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Privacy Policy

LAST UPDATED: July 24, 2025

1. ABOUT US Our Platforms (“Platforms” means the website(s), including but not limited to https://www.lunadogai.com/ (the “Site”) and mobile applications (each an “App”, collectively “Apps”)) are owned, managed, and operated by the Company. The digital content, features, and functionality accessible within the Apps or Site (referred to as “App Content”) are integral to our Platforms.

“Company” shall mean: LunaDogAI LLC, a company incorporated in the state of Delaware with registration number 10198661and registered address at PO Box 861, Ravenel SC 29470.

You can contact us by writing to: LunaDogAI LLC, PO Box 861, Ravenel SC 29470, or via woof@lunadogai.com.

At LunaDogAI LLC, we are dedicated to leveraging technology to enhance users’ physical and emotional well-being, foster enjoyment, and boost productivity and convenience in mobile device usage. We believe in the remarkable potential of technology to drive positive change and are committed to the highest standards of privacy and security. As trusted keepers of your personal data, we prioritize transparency and accountability in our data practices, ensuring that you have full knowledge of your data while benefiting from our Platforms.

When you use our Platforms, we collect, store, and process certain information, including personal data. This Privacy Policy sets out the main principles on which the data collected from you, or that you provide to us, will be processed by us. This Privacy Policy also aims to inform you about your rights and to provide you with all the elements you need to exercise them. For the purposes of data protection legislation (e.g., GDPR, UK GDPR, CCPA/CPRA, VCDPA, etc.), we act as the Controller of your personal data, meaning we determine the purposes and means of processing that data.

We encourage you to review this Privacy Policy in its entirety to gain insight into our data handling practices. We have meticulously crafted this policy to be clear and accessible, but if you have any questions or concerns, please don’t hesitate to contact us at woof@lunadogai.com or the address listed above for further information.

IF YOU DO NOT ACCEPT THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR PLATFORMS.

2. YOUR DATA COLLECTED BY US As you engage with our Platforms, we gather data concerning a recognized or identifiable living individual (“personal data”) through the following means:

A. Data Directly Provided by You: This encompasses any information you manually input or furnish to us while utilizing our Platforms. The categories of personal data you may provide include:

  • Identifiers: Such as your name, email address, phone number, username, password.
  • Demographic Data: Such as your age, gender (if voluntarily provided).
  • Dog-Related Data: Such as your dog’s name, breed, age, weight, and behavioral profile information (e.g., reactivity, anxiety, aggression, specific training goals).
  • User-Generated Content: Such as photos, videos, audio recordings, text, comments, suggestions, reviews, and training logs you upload or submit through the Platform.
  • Payment Information: If you make purchases directly through our Site, we may receive limited payment information (e.g., billing address, last four digits of your payment method, transaction ID, card type) from our third-party payment processors to manage your subscription and for accounting purposes.

B. Data Automatically Collected by Us: When you access our Platforms, we automatically procure certain details regarding your engagement and activities within the Platforms. The categories of personal data automatically collected include:

  • Device Information: Such as your device model, operating system, unique device identifiers, IP address, mobile network information.
  • Usage Data: Such as features accessed, pages viewed, time spent on the Platform, specific interactions within the App, referring URLs, performance data, crash logs, and general activity within the Platforms.
  • Location Data: General location inferred from your IP address or more precise location data if you enable location services on your device and consent to its collection.

C. Data Acquired via Cookies and Similar Technologies: To understand your interactions with our Platforms better, we utilize cookies and similar technologies (e.g., web beacons, pixels, local storage). Cookies enable us to retain particular details about you, such as your preferences or previous interactions, thereby enhancing your experience on our Platforms and delivering tailored content. You can find more information in our dedicated Cookie Policy.

3. WHY WE PROCESS YOUR DATA (PURPOSES) Data processing is crucial to enable your usage of our Platforms. Whenever you use our Platforms, some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.

We process your data for the following primary purposes:

  • To Provide and Operate the Service: To deliver the core functionalities of the Apps and Site, including creating and managing your account, providing access to App Content, and allowing you to utilize features like video upload and AI analysis.
  • To Manage Your Account and Subscriptions: To process your purchases, manage subscription renewals, send transactional communications (e.g., confirmations, invoices, reminders), and handle account-related queries.
  • To Personalize Your Experience: To tailor the App Content, training plans, and features to your specific needs, your dog’s profile, and your training progress.
  • To Enhance and Improve Our Platforms: To analyze how you interact with the Platforms, refine prediction accuracy, develop new algorithms, improve features, fix bugs, and optimize overall performance and user experience.
  • For Customer Support: To communicate with you and respond to your inquiries, feedback, or concerns regarding our Platforms.
  • For Marketing and Advertising: To optimize our advertising strategies, analyze the performance of our advertising campaigns, identify your engagement and subscription status, gauge interaction with our advertisements, and send you promotional offers if you have provided consent (where required).
  • For Security and Fraud Prevention: To protect our Platforms, users, and data from unauthorized access, fraud, or other malicious activities.
  • To Comply with Legal Obligations: To adhere to applicable laws, regulations, legal processes, and governmental requests.

4. HOW YOUR DATA IS HANDLED (LEGAL BASES FOR PROCESSING) Depending on which features of the Platforms you use and your location, we will process your personal data based on one or more of the following legal bases:

  • Contractual Necessity (Contract): We process your personal data where it is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract. This applies to processing related to providing you access to our Platforms, managing your account, processing transactions, and delivering subscription services.
    • Example: Processing your payment information to fulfill your subscription purchase.
  • Legitimate Interests: We process your personal data where it is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your data protection interests or fundamental rights and freedoms. This applies to processing related to improving our Platforms’ features and technical aspects, enhancing user experience, and for security and fraud prevention.
    • Example: Analyzing usage data to identify popular features and areas for improvement, or processing your contact information to respond to your support requests.
  • Legal Obligation: We process your personal data where it is necessary to comply with a legal or regulatory obligation that applies to us.
    • Example: Retaining certain transaction records for tax compliance, or responding to valid governmental requests.
  • Consent: We process your personal data where you have given your explicit consent for specific purposes. This is particularly relevant for the processing of special categories of personal data (e.g., health data related to your dog, if considered sensitive data under applicable law) and for certain marketing activities, where required by law.
    • Example: Collecting precise location data if you enable it and consent, or sending you marketing communications if you have opted in.

5. DATA RETENTION We retain your personal data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing, including for resolving disputes, for safety and security reasons, for internal analysis, and for complying with our legal, tax, accounting, and regulatory obligations. The specific retention period will vary depending on the type of data and the purpose of processing.

6. SHARING OF YOUR PERSONAL DATA We may need to share your personal data with certain third parties as follows:

  • Third-party service providers: This may include providers of certain systems and services that we use to host, administer, and maintain our Platforms, including server hosts, cloud service providers, email service providers, payment processors, fraud prevention vendors, analytics providers, customer service platforms, and other service providers. These third parties are authorized to use your personal data only as necessary to provide these services to us.
  • Third-party advertising and marketing partners: We may share certain personal data with advertising and marketing partners to help us carry out and measure the effectiveness of our marketing campaigns, deliver relevant advertisements to you, and analyze user engagement. This may constitute “selling” or “sharing” of personal data under certain US state privacy laws (e.g., CCPA/CPRA), even if no monetary exchange occurs for the data itself.
  • Compliance with Laws: We may disclose your personal data to a third party if:
    • we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; or
    • to protect the security or integrity of the Platforms; or
    • to protect us, our customers, or the public from harm or illegal activities; or
    • to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
  • Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.
  • Group companies: Your personal data may be shared among our affiliates and subsidiaries for internal business purposes consistent with this Privacy Policy. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
  • Corporate Transactions: We may also disclose personal data as part of a corporate transaction, such as a merger, acquisition, or sale of assets, provided the acquiring entity commits to protecting your personal data consistent with this Privacy Policy.

The following are a few of the essential processors/partners we trust:

7. DATA STORAGE AND CROSS-BORDER TRANSFERS The personal data we maintain will primarily be stored and processed within the United States. We implement robust measures to keep this personal data secure. All information we hold is stored on our secure servers (which we own or license from appropriate third parties), utilizing industry-standard procedures and security standards to prevent unauthorized access.

If you reside in the European Economic Area (EEA) or the United Kingdom, we may transfer your personal data to countries outside the EEA and UK, including the United States, which may not provide the same level of data protection. When such a transfer occurs, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • Where we use certain service providers, we may use specific contracts approved for use in the EEA/UK which give personal data the same protection it has in the EEA/UK (e.g., Standard Contractual Clauses).
  • Where transfers are made to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK authorities.

By continuing to use our Platforms, you understand and acknowledge that your personal data may be transferred to, stored, and processed in the United States and other countries where our service providers are located, and you consent to such transfers where consent is required by applicable law.

8. SECURITY Ensuring the security of your data is a top priority for us. We employ robust technical and organizational measures to safeguard the personal information entrusted to us.

Your personal data is safeguarded by the password you create when registering on our Platforms. It’s essential to choose a strong password and keep it confidential to prevent unauthorized access. Additionally, refrain from sharing your password and ensure the security of your computer or mobile device.

We have instituted reasonable administrative, technical, and physical security measures to protect your personal data from unauthorized access, alteration, or destruction. For instance:

  • We utilize SSL encryption (HTTPS) for all interactions involving personal data.
  • Our databases are encrypted, and we store data on physically secure servers protected by firewalls.

In the event of a personal data breach as defined in applicable data protection laws (e.g., GDPR Article 4.12), we will promptly notify affected individuals and/or relevant supervisory authorities in accordance with our legal obligations. This notification will include relevant details, measures taken, and an assessment of associated risks. We are committed to addressing breaches promptly and transparently, taking necessary actions such as logging affected users out, initiating password resets, and other appropriate measures to mitigate the breach. To report a personal data breach or seek assistance, please contact us via woof@lunadogai.com. We will address your concerns accordingly.

9. YOUR PRIVACY RIGHTS We aim to ensure that you are fully informed about all your data protection rights and the methods available to exercise them. Please note that these rights may vary depending on your location and applicable laws:

  • Access: You can request to receive a copy of the personal data we hold about you.
  • Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement it. You can also correct some of this information directly from your account settings. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
  • Objection: You can contact us to inform us that you object to the collection or use of your personal data for certain purposes.
  • Erasure: You can request that we erase some or all of your personal data from our systems.
  • Restriction of Processing: You can ask us to restrict or limit further processing of your personal data.
  • Portability: You have the right to ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the personal data to another entity where technically feasible.
  • Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of such data collection), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have then to provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all Platforms.
  • Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your personal data with the relevant supervisory authority in your country or state of residence.

To exercise your rights, please contact us via woof@lunadogai.com or write to us at the address set forth in the “Contact” section. If you submit a request, we typically aim to fulfill it within one month. If additional time is needed to assist you in exercising your rights (e.g., for complex requests or during high volume periods), we will inform you accordingly within the initial response period, extending the response time by up to two additional months. We reserve the right to reject manifestly unfounded or excessive requests.

During the process of exercising your data protection rights, we may ask you to confirm your identity. This verification step ensures that you are entitled to access certain information and that the rights of third parties are not infringed upon. If we are unable to verify your request, we will be unable to fulfill it.

10. OUR POLICIES CONCERNING CHILDREN If you are in the EU/UK, you must meet the age requirement specified by the laws of your country (e.g., at least 16 years old in Germany, 13 years old in the UK) to provide explicit consent for the processing of your data for services. Alternatively, if you are under the required age, you can still use our services with the consent of your parent or legal guardian. In the event that we learn that we have inadvertently gathered personal data from children under the applicable age, we will take reasonable measures to promptly erase such information from our records and terminate the associated account.

If you are a parent or legal guardian and learn that your child is using our Platforms without your permission, or if you have a specific question about data privacy, please contact us via woof@lunadogai.com.

If you are in the United States, you must be at least 13 years old to use the Platforms. If we become aware that information has been collected from children under the age of 13 in the United States in violation of the Children’s Online Privacy Protection Act of 1998 (COPPA) and its regulations, we will promptly delete the account and erase all associated personal data from our servers.

11. HOW CAN YOU MANAGE YOUR DATA? If you wish to access, correct, or update your personal data, you can do so at any time by contacting us via woof@lunadogai.com.

If you would like us to delete your information, you may: (1) contact us at woof@lunadogai.com and describe your request, and/or (2) open “Profile” in the App, select “Profile Details”, press “Delete account” button, fill subscription field, and press “Submit” button. If you proceed with the deletion of your account, you will no longer have access to the account or subscriptions associated with your account. Other steps you should take should you wish to delete your account include disassociating your Meta account from our applications, if applicable, and deleting the application(s) from your device. Please note that if you ask us to delete your account, all your progress in the application and any unused virtual items will be lost, and we may not be able to restore them in the future.

12. CHANGES TO THIS PRIVACY POLICY We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of our Platforms, or advances in technology. Please check this page periodically for changes and refer to the “last updated” date at the top of the page to know if it has been revised since your last visit. If we make any changes to this Privacy Policy that we consider to be material to your consent, we will notify you of them.

13. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS This section supplements the information provided elsewhere in this Privacy Policy and applies solely to residents of California. This section is intended to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable California privacy laws.

A. Categories of Personal Data Collected: In the preceding 12 months, we have collected the following categories of personal data: Identifiers (e.g., name, email address, unique online identifiers); Dog-Related Data (e.g., dog’s name, breed, age, behavioral profile, training logs, videos); Internet or other electronic network activity information (e.g., Browse history, interaction with our Platform or advertisements); Inferences drawn from other personal information (e.g., profiles reflecting preferences, characteristics).

B. Categories of Sources: We collect these categories of personal data directly from you (e.g., when you create an account, provide dog information, upload content) and automatically from your devices (e.g., through cookies, usage analytics).

C. Purposes of Processing: We collect and process these categories of personal data for the business and commercial purposes described in Section 3 (“Why We Process Your Data (Purposes)”) above, including to provide and operate the Service, manage accounts, enhance features, personalize experience, for customer support, marketing and advertising, and for security and fraud prevention.

D. Disclosure of Personal Data for Business Purposes: In the preceding 12 months, we may have disclosed the categories of personal data listed in Section 2 with our service providers for business purposes, such as hosting, analytics, customer support, and payment processing.

E. “Sale” or “Sharing” of Personal Data: We do not “sell” your personal information for monetary consideration. However, like many online companies, we engage in activities that may constitute “sharing” of personal information for cross-context behavioral advertising (i.e., targeted advertising) under the CPRA, even if no money is exchanged for the data itself. In the preceding 12 months, we may have “shared” categories of Identifiers and Internet or other electronic network activity information with third-party advertising and analytics partners for purposes of cross-context behavioral advertising.

F. Right to Opt-Out of “Sale” or “Sharing”: California residents have the right to opt-out of the “sale” or “sharing” of their personal information for cross-context behavioral advertising. You can exercise this right by

  • Adjusting your preferences via the “Your Privacy Choices” link on our Platforms (where available, such as through a cookie consent management tool).
  • Adjusting your browser settings to send a Global Privacy Control (GPC) signal.
  • Contacting us directly at woof@lunadogai.com with the subject line “California Privacy Opt-Out Request.”

G. Limitation on Handling Sensitive Personal Information: We only collect and process sensitive personal information when absolutely necessary to provide you with products or access to use Platforms (e.g., dog health data for training plan personalization, if you provide it). We do not “sell” or “share” sensitive personal information.

H. Your California Privacy Rights: As a California resident, you have the right to:

  • Know: Request access to (i) the specific pieces of personal information we have collected about you; and (ii) the categories of personal information collected, the categories of sources from which it was collected, the purposes for collecting or “selling”/”sharing” it, and the categories of third parties to whom it was disclosed or “sold”/”shared” in the preceding 12 months. You can make this request twice a year at no cost.
  • Delete: Request the deletion of personal information we have collected about you, subject to certain exceptions.
  • Correct: Request the correction of inaccurate personal information we maintain about you.
  • Opt-Out of Sale/Sharing: As detailed above in Section 13.E, opt-out of the “sale” or “sharing” of your personal information.
  • Limit Use/Disclosure of Sensitive Personal Information: Request to limit the use and disclosure of your sensitive personal information to that which is necessary to perform the services or provide the goods. (Note: We only process sensitive personal information when necessary for providing the Service.)
  • Non-Discrimination: Not be discriminated against for exercising any of your CCPA/CPRA rights.

I. “Shine the Light” Law: California residents also have the right to request, once a year, disclosure regarding any personal information shared with third parties for their separate direct marketing purposes. To make such a request, please contact us via woof@lunadogai.com with the subject line “California Privacy Rights Request,” and include relevant details such as your name, street address, city, state, and ZIP code.

J. Authorized Agent: You may designate an authorized agent to make requests on your behalf. We will require verification of your identity and the agent’s authorization.

14. PRIVACY NOTICE FOR VIRGINIA, CONNECTICUT, COLORADO, UTAH, AND NEVADA RESIDENTS This section supplements the information provided elsewhere in this Privacy Policy and is intended to comply with privacy laws in Virginia (VCDPA), Connecticut (CTDPA), Utah (UCPA), Colorado (CPA), and Nevada (NPL).

A. Collection and Use of Personal Information: We may collect and use personal information as described in Section 2 (“Your Data Collected by Us”) and for the purposes described in Section 3 (“Why We Process Your Data (Purposes)”) of this Privacy Policy. Please note that some of this personal information may be considered sensitive under your state’s legal definition (e.g., mental or physical health information related to your dog, if you provide it for training personalization). We only process sensitive personal information when absolutely necessary to provide you with products or access to use Platforms.

B. Disclosure of Personal Information: We may disclose your personal information to the categories of service providers and third parties identified in Section 6 (“Sharing of Your Personal Data”) of this Privacy Policy.

C. Targeted Advertising and Sale of Personal Data:

  • Targeted Advertising: We process personal data for targeted advertising (i.e., cross-context behavioral advertising based on your activity across unaffiliated websites/apps).
  • Sale of Personal Data: We do not “sell” personal data in exchange for monetary consideration. However, some sharing for targeted advertising may be considered a “sale” under certain state laws (e.g., Virginia’s VCDPA).
  • Right to Opt-Out: Residents of Virginia, Connecticut, Colorado, and Utah have the right to opt-out of the processing of personal data for targeted advertising and the sale of personal data. You can exercise this right by:
    • Adjusting your preferences via the “Your Privacy Choices” link on our Platforms (where available, such as through a cookie consent management tool).
    • Adjusting your browser settings to send a Global Privacy Control (GPC) signal.
    • Contacting us directly at woof@lunadogai.com with the subject line “[Your State] Privacy Opt-Out Request.”
  • Nevada Residents: Nevada provides its residents a limited right to opt out of the sale of personal information, primarily defined as the exchange of covered information for monetary consideration. We do not engage in the sale of personal information as defined by Nevada law.

D. Profiling: For users in Colorado, Connecticut, and Virginia, you may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. While you may still make this request, we do not currently use profiling in this manner.

E. Your Privacy Rights (General): We generally provide the privacy rights described in Section 9 (“Your Privacy Rights”) above, regardless of your location. Your specific state may afford you additional privacy rights as noted in this section. We will respond to your verifiable request within the time limit afforded under applicable law.

15. CONTACT US If you have any questions about this Privacy Policy or our data practices, please contact LunaDogAI LLC at woof@lunadogai.com.

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