Policy version: 2025-12-08
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).
Lunos complies with the EU-U.S. Data Privacy Framework (EU-U.S.DPF) and the UK Extension to the EU-U.S. Data Privacy Framework (DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere 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 UK Extension.
This privacy policy is divided into the following sections:
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.
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:
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.
We collect personal data from you:
We may also collect personal data about you from other sources as follows:
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.
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
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:
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:
|
| 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:
|
| 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:
|
| 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:
|
| 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:
|
| 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:
|
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.
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:
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.
We routinely share personal data with:
We or the third parties mentioned above occasionally also share personal data with:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
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.
Countries outside of the US, UK, and EEA 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, and EEA. In such cases, we will comply with applicable US, UK, and EEA laws designed to ensure the privacy of your personal data.
We may transfer your personal data to service providers located outside the US, UK, and EEA. As we are based in the US, we will also transfer your personal data between the US, UK, and EEA.
Under data protection laws, we can only transfer your personal data to a country outside the US, UK, or EEA where:
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.
Lunos participates in the EU-U.S. Data Privacy Framework (“DPF”), a data transfer mechanism administered by the U.S. Department of Commerce and recognized by the European Commission as providing an adequate level of data protection for personal data transferred from the European Union, the United Kingdom, and Switzerland to the United States. Lunos has committed to comply with the DPF Principles with respect to such personal data, including accountability for onward transfers.
You can learn more about the Data Privacy Framework and view the official participant list at: https://www.dataprivacyframework.gov.
When Lunos transfers personal data received under the DPF to a third party acting as an agent or service provider, we do so in accordance with the DPF Principles and applicable law. We require such third parties to provide at least the same level of protection for personal data as required under the DPF and to process the data only for limited and specified purposes consistent with this Privacy Policy.
Lunos remains liable under the DPF Principles if a third party processes personal data in a manner inconsistent with the DPF, unless Lunos demonstrates that it is not responsible for the event giving rise to the damage.
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.
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.
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.
You generally and under the DPF principles 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:
|
| Recourse | The right to seek recourse if you believe your personal data has been processed in violation of the DPF Principles. |
| 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 these 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:
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.
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:
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 here.
If you believe that Lunos has not complied with the DPF Principles in processing your personal data, you should first contact us using the details below so that we can attempt to resolve your complaint directly.
If your complaint is not resolved, you may pursue independent dispute resolution free of charge, or in certain circumstances invoke binding arbitration, in accordance with the DPF Principles. The U.S. Federal Trade Commission (FTC) has jurisdiction over Lunos’s compliance with the DPF.
Additional information about the DPF complaint and enforcement process is available at https://www.dataprivacyframework.gov.
In compliance with the EU-U.S. Data Privacy Framework (DPF), Lunos has designated an Independent Recourse Mechanism (“IRM”) to address complaints regarding our compliance with the DPF Principles.
Individuals should first contact us directly using the contact details provided above. If we are unable to resolve a complaint, individuals may submit their complaint free of charge to our designated IRM:
BBB National Programs: https://www.bbbprograms.org/dpf-complaints
If a complaint is not resolved through the IRM, individuals may, under certain conditions, invoke binding arbitration before the DPF Arbitration Panel as a last-resort mechanism, as described in the DPF Principles.
The U.S. Federal Trade Commission (FTC) has jurisdiction over Lunos’s compliance with the DPF.
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.
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