Privacy Policy of Lunu Solutions GmbH
The Lunu Solutions GmbH, Kronberger Straße 12, 14193 Berlin (thereinafter „we“, „us“ or „Lunu“) offers
businesses that offer goods and/or services (“Retailers”) a technical solution which enables Retailers
to accept cryptocurrencies as payment from their customers and be paid in stable coins that can be
converted to EUR and paid out to the Retailer’s bank account. In addition, Lunu sells POS
Terminals and/or provides an online widget to Retailers that enable the Retailer to accept
cryptocurrencies at the point of sale and as online payments (together referred to as “Lunu Services”).
With the following information, we would like to inform you about how we implement the provisions of
the EU General Data Protection Regulation (hereinafter "GDPR") and protect your personal data, when
visiting the Lunu Website on https://lunu.io/ (“Lunu Website”)
and when using the Lunu Services, as a Retailer or an Arbitrageur.
Please note that the use of the Lunu Services may involve number of service providers who are themselves controllers and therefore responsible for the processing of your personal data within the meaning of the GDPR. These service providers have their own privacy policy. These data protection notices reflect only the data processing when visiting the Lunu Website and when using the Lunu Services for which we are the controller within the meaning of the GDPR.
Section 1
Name and Contact Details of the Controller and the Company Data Protection Officer
Lunu Solutions GmbH
Kronberger Straße 12
14193 Berlin
Germany
Telephone: +49 (0) [Please add]
E-Mail: abuse@lunu.io
Contact details of the data protection officer
Data protection officer of the Lunu Solutions GmbH
[Please add name and contact details]
E-Mail: [Please add]
Section 3
Data Processing for Providing Lunu Website as visitor without registration
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Scope of processing of personal data
Each time you access any content on our Lunu Website, our system automatically
collects data and information from the computer system from which you are accessing
the content. The following data is collected (hereinafter "Log Data"):
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Information about the browser type and version used (so-called "User Agent");
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the operating system of your computer system;
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the IP address of your computer system;
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the amount of data sent in bytes;
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date, time, and duration of access;
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language setting;
Except for the IP address, the log data listed above cannot be
used to identify you personally. A personal identification can only
be established by assigning or linking the Log Data to data on the
user of an IP address, which is generally not available to us.
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Purpose of the processing
The collection and processing of Log Data on the Lunu Website,
in particular the IP address, is for the purpose of providing the
content of the Lunu Website. This requires a temporary storage of
the IP address. This is necessary to address the data traffic
between your computer system and the Lunu Website.
A further processing and storage of the IP address in log files
takes place for the purpose of ensuring the functionality of our
Lunu Website and to ensure the security of our information technology systems.
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Legal Basis
The legal basis for the collection and processing of Log Data,
insofar as these are personal data, is Art. 6 para. 1 sentence 1
lit. b GDPR (performance of a contract and initiation of contract).
Legal basis for a storage beyond the communication process, i.e.
for the functionality of our Lunu Website as well as to ensure the
security of our information technology systems, the log data
(if these are personal data), is Art. 6 para. 1 sentence 1 lit.f
GDPR (protection of legitimate interests).
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Deletion of data and storage period
The data will be deleted as soon as it is no longer required to
achieve the purpose for which it was collected. In the case of
the collection of data for the provision of the Lunu Website,
this is the case when the relevant session – i.e. the visit of
the Lunu Website – has ended. The storage of log data beyond this,
including the IP address for the purpose of system security,
takes place for a maximum period of [please add time period]
days after the page was accessed.
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Possibility of objection and deletion
The collection of Log Data for the provision of the Lunu Website,
including its storage in log files within the limits mentioned above,
is essential for the operation of the Lunu Website. Therefore,
there is no possibility to object.
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Disclosure to third parties
We always only disclose your personal data to third parties if:
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You have given your express consent to do so under Art.
6 Para. 1 sentence 1 lit. a GDPR.
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This is legally permissible and, according to Art.
6 Para. 1 sentence 1 lit. b GDPR, necessary for the performance
of a contract with you or in order to take steps at your
request prior to entering into a contract.
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According to Art. 6 Para. 1 sentence 1 lit. c GDPR disclosure
is necessary for compliance with a legal obligation.
We are legally obliged to transmit data to state authorities,
e.g. criminal prosecution authorities.
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The processing is necessary for the purposes of the legitimate
interests pursued by the controller or by a third party
pursuant to Art. 6 Para. 1 sentence 1 lit. f GDPR, and there
is no reason to assume that you have an overriding interest
worthy of protection in not disclosing your data.
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In accordance with Art. 28 GDPR, we use external service
providers, so-called processors, who are obliged to handle
your data with care.
The data mentioned under clause 3.1. will be passed on to the following service providers who are our processors:
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Service providers that we use to ensure the security of our information technology systems,
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our hosting provider
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and cloud provider.
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No processing outside the EU
The Log Data is processed exclusively within the European Union.
Section 4
Use of cookies in Lunu Website
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Scope of data processing
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Purpose of the processing
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Legal Basis
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Deletion of data and storage period
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Possibility of objection and deletion
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Disclosure to third parties
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No processing outside the EU
Section 5
Data Processing of Retailers personal data when registering for
the Lunu Console in accordance with the “Terms and Conditions for
the Lunu Processing Service and Terminal Sale” and using
the Lunu Services as registered user of the Lunu Console
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Scope of data processing
During the registration of the Lunu Console and use of
Lunu Services we process the following personal data:
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Company name or name of the contractual partner
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Legal form of the contractual partner
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Address of the registered office or principal place of business of the contracting party
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Registration number
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Tax identification number
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Name and e-mail address of the person for whom the account is being set up
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Mobile number
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Stablecoin account number
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Purpose of the processing
The collection and processing of the personal data stated in
section 5.1. is for the purpose of registering you for the
Lunu Console and providing the Lunu Services. Also, we will process
personal data in order to comply with legal obligations (e.g. tax laws).
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Legal Basis
The legal basis for the collection and processing of data stated
in section 5.1., insofar as these are personal data, is Art.
6 para. 1 sentence 1 lit. b GDPR (performance of a contract and
initiation of contract). The purpose of the processing also includes
pre-contractual measures to arrange and initiate the contracts.
Lunu is subject to various legal regulations, e.g. tax laws, as well
as the supervisory regulations, which are laid down by e.g. the
Data Protection Supervisory Authority in Berlin (Berliner Beauftragte
für Datenschutz und Informationsfreiheit), which interpret and
further specify the relevant legal provisions. In so far as these
legal requirements oblige us to process personal data, the purpose
of the processing is to fulfil these legal obligations
(Art. 6 para. 1 sentence 1 lit. c GDPR).
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Deletion of data and storage period
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Disclosure to third parties
We always only disclose your personal data to third parties if:
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You have given your express consent to do so under Art. 6 Para.
1 sentence 1 lit. a GDPR.
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This is legally permissible and, according to Art. 6 Para. 1
sentence 1 lit. b GDPR, necessary for the performance of a
contract with you or in order to take steps at your request
prior to entering into a contract.
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According to Art. 6 Para. 1 sentence 1 lit. c GDPR disclosure
is necessary for compliance with a legal obligation. We are
legally obliged to transmit data to state authorities,
e.g. criminal prosecution authorities.
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The processing is necessary for the purposes of the legitimate
interests pursued by the controller or by a third party pursuant
to Art. 6 Para. 1 sentence 1 lit. f GDPR, and there is no reason
to assume that you have an overriding interest worthy of
protection in not disclosing your data.
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In accordance with Art. 28 GDPR, we use external service
providers, so-called processors, who are obliged to handle your
data with care.
The data mentioned under clause 5.1. will be passed on to the
following service providers who are our processors:
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No Procession Outside the EU
The data mentioned in this section 6 will be processed exclusively
within the European Union.
Section 6
Your Rights
You have the right
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In accordance with Art. 7 Para. 3 GDPR to withdraw your once given
consent to us at any time. As a result, we may no longer continue
to process the data which was based on this consent in the future;
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To request information about your personal data processed by us in
accordance with Art. 15 GDPR. In particular, you may request
information on the purposes of processing, the categories of
personal data, the recipients or categories of recipients to
whom your data have been or will be disclosed, the planned
storage period, the existence of a right of rectification,
erasure, restriction of processing or opposition, he right
to lodge a complaint with a supervisory authority, the origin
of your data, if not collected by us, as well as the existence
of automated decision making including profiling and, if applicable,
meaningful information on the details of the data;
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In accordance with Art. 16 GDPR to immediately request the
rectification of incorrect or completion of incomplete personal
data stored by us;
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To demand the deletion of your personal data stored with us in
accordance with Art. 17 GDPR, unless the processing is necessary
to exercise the right to freedom of expression and information,
to fulfil a legal obligation, for reasons of public interest or
to assert, exercise or defend legal claims;
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Pursuant to Art. 18 GDPR, to demand the restriction of the
processing of your personal data if the accuracy of the data
is contested by you, if the processing is unlawful but you refuse
the deletion of it and we no longer require the data, but you
require it for the establishment, exercise or defence of legal
claims or you have lodged an objection to the processing pursuant
to Art. 21 GDPR;
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In accordance with Art. 20 GDPR, to receive your personal data that
you have provided us with in a structured, commonly used, and
machine-readable format or to request that it be transmitted
to another controller and
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Pursuant to Art. 77 GDPR, the right to lodge a complaint with a
supervisory authority. Without prejudice to any other administrative
or judicial remedy, every data subject shall have the right to lodge
a complaint with a supervisory authority, in particular in the
Member State of his or her habitual residence, place of work or
place of the alleged infringement if the data subject considers
that the processing of personal data relating to him or her
infringes GDPR Regulation. The authority responsible for us,
e.g. in Berlin, is mentioned in section 2.
Section 7
Right to Object
If your personal data is processed on the basis of legitimate
interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR,
you have the right, pursuant to Art. 21 GDPR, to object processing
of your personal data if there are reasons for doing so arising
from your particular situation. If you wish to exercise your right
of objection, simply send an e-mail to abuse@lunu.io<