LOÓNA PRIVACY POLICY

Effective Date: April 25, 2024.

This privacy policy explains how we, Loona Inc. of 8 The Green, Ste B, Dover, DE, 19901, USA or any of our affiliated entities(“Loóna”, “we”, “us”, “our”) process your personal information (“you”, “your”) when you use our website, app or other services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY 

By using the Loóna mobile application (the “App”) or the website located at https://loona.app/ (the “Website”) (App and Website individually referred to as a “Loóna Service” or collectively as the “Loóna Services”) or otherwise indicating your acceptance (e.g. by clicking tick-box or bottom “agree” or “continue”), you agree to the following terms of our Privacy Policy, which will bind you at all times and in whatever manner you use the Loóna Services.

Please note:

  1. Individuals in the European Economic Area (EEA) and the United Kingdom (UK) should also read our section about “Your EEA & UK Data Privacy Rights”.
  2. Individuals in California should also read our section about “Your California Privacy Rights”.
  3. Individuals in Nevada should also read our section about “Your Nevada Privacy Rights”.


  • 1. WHAT THIS PRIVACY POLICY APPLIES TO

This Privacy Policy applies to all Loóna Services. 

  • 2. WHAT TYPES OF INFORMATION DO WE COLLECT

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.

We will process the following information which may be considered personal information:

Information You Provide To Us Directly

  • Account details.Your user details when you sign up as a user of Loóna Services, such as your name/ user name and email address. If you log in with your Apple ID we will receive your Apple ID and may receive the email address associated with your Apple ID, depending on your Apple settings. If you log in via your Google Account we will receive your associated email address.
  • Details of your request. When you contact or visit us, we may process the details of your request, communications, complaints, or other interaction.
  • Activity Data and Health Data. Information you provide to us when you participate in any interactive features of Loóna Services, including surveys, contests, promotions. For instance, if you choose to take our test to determine your ideal sleep schedule, you can voluntarily share personal information with us. This may include details such as your gender identity, age group, whether you have children, information about your sleep and activity patterns, and health data. This information will be solely utilized for generating test results and performing statistical analysis. The retained data will be stored for up to 12 months and will be automatically deleted. The health data you provide will be processed on the basis of your consent, which you will be able to withdraw at any time by contacting us at privacy@loona.app. 

Information We Collect Automatically

Such automatically collected data helps us operate Loóna and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Loóna and what you like and dislike the most.

  • Transaction information. Transaction information such as your purchases in our Loóna Services, including date of purchase, currency, amount, payment type and the last four digits of your card number.
  • App and country information: Information regarding the version of the app that you are using and the country version of the app store from which you downloaded Loóna.
  • Device information. When accessing Loóna Services, your device and browser will automatically provide unique information such as account ID, mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, operating system, browser type, time zone setting, location and date and time of access. (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Loóna Services, please follow in-app instructions.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.

Tap to turn off or turn on permission to track for Loóna.

If you use an Android device:

Open Settings app

Navigate to “Privacy” > “Ads”

Tap “Delete Advertising ID”

Tap it again on the next page to confirm.

We and third-parties may use cookies, Software Development Kits (SDKs), and other tracking technologies to automatically collect the Personal Data set forth above. For more information regarding our use of these technologies, please see Section 6: Cookies, Software Development Kits, and Other Tracking Technologies.

  • Usage data. Details of your use of Loóna, including frequency of use, areas and features of the application that you access and information regarding engagement with particular features of the app.
  • Interaction information. When we send you emails or other communications, we may collect technical interaction information, such as open rates and if you clicked on any content.

Information We Obtain From Third Parties

In addition to the information you may provide us directly, we receive information about you from others, including:

  • Social media. You may decide to share information with us through your social media account, such as your interaction with our posts and content, social media profile by sharing your “stories” and ‘likes’ on social media platforms, such as Twitter and Instagram, TikTok.
  • Our suppliers. We may receive information about you from our partners where our ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). We may receive information about you from our analytics service providers to help us measure traffic and usage trends with data they collect through Loóna Services in accordance with their own privacy policies.
  • 3. DATA ACCURACY

We will rely on the information provided by you as accurate, complete, and up to date, and we would be grateful if you could inform us of any changes.

  • 4. WHAT PURPOSES DO WE COLLECT YOUR INFORMATION FOR?

Generally, we will use your personal information to (i) provide Loóna Services and enable you to use our service features, (ii) respond to your queries, (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of Loóna Services; and (v) comply with the law.

*If you are an individual in the EEA or the UK, we have to inform you about the “legal ground” for us to use your “personal data”. This will typically be the performance of our contract with you (based on our Loóna Terms of Use) or our legitimate interest to use your personal data to ensure that Loóna Services are provided properly, efficiently and securely, as is further explained below. We may be obligated to process some of your personal data to comply with applicable laws and regulations. 

Where the legal basis is consent, you can withdraw consent at any time. You may withdraw your consent by adapting your settings or by deleting your content (for instance where you entered information in your profile that may be considered 'special' or 'sensitive'). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Where we rely on legitimate interests as the legal basis for processing personal data, we have considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose data are being processed and concluded that the processing is, on balance, fair. Where the legal basis is legitimate interests, you have a right to object to our use of your data.

We use your information for the following purposes:

  • To register you as a service user when you sign up for Loóna Services and to enable you to use Loóna Services and its functionalities. 
  • To enable you to make purchases through our Loóna Service.
  • To assist and contact you in relation to your enquiry or to send you information which you have requested about Loóna Services.
  • To fulfill your requests and send you service communications and notifications about matters relevant to your use of Loóna Services and your engagement with us, such as information about offers you might be interested in, targeted content, confirmations of purchases, details of events, surveys, changes in our terms, etc.
  • To send you promotional information through various marketing channels including post, email, social media and etc. about Loóna Services and our organization, reviewing and optimizing campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.
  • To improve and develop Loóna Services, including to: obtain feedback; record preferences; conduct statistical analysis; make services and features more relevant; improve user experience; and work with third parties and evaluate data to improve and develop Loóna Services.
  • To ensure proper administration of our business, including to: keep appropriate records about how Loóna Services are used; resolve complaints; conduct troubleshooting; manage our business relationships and identify opportunities; register interactions with our communications, such as emails; enforce our terms; and debt collection.
  • To engage our third party service providers who may process your information on our behalf to facilitate the provision of Loóna Services and the fulfillment of essential service functions, such as web hosting, cloud storage, analytics, payments, plugins, communications, accounting, security and others. It is our legitimate interest in delivering our Loóna Services properly, efficiently and understanding our users’ needs and to make analytics of our audience as it helps us understand our product and business metrics.
  • To monitor our networks, Loóna Services and systems for suspicious activities, test and audit our systems and deploy appropriate security measures.
  • To monitor operations, user activity and networks for fraud prevention, including information from third parties who may alert us about suspicious activities. 
  • To share information with our group companies.
  • To share data with another organization for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization or similar event relating to our business.
  • To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.
  • To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.
  • 5. NO PROCESSING OF PAYMENT DETAILS

We will not receive or store any of your payment details, this is fully handled by the relevant payment service provider. If/when you make any purchases, we are notified by the payment processor once the transaction takes place and then ensure you receive your purchase. We do not, however, receive any of your actual payment details or personal data related to the payment. We only keep the data concerning transaction dates, currencies, value, the last four digits of your card number and the subject of the transaction.

  • 6. COOKIES, SOFTWARE DEVELOPMENT KITS, AND OTHER TRACKING TECHNOLOGIES

While using Loóna Services, we and our service providers, vendors, and partners, including third parties, may use cookies (a small text files stored on your computer or mobile device to identify your computer and web browser) and other similar technologies to collect or receive specific information regarding you and/or your interaction with Loóna Services. 

Additionally, we employ third-party analytics tools such as Google Firebase, RevenueCat, AppsFlyer, and Amplitude to assist us in measuring traffic and usage trends for Loóna, among other purposes. These analytics tools collect data through third-party SDKs integrated into Loóna, encompassing details about the features you explore or use within Loóna, your interactions within the Loóna, and information concerning your subscription. This information might be used to deliver content, advertising, or features, as well as to evaluate and analyze the effectiveness of advertisements on Loóna or other websites or platforms. Third parties may also leverage this data for their own purposes. 

Interest-based Advertising. We might collaborate with ad networks and other providers of ad-serving services to deliver advertisements on non-affiliated platforms. Some of these advertisements may be personalized, which means that they may try to be relevant to you using data collected by ad networks and ad-serving providers regarding your app usage patterns over time, including details about connections between various browsers and devices. This form of advertising is commonly referred to as interest-based advertising.

Your Choices. Most browsers and devices are set to accept cookies and similar tracking technologies by default. However, you may have the option to set your browser and device settings to limit these technologies. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visitwww.allaboutcookies.org .

For users in the European Economic Area, United Kingdom and United States. You can opt-out from processing of Personal Data via cookies, SDKs and other tracking technologies by sending a request to

Additionally, you have the option to prevent our Loóna Services from placing cookies by using a global privacy control signal or by using a browser equipped with privacy features or installing browser plugins and configuring them to block cookies or trackers.

Please note that these opt-out mechanisms apply only to the specific device or browser on which they are activated, necessitating opting out on each browser and device individually.

It's important to acknowledge that certain features of the app may not operate as intended if you choose to reject cookies or similar tracking technologies. Additionally, disabling cookies or similar tracking technologies could limit your access to certain content within our app. Remember that your preferences are typically tied to specific devices and browsers.

  • 7. HOW WE MAY DISCLOSE YOUR INFORMATION TO THIRD PARTIES

We do not rent or sell your Personal Data to any third parties outside the Loóna or its affiliates (as defined below).

We do not share your personal information except as approved by you or as described below:

  • We may engage other companies and individuals to perform services on our behalf. An example of these services may include analyzing data and providing customer support. These agents and service providers may have access to your personal information in connection with the performance of services for us, and they are bound by appropriate contractual safeguards in place.
  • We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Loóna may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements.
  • We may share your Personal Data if our company or any of our affiliates, subsidiaries or business units is involved in a business change such as a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, or liquidation. In these situations, your Personal Data and other collected data may be among the assets transferred or disclosed as part of the business transaction or proceeding.
  • Loóna may contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies, APIs, and SDKs in Loóna to enable them to collect and analyze user and device related data and information on our behalf. We collect and use this analytics information in an aggregated manner with analytics information so that it cannot reasonably be used to identify any particular user. The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.
  • Apple iOS users may opt-in to allow Loóna Services to provide data regarding the amount of minutes spent within Loóna applications to the Apple iOS “Health” application for display. This data will not be shared with third parties or used for marketing purposes.
  • We may share aggregate or anonymized information about you with advertisers, publishers, business partners, sponsors, and other third parties.
  • 8. CONTROLS FOR DO-NOT-TRACK FEATURES

Many web browsers, as well as certain mobile operating systems and applications, offer a feature called Do-Not-Track ("DNT") that allows you to indicate your preference for privacy by requesting that your online browsing activities not be monitored or collected. However, it's important to note that there is currently no universally accepted technology standard for recognizing and implementing DNT signals. Therefore, we do not currently act upon DNT browser signals or any other automatic mechanism that indicates your preference not to be tracked online. If a standard for online tracking is established in the future that requires our compliance, we will update this privacy notice accordingly to inform you of any changes in our practices. We do recognize the global privacy control signal if you rbrowser or device is using such a signal. Please see Section 6 (Your Choices) above for more information.

  • 9. LINKS TO OTHER SITES

For the convenience of our visitors and clients, Loóna Services may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.

  • 10. HOW LONG IS YOUR INFORMATION KEPT?

We retain your Personal Data for as long as your account is active or as needed for the purposes of processing. At any time, you can delete your account, as well as the Personal Data associated with it by sending a request to privacy@loona.app or proceed with App Settings.

Please note that we still may retain certain data about you if so needed due to applicable legislation requirements, any potential or ongoing dispute resolution, or in order to enforce our rights. Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. 

Please, note that deletion of App does not imply the deletion of your account and your data.

  • 11. HOW DO WE SECURE YOUR INFORMATION?

We maintain appropriate organizational and technological safeguards to help protect against unauthorized use, access to or accidental loss, alteration or destruction of the personal information we hold. We also seek to ensure our third-party service providers do the same.

We will endeavour to use the least amount of personal information as is required for each purpose. 

Our staff will access your personal information on a “need-to-know” basis.

Unfortunately, the transmission of personal data through the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to or stored on our IT system, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access.

  • 12. WHERE IS YOUR INFORMATION PROCESSED?

We may transfer your personal information to our group companies, suppliers and other third parties in countries different to your country of residence.

In addition, data may be transferred to our subsidiaries or processors in third countries or subcontractors of our processors in third countries.

We and certain of our service providers are incorporated in the United States. Accordingly, your Personal Data may be transferred to and stored in the United States.

Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.

  • 13. OUR POLICY REGARDING CHILDREN

General age limitation. Loóna is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to use Loóna. If you are under 13, do not: (i) use or provide any information in Loóna or through any of its features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. If you are a parent or guardian and believe we have collected information from your child who is under the age of 13, please contact us at privacy@loona.app.

Age limitation for EEA/UK individuals. You must be at least 16 years old in order to use Loóna Services. We do not allow use of Loóna by EEA individuals younger than 16 years old. If you are aware of anyone younger than 16 using Loóna, please contact us by e-mail: privacy@loona.app, and we will take the required steps to delete the information provided by such persons.

  • 14. ELECTRONIC COMMUNICATIONS

By using Lóona, you also agree to receive electronic communications from us, including via email, push notifications and by posting notices on Lóona. The communications between you and us may take place via electronic means, whether you use Lóona or send us emails, or whether we post notices on Loóna or communicate with you via email. These communications may include notices about Lóona and the Purchased Content and are part of your relationship with us. For contractual purposes, you: (i) consent to receive communications from us in an electronic form; and (ii) agree that all terms and conditions, agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if it were to be in writing. The foregoing does not affect your statutory rights. Communications from us and our affiliated companies may include but are not limited to: operational communications concerning your Account or the use of Loóna (e.g., technical and security notices, updates to this Privacy Policy and Loóna Terms of Use), and updates concerning new and existing features (e.g., changes/updates to features of Lóona and their scope, prices of in-app subscriptions).

You may opt-out of receiving promotional emails from us at any time through any of the following methods:

  • by following the opt-out links in any promotional email sent to you; or
  • through Loóna settings on your mobile device; or
  • by contacting us at any time at privacy@loona.app 

You may opt-out of push notifications by changing the settings on your mobile device.

  • 15. CONTACT US

Please email us if you have any queries or concerns about how we use your personal information. We will try to resolve your query without undue delay.

E-mail: privacy@loona.app

Appointed EEA/UK representative. Loona has appointed BrattePL Sp. z o.o. as its data privacy representative in the EEA and UK to act as its direct contact for data subjects and EEA/ UK supervisory authorities. If you usually reside in an EEA/ UK you can contact BrattePL Sp. z o.o. regarding matters pertaining to the GDPR by: 

E-mail: privacy@loona.app

Postal address: 8/12 Młynarska St., 01-194 Warsaw, Poland

  • 16. UPDATES

This Privacy Policy may change from time to time, and we encourage you to review it periodically. The date this Privacy Policy was last revised is indicated at the top of the page. We may modify or update this Privacy Policy from time to time. Some changes do not require your consent. However, if we determine that the changes may pose risk to your rights and freedoms, we will ask for your consent to those changes separately from this Privacy Policy.

  • 17. YOUR EEA & UK DATA PRIVACY RIGHTS

This section provides further disclosures and describes the rights in relation to your personal data that you may have under GDPR if you are an individual in the EEA or UK GDPR if you are an individual in the UK.

  1. Personal data
    “Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.
  2. How do we process your information and why?
    We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above. We will update you about any new purposes of processing your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so by law.
  3. Data subject rights
    Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:
  1. Right to information about matters set out in this policy. You may also contact us for further details about our retention policy and international data transfers.
  2. Right to make an access request to receive copies of personal data, as well as to share your personal data with other parties.
  3. Right to rectification of any inaccurate or incomplete personal data.
  4. Right to withdraw consent previously provided, without affecting the lawfulness of our processing based on consent before its withdrawal.
  5. Right to object to our processing of personal data for direct marketing purposes, or that is based on our legitimate interests, and any automated decision-making and profiling.
  6. Right to erasure of personal data, in certain circumstances. Please note that the erasure of some of your personal data may affect your ability to use Loona Services.
  7. Restriction on the processing of personal data in certain circumstances.
  8. Right to data portability from one service provider to another, where applicable. In this case, we will provide you with a copy of your personal data in a machine-readable format in accordance with industry standards so that you can pass this information to another data controller.
  9. Right to lodge a complaint with your country’s supervisory authority. Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period, we will explain why and extend the period by up to two months where necessary, taking into account the complexity and number of requests. You can exercise these rights directly with us by submitting a request at privacy@loona.app. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

  1. 18. YOUR CALIFORNIA PRIVACY RIGHTS

​​California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@loona.app.

  • 19. YOUR NEVADA DATA PRIVACY RIGHTS

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@loona.app. However, please know we do not currently sell data triggering that statute’s opt-out requirements.