests, ie to protect our business, interests and rights
Customising our Platform and its content to your particular preferences based on a record of your selected preferences or on your use of our Platform	Depending on the circumstances: your consent as gathered by the cookies tool on the public website part of our Platform—see ‘Cookies and other tracking technologies’ below where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our Platform and how you move around different sections of our Platform for analytics purposes to understand how people use our Platform so that we can make it more intuitive or to check our Platform is working as intended	Depending on the circumstances: your consent as gathered by the cookies tool on the public website part of our Platform—see ‘Cookies and other tracking technologies’ below where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products and services or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract to comply with our legal and regulatory obligations for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at help@lunos.ai
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and will never sell it to other organisations outside the Lunos group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our products and services to you, e.g. payment service providers, warehouses and delivery companies
other third parties we use to help us run our business, e.g. marketing agencies or web hosting and analytics providers

We or the third parties mentioned above occasionally also share personal data with:

our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data. Further details on this are available upon request.

If you stop using your account we will delete or anonymise your account data after seven years.

Following the end of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the US, UK, EEA, and Switzerland

Countries outside of the US, UK, EEA, and Switzerland have differing data protection laws, some of which may provide lower levels of protection for privacy. It is sometimes necessary for us to transfer your personal data to countries outside of the US, UK, EEA, and Switzerland. In such cases, we will comply with applicable US, UK, EEA, and Swiss laws designed to ensure the privacy of your personal data.

We may transfer your personal data to service providers located outside the US, UK, EEA, and Switzerland. As we are based in the US, we will also transfer your personal data between the US, UK, EEA, and Switzerland.

Under data protection laws, we can only transfer your personal data to a country outside the US, UK, EEA, or Switzerland where:

in the case of transfers subject to US data protection laws, applicable safeguards ensure compliance with relevant US data transfer requirements.
in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (an ‘adequacy regulation’) under Article 45 of the UK GDPR. We rely on adequacy regulations for transfers between the UK and the US, EEA, and Switzerland.
in the case of transfers subject to EEA data protection laws, the European Commission has determined that the particular country provides adequate protection for personal data under Article 45 of the EU GDPR. We rely on adequacy decisions for transfers between the EEA and the US, UK, and Switzerland.
in the case of transfers subject to the Swiss data protection laws, the Federal Council recognizes the adequacy of protections provided by the particular State under Article 16 of the Swiss Federal Act on Data Protection (FADP). We rely on adequacy regulations for transfers between Switzerland and the US, UK, and EEA.
there are appropriate safeguards in place with enforceable rights and effective legal remedies for you.
a specific exception applies under relevant data protection law.

When transferring personal data outside the US, UK, or EEA, we rely on an adequacy regulation, an adequacy decision, or (where these are not available) legally-approved standard data protection clauses (e.g. standard contractual clauses recognized under Article 46(2) of the UK or EU GDPR or US-based equivalents). Should we be unable or choose not to continue using these mechanisms, we will ensure transfers comply with alternative mechanisms or exceptions provided by relevant data protection laws and update this policy accordingly.

Any changes to the destinations to which we send personal data or the transfer mechanisms we rely on will be communicated in accordance with the ‘Changes to this Privacy Policy’ section below.

Data Privacy Framework Obligations

Lunos complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Lunos has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Lunos has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the DPF Principles and/or the Swiss-U.S. DPF Principles (DPF Principles), the Principles shall govern. To learn more about the Data Privacy Framework Program (DPF Program), and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the DPF Program, Lunos is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Pursuant to the DPF Principles, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States in reliance on the DPF Program should direct their query to support@lunos.ai. If requested to remove data, we will respond within a reasonable timeframe. Additionally, we will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@lunos.ai.

If you are an EU, UK, or Swiss Individual, where we transfer your personal data to third party service providers who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

RECOURSE: In compliance with the DPF Principles, Lunos commits to resolve DPF Principles-related complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, and Swiss individuals with inquiries or complaints regarding our handling of personal data in reliance on the DPF should first contact Lunos at: support@lunos.ai.

Lunos has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.

See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Platform. We use cookies and single-pixel gifs on our Platform.

For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Automated decision-making technology

Our Platform utilizes automated decision-making technology to enhance the efficiency and accuracy of our Platform. This technology employs algorithms to analyze historical payment patterns, creditworthiness, and other relevant financial data to make decisions regarding credit limits, payment terms, and collection strategies. The logic behind these decisions is based on a combination of data inputs, statistical analysis, and predictive modeling.

While this technology helps streamline operations and improve decision accuracy, it is important to note that automated decisions can have significant consequences for individuals and businesses, such as affecting credit terms, payment schedules, and the prioritization of collection efforts. We strive to ensure that our automated decision-making processes are fair, transparent, and compliant with applicable laws. You may contact us if you have any concerns or require further information about how these automated decisions are made and their potential impacts.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please email us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (e.g. your full name, address and company name) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

state Attorney Generals or the Federal Trade Commission (FTC), which oversees compliance with federal consumer protection laws, including certain aspects related to data privacy,
the Information Commissioner in the UK,
a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work, or the location of an alleged infringement of data protection laws in the EEA.

For U.S.-based complaints, you may contact your state’s Attorney General office or the Federal Trade Commission at https://reportfraud.ftc.gov.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details, see https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

The Swiss Federal Data Protection and Information Commissioner (FDPIC) may be contacted at https://www.edoeb.admin.ch/en/contact-2.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email and/or by including a prominent link to a description of those changes on our Platform for a reasonable period.

How to contact us

You can contact us by email or post if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Email: support@lunos.ai

Post: 447 Broadway, 2nd Floor Unit 273, New York, NY, 10013, USA