Privacy Policy

1. Introduction

This Privacy Policy explains how Destek Her Yerde Bilişim Anonim Şirketi ("Luno," "we," "us," or "our") collects, uses, shares, and protects personal data when you use the Luno mobile application, website, and related services (the "Service").

Luno is a wellness application, and much of the information you share with it — including how you're feeling, what you're working through, and your conversations with our AI system and with human wellness Experts — is sensitive. We built this policy around that fact, and we encourage you to read it before you share anything with the Service you wouldn't want retained.

2. Information We Collect

3. How We Use Your Information

We use the information above to:

• Generate your AI-driven wellness journeys and personalize check-ins.
• Provide Expert responses to the questions included in your plan.
• Process payments and manage your subscription.
• Maintain, secure, and improve the Service, including through aggregated, de-identified analytics.
• Communicate with you about your account, billing, and material changes to our policies.
• Meet legal obligations, including responding to lawful requests from authorities.

We do not use your wellness inputs or Expert conversations for advertising, and we do not sell this data.

4. Who We Share Information With

We do not sell your personal data. We share information only with the following categories of recipients, each bound by contractual confidentiality and data-protection obligations:

• Payment processor: a third-party payment gateway (e.g., a provider such as Stripe) that handles your billing information directly. Luno does not receive or store your full payment card number.
• AI processing provider: a third-party artificial intelligence provider that processes the information you share in order to generate your personalized journeys. We do not name this provider here because our underlying provider may change as the product evolves; regardless of which provider is in use at a given time, we require contractual commitments that your data will not be used to train that provider's general-purpose models and will be handled under confidentiality and data-protection terms at least as protective as this Policy.
• Analytics and infrastructure providers: third-party tools that help us operate the app, monitor performance, and diagnose crashes, generally on an aggregated or pseudonymized basis where feasible.
• Legal and safety disclosures: where required to comply with a legal obligation, enforce our Terms of Use, or protect the rights, property, or safety of Luno, our users, or the public.

5. International Data Transfers

Our primary servers are located in the European Union. Some of the third-party service providers described in Section 4 (such as our AI processing provider, analytics tools, or payment processor) may be located in, or transfer data to, other countries, including the United States. Where this occurs, we rely on appropriate safeguards (such as Standard Contractual Clauses, a UK Addendum, or equivalent mechanisms) to protect your data in connection with such transfers.

6. Data Retention

We retain personal data according to the following schedule:

• Active accounts: retained for as long as your account remains active and you continue to use the Service.
• Inactive accounts: if you do not log in for 24 consecutive months, we will delete your account and associated data, subject to any shorter or longer period required by local law.
• Account deletion requests: upon your request to delete your account, we will delete your personal data within 30 days.
• Backups: for technical reasons, deleted data may persist in encrypted backup systems for up to an additional 90 days before being permanently purged.

We may retain limited information beyond these periods where required to comply with legal obligations, resolve disputes, or enforce our agreements.

7. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your data (see Section 6).
• Request a portable copy of your data in a structured, commonly used format.
• Object to or restrict certain processing, including withdrawing consent where processing is based on consent.
• Lodge a complaint with your local data protection authority.

To exercise these rights, contact us at contact@getlunoapp.com. We may need to verify your identity before fulfilling a request.

8. Special Category (Health-Related) Data

Information you share about your mental and emotional wellbeing may be considered a special category of personal data under some data protection laws. Where required, we rely on your explicit consent to collect and process this information, and you may withdraw that consent at any time by ceasing use of the relevant features or deleting your account, without affecting the lawfulness of processing carried out before withdrawal.

9. Crisis and Safety-Related Information

Luno is a wellness tool and is not a substitute for professional mental health treatment or therapy. It is not designed to detect or respond to crises in real time. If you are experiencing a psychological crisis, having thoughts of self-harm or suicide, or facing a medical emergency, do not rely on the Service — contact your local emergency services or a crisis line in your country or region immediately.

We do not monitor your inputs for signs of crisis, and we will not proactively contact emergency services or third parties based on what you share. However, where required by law or in response to a valid request from a court, law enforcement, or another government authority — including circumstances involving a risk to your safety or the safety of others — we may disclose relevant information to that authority.

10. Children's Privacy

The Service is not directed to children under the age required by our Terms of Use (see Terms of Use, Section 5), and we do not knowingly collect personal data from users below that age. If we learn we have collected such data, we will delete it.

11. Data Security

We use administrative, technical, and physical safeguards designed to protect your personal data, including encryption in transit and industry-standard access controls with our service providers. No system is completely secure, and we cannot guarantee absolute security.

12. Cookies and Similar Technologies

We and our analytics providers use cookies, SDKs, or similar technologies to operate the Service and understand usage patterns. Where required, we will present a consent mechanism for non-essential tracking technologies in line with local law.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice (for example, by email or an in-app notice) before the changes take effect.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, contact us at contact@getlunoapp.com. Our data controller entity is Destek Her Yerde Bilişim Anonim Şirketi, located in Yıldız Teknik Üniversitesi Teknopark Çifte Havuzlar Mahallesi Eski Londra Asfaltı Caddesi No: 151/1C Kapı No:20 Esenler/İstanbul.