Last Updated: Jun 16, 2025
This Privacy Policy (“Policy”) describes how Totalus and its affiliates (“Totalus,” “we,” “our,” or “us”) collect, use, and share information from and about you.
This Policy applies to the Luni mobile application, our websites, and any other digital products and services we provide that link to this Policy (collectively, the “Services”).
By using our Services, you agree to the collection, use, and sharing of your information as described in this Policy. If you do not agree, please do not use the Services.
Capitalized terms that are not defined in this Policy have the meaning given to them in our Terms of Service.
When you use our Services, we collect information from and about you. The types of information we collect depend on how you use our Services. Please note that we need certain types of information to provide the Services to you. If you don’t provide us with such information, or if you ask us to delete it, you may no longer be able to use our Services.
We collect information that you provide directly to us. For example, you may provide information when you register for an account, use the Services, or communicate with us. This information may include:
We and our third-party partners (like analytics providers) may use cookies, web beacons, and other tracking technologies to automatically collect information about the devices you use to access our Services. This information may include:
We use this information for analytics, to improve and personalize the Services, and to evaluate the success of our marketing campaigns. For more information about cookies and how to disable them, you can visit https://www.allaboutcookies.org.
We may receive information about you from third parties, such as when you connect your Luni account to a third-party service.
We use the information we collect for various purposes, including:
Aggregated and De-Identified Information. We may aggregate or de-identify your information so that it can no longer be used to identify you. We may use this de-identified data for any purpose, including for research and marketing, and may also share such data with third parties.
We do not sell your personal information. However, we may share your information in the following circumstances:
Important Note on Your Conversations: Your one-on-one conversations with Luni are private. We will not share the content of your conversations with other users or third parties for their own marketing purposes.
We use third-party analytics services to better understand how you use our Services and to help us improve them. We currently use Google Analytics and Mixpanel.
These services use cookies and similar technologies to collect and analyze information about your use of the Services. This information is collected directly by these service providers to evaluate your use of the Services.
We provide you with choices regarding the information we collect and use.
Depending on your location and subject to applicable law, you may have the right to:
Please note that we may need to retain certain information for legal compliance, to secure our Services, or to complete transactions. If you ask us to delete information necessary to provide the Services, you may no longer be able to use the Services.
If you would like to exercise any of your rights, please contact us at: [email protected].
To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request. Depending on applicable law, you may have the right to appeal our decision to deny your request.
Additional information for residents of certain regions, such as the European Economic Area, United Kingdom, and California, may be set forth in a separate section below.
Totalus is the "data controller" responsible for the processing of your personal data under this Policy. The legal grounds we rely on for processing your data are:
You have the right to lodge a complaint with your local supervisory authority, but we encourage you to contact us first so we can try to resolve your concern.
We do not "sell" your personal information as defined by Nevada law. However, if you are a Nevada resident, you may submit a request to opt-out of any future sales by contacting us at [email protected] with the subject line "Nevada Do Not Sell Request".
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (CCPA).
Categories of Personal Information Collected: In the past 12 months, we have collected the following categories of personal information as defined by the CCPA: identifiers (like username and IP address), commercial information, internet or other electronic network activity information, general geolocation data, and inferences drawn from this information.
Categories of Sensitive Personal Information Collected: We may also collect sensitive personal information, which includes your account log-in credentials. You may also voluntarily provide other sensitive information through your conversations with the AI (for example, by revealing your race, religion, or sexual orientation).
We collect this information from you directly, through your use of the Services, and from third parties like social media platforms if you connect your account. We use this information for the purposes described in Section 2, "How We Use Your Information."
"Sale" and "Sharing" of Personal Information: We do not "sell" your personal information in the traditional sense. However, our use of third-party analytics services like Google Analytics may constitute "sharing" under the CCPA. To opt out of this "sharing," please use the tools described in Section 4, "Online Analytics." We do not knowingly "share" the personal information of minors under 16.
Do Not Track: We do not currently respond to "Do Not Track" signals, as the industry is still working on a standardized solution.
Your California Privacy Rights: In addition to the rights described in Section 5, "Your Choices and Rights," the CCPA provides California residents with the right to limit the use and disclosure of sensitive personal information. Please note that we do not use or disclose your sensitive personal information for purposes that would trigger this right under the CCPA.
Our Services are not designed for or directed to children under the age of 13 (or 16 for residents of the EEA/UK). We do not knowingly collect personal information from children under this age. If we learn that we have collected personal information from a child in violation of applicable law, we will delete it.
We implement reasonable technical, administrative, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access or disclosure. However, no internet or email transmission is ever fully secure or error-free. We cannot guarantee the security of your information.
We keep your information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services and to comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period depends on the purposes for which we collected and use the information and your choices. After this period, we may delete or de-identify your information.
Our services are global. Your information may be stored and processed in the Republic of Korea, the United States, and other countries that may have data protection laws that differ from the laws in your country. By using our Services, you consent to the collection, processing, and transfer of your information in and to the Republic of Korea, the United States, and other applicable countries.
The Services may contain links to third-party websites or services. We are not responsible for the content or privacy practices of those websites or services. This Policy does not apply to them. We encourage you to read the privacy policies of any third-party service before providing any information to them.
We may change this Policy to reflect changes in the law, our information practices or the features of the Services. We will indicate the date of the most recent update in this Policy. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.
If you have any questions about our Privacy Policy or information practices, please submit a request to [email protected]