Privacy Policy

01Who we are, and our two roles

The controller for the processing described in this policy is:

We have not appointed a Data Protection Officer; privacy questions go to the address above.

LUNR as controller. We decide why and how data is processed — and this policy governs it — for:

• this website and the people who visit or contact us through it;
• LUNR’s own lead-generation campaigns and the enquiries they produce;
• accounts, billing, and the customer relationships of people who use Adara.

LUNR as processor. When an Adara customer connects their own advertising accounts and uses Adara to retrieve leads from their lead forms, that customer is the controller of those leads and we are their processor. We act only on their documented instructions, under a Data Processing Agreement. This policy does not govern that data — the customer’s own privacy notice does.

So: if you submitted a lead form for a brand that uses Adara, that brand is your controller, not LUNR. The privacy notice you should read is the one linked from the form you submitted. Each customer’s form links to that customer’s own notice; a customer’s form must not link here. If you are unsure who to approach, section 11 explains what to do.

02Data we collect

We collect only what we need, and we never sell personal data. Depending on how you interact with us:

• Contact & correspondence — the name, email address, and message you send through the contact form on this site, or the content of an email you write to us. Form messages are delivered to our inbox by Resend; your address is used as the reply-to so that answering you is a normal email reply.
• Lead-generation form submissions — when you submit one of LUNR’s own lead forms on Meta, Google, or TikTok. Section 03 describes exactly what those forms collect.
• Cookieless site analytics — Vercel Web Analytics records anonymous, aggregate page-view data such as the page URL, referrer, approximate location, device, operating system, and browser. It does not use cookies or store an IP address or other personal identifier; its daily visitor hash is discarded after 24 hours.
• Analytics data (only with your consent) — usage data collected by Google Analytics 4 and Microsoft Clarity: pages viewed, approximate location (city level), device and browser type, and how you interact with the site. Clarity may record anonymized session replays with typed input masked.
• Authentication data (Adara) — your name, email address, and login identifiers when you create an account.
• Ad account connections & API tokens (Adara) — when you connect an advertising account (Meta Ads, Google Ads, or TikTok Ads), we receive account identifiers, OAuth access tokens, and campaign, ad set, ad, creative, performance, and reporting data from the connected account.
• Adara activity and attention records — while you are signed in, Adara records the time you last used Adara in a foreground browser tab and whether you were in the app shell, Home, or Notifications. For each Brand you can access, we also record when you last viewed its list of items needing attention and a one-way fingerprint of the list you saw. These are current-state records overwritten in place, not a history of your activity.
• Attention required email settings and delivery records — whether you enabled Attention required emails for a Brand; the verified sign-in email saved as the destination; and limited delivery metadata such as submission and delivery status, timestamps, the provider’s message identifier, a standard failure reason where available, and a one-way digest of the destination address.
• Service usage analytics — logs, diagnostics, and feature-usage data tied to your account, used to keep the service secure and improve it.

Lead data belonging to an Adara customer is handled differently and is not retained by us at all — see section 07.

03Lead-generation forms

LUNR runs lead-generation campaigns for its own business. If you submitted one of our forms, LUNR is your controller and this section applies to you.

Where the form lives. We use the in-platform lead forms offered by the advertising platforms:

• Meta Instant Forms on Facebook and Instagram;
• Google lead form assets on Google Ads;
• TikTok Instant Forms on TikTok.

You fill the form inside the platform’s app. The platform passes the submission to the advertiser, and we retrieve it into Adara through that platform’s advertising API, using an authorized connection to LUNR’s own advertising accounts.

What we collect. Only the fields shown on the particular form you submitted:

• your name;
• your email address;
• your phone number, where that form asks for one;
• company details — such as company name or your role — where that form asks for them;
• your answers to any custom questions on that form;
• submission metadata: the platform’s lead identifier, the form and the campaign or ad it belonged to, and the time of submission.

Forms differ. A given form collects only what it displays to you before you submit. We do not add fields afterwards, and we do not buy, append, or enrich your details from any other source.

The platform is processing your submission too. When you use an in-platform lead form, the platform handles your data for its own purposes as well, under its own terms and policy — TikTok, for example, states that it and the advertiser are each controllers for lead ads. What the platform does with your submission, and how long it keeps it, is governed by that platform’s policy, not by this one.

Forms run by Adara customers are not covered here. If the advertiser named on the form was someone other than LUNR, see sections 01 and 07.

04Cookies & similar technologies

We do not set any analytics cookies until you allow them. When you first visit, a consent banner lets you allow or decline Google Analytics and Microsoft Clarity — both choices are equally easy, and your decision is remembered in your browser’s local storage (a strictly functional record with no tracking value).

• If you allow analytics: Google Analytics 4 sets cookies such as _ga and _ga_* (up to 24 months), and Microsoft Clarity sets cookies such as _clck and _clsk (up to 12 months).
• If you decline: Google Analytics and Microsoft Clarity do not load, and no analytics cookies are set. Cookieless, anonymous Vercel Web Analytics remains active. The site works exactly the same.

You can change your choice at any time via Cookie Settings in the footer of every page. Withdrawing consent stops further cookie-based analytics tracking immediately.

05Why we process your data, and on what legal basis

Each purpose below is separate, and each has its own legal basis under Article 6 GDPR. Submitting a form gives us what we need to answer it. It is not blanket permission to use your details for every other purpose.

If you contacted us or submitted one of our lead forms:

• Answering your enquiry — replying to what you actually asked. Legal basis: steps taken at your request before entering a contract (Art. 6(1)(b)), or our legitimate interest (Art. 6(1)(f)) in responding to a business enquiry where you wrote on behalf of an organisation.
• Arranging a demo, where you asked for one — scheduling it and following up on it. Legal basis: Art. 6(1)(b), pre-contractual steps at your request.
• Preparing a quotation or proposal, where you asked for one — working out scope and pricing and sending it to you. Legal basis: Art. 6(1)(b).
• Ongoing promotional communications — a newsletter or recurring marketing email, which is not the same as answering you. Legal basis: your separate consent (Art. 6(1)(a)). Submitting a lead form is not that consent, and we do not add you to a marketing list because you asked us a question. See section 06.
• Keeping a record of your enquiry and of any consent you gave — so we can show what was asked and what was agreed. Legal basis: legitimate interests, and Art. 7(1) where the record evidences consent.

Everywhere else:

• Consent (Art. 6(1)(a)) — analytics cookies, and any optional marketing.
• Contract (Art. 6(1)(b)) — providing Adara and the services you sign up for, including analyzing the ad accounts you connect.
• Legitimate interests (Art. 6(1)(f)) — keeping the service secure, preventing fraud and abuse, debugging, and understanding in aggregate how the site performs; always balanced against your rights.
• Legal obligation (Art. 6(1)(c)) — where accounting or tax law requires us to keep records.

We do not sell personal data, and we do not use your data for third-party advertising.

06Marketing preferences, consent, and withdrawal

How we follow up. When you submit one of LUNR’s lead forms, we reply by email, to the address you gave, about the thing you asked about. We do not cold-call people who submit our forms, and we do not send SMS or WhatsApp marketing. Where a form asks for a phone number, we use it only if you have asked us to reach you that way.

Marketing consent is asked for separately. Where we want to send you promotional communications beyond answering your enquiry, we ask for that on its own: an optional, unchecked control on the form, worded so it is clear what you are agreeing to. It is never bundled into the submit button, never pre-ticked, and declining it never blocks your enquiry.

An advertising platform’s terms are not your consent. LUNR’s acceptance of TikTok’s LeadAds terms — or Meta’s or Google’s equivalents — is an agreement between LUNR and that platform. It says nothing about what you agreed to, and we do not treat it as marketing consent.

Withdrawing, and objecting.

• Every marketing email we send carries a working unsubscribe link.
• You can also email office@hellolunr.com at any time and ask us to stop. One line is enough; you do not have to give a reason.
• Withdrawing consent is as easy as giving it (Art. 7(3)). It takes effect promptly and does not affect processing that already happened.
• You have an absolute right to object to direct marketing (Art. 21(2)). If you object, we stop — there is no balancing test and nothing for you to justify.
• If you ask never to be contacted again, we keep the minimum record needed to honour that (see section 10).

As things stand, LUNR does not run a newsletter or send ongoing promotional email to people who submit a lead form. If that changes, we will ask for consent separately and update this policy before doing it — not after.

07How Adara handles lead exports for customers

This section describes what happens to an Adara customer’s leads. Here LUNR is a processor; the customer is the controller.

The export works like this:

1. An authorized user in the customer’s workspace requests an export of leads from a form on an advertising account that workspace is connected to.
2. Adara calls the platform’s API using that customer’s authorized connection and retrieves the matching lead records.
3. Adara holds those records only for as long as the request takes, formats them, and returns a CSV file to the user who asked for it.
4. The lead content — names, email addresses, phone numbers, answers — is not written to Adara’s database and is not kept after the response is delivered.

What we do keep is a metadata record of the export itself, for security and accountability: which user requested it, which workspace and connected account, which form, how many records, and when. That record does not contain lead content.

To be plain about it: this is temporary processing, not the absence of processing. LUNR processes personal data while an export runs, as a processor on the customer’s instructions, under a Data Processing Agreement. Security, confidentiality, sub-processor and assistance obligations all apply to it.

What Adara does not do with lead data. We do not:

• score, rank, or otherwise automatically evaluate leads;
• run lead content through AI or language models;
• enrich or append leads from other sources;
• build custom audiences, lookalike audiences, or match lists from lead data;
• use any customer’s lead data to improve Adara or to train models;
• sell it, or share it for anyone’s advertising.

Once a CSV is downloaded it is in the customer’s hands. Removing a connection in Adara does not delete a file that has already been downloaded, and does not delete the leads still held by the advertising platform. Section 10 says what that means for deletion.

08Ad account connections & API tokens

When Adara connects to an advertising account, we request the minimum scopes needed for the features that account actually uses: reading account structure, campaign, creative, performance and conversion data to produce reporting and recommendations; preparing campaign changes and new campaigns for a person to approve; and, where the workspace uses lead retrieval, reading leads from lead forms on that account.

Adara does not act on a connected account on its own. Every change affecting campaigns, delivery, targeting, budgets, bidding, ads, or spend requires explicit approval by a person, and new campaigns are created paused.

Access tokens are stored encrypted and are never shared with third parties. You can revoke access at any time from the connected platform’s own settings (for example Meta under Settings → Business Integrations, Google under Third-party apps & services, or TikTok under Authorized apps), or by asking us to delete your data — see the Data Deletion Instructions.

Attention required emails (Adara)

Adara can email you when items in one of your Brands need your attention. Attention required emails are off unless you turn them on for a Brand under Notifications → Preferences. The destination is the primary sign-in email verified for your account. You cannot enter an unrelated destination address. If your verified address changes, Adara continues using the previously saved address until you explicitly save the preference again.

To avoid emailing you about something you are already viewing, Adara keeps two limited current-state records. The first records when you last used Adara in a foreground browser tab and whether you were in the app shell, Home, or Notifications. The second records when you last viewed a Brand’s attention list and a one-way fingerprint of the list you saw.

These records are used only to avoid unnecessary operational email and interruptions. They are not used for advertising, profiling, scoring, or measuring how long you spend in the product. Each record is overwritten with the latest state rather than retained as an activity history.

For this feature, we do not record keystrokes, pointer or touch movement, individual clicks, page contents, your IP address, or device and browser details. Nothing is recorded while you are signed out or while the Adara tab is in the background.

Adara sends these operational messages through Resend, acting as our email-delivery processor. The message may contain the Brand name, a count, up to three items requiring attention, plain-language reasons, the generation time, a link back to Adara, and an unsubscribe link. Resend receives the recipient and sender addresses, subject, HTML and plain-text message, delivery headers and an opaque idempotency identifier used to prevent duplicate sends.

Resend reports whether a message was accepted, delayed, delivered, bounced, failed, reported as spam, or suppressed. Adara stores the applicable outcome, timestamps, provider message identifier, a limited reason code where available, and a one-way digest of the destination address. The digest lets Adara compare destinations without storing another copy of the address, although someone who already knows or guesses an address could calculate its digest and compare it.

Adara does not track whether you open an Attention required email and does not track whether you click a link in one. Open and click tracking are disabled for Adara’s sending domain. Adara does not subscribe to those events and discards them if they are received.

You can turn Attention required emails off at any time under Notifications → Preferences. Every message also carries an unsubscribe link that works without signing in, including the one-click unsubscribe control supported by some email applications. Unsubscribing this way stops Attention required emails for all your Brands; you can explicitly turn them back on in Adara.

If delivery to an address bounces or is suppressed by the provider, Adara stops sending Attention required emails to that destination. A bounce stops applying after you explicitly save a different verified address. A spam complaint is not cleared by changing the address or switching the preference back on; contact office@hellolunr.com if it needs to be reviewed.

09Who receives data, and transfers outside the EEA

Not every recipient plays the same role, and the difference matters.

Processors acting for LUNR, under Article 28 data-processing agreements:

• Vercel — website and application hosting, serverless functions, and cookieless, anonymous Web Analytics.
• Resend — delivery of contact-form messages to our inbox and delivery of Adara’s operational email to people who use Adara. For an Attention required message, Resend receives the recipient and sender addresses; a subject containing the Brand name and item count; the HTML and plain-text body containing the Brand name, up to three items requiring attention, generation time, a link to Adara and an unsubscribe link; delivery and unsubscribe headers; and an opaque idempotency identifier used to prevent duplicate sends. Resend reports the delivery outcome back to Adara. Adara does not use Resend’s open or click tracking for these messages.
• Google — Google Analytics 4 (only with your consent).
• Microsoft — Clarity analytics (only with your consent).

We do not use a third-party CRM. Leads from our own campaigns, and the messages you send us, are held in LUNR’s own systems and email. They are not loaded into a sales or marketing platform, and there is no other recipient to disclose.

The advertising platforms are not our processors.

• Meta Platforms, Google, and TikTok process advertising and lead data for their own purposes as well, under their own terms and privacy policies. TikTok states that it and the advertiser are each controllers for lead ads; Meta and Google likewise process lead form data under their own terms alongside the advertiser. Retrieving data through their APIs does not turn them into our processors, and we cannot answer for what they do with it.

LUNR acting for its customers. Where an Adara customer is the controller, LUNR is the processor and the customer’s own recipients and notices apply. Our commitments to them are in the Data Processing Agreement.

Transfers outside the EEA. Several of these providers process data outside the European Economic Area, principally in the United States. Each such transfer relies on a mechanism under Chapter V GDPR — in practice the European Commission’s Standard Contractual Clauses, supplemented, where a provider offers it, by certification under the EU–US Data Privacy Framework. We do not assert a particular safeguard for a particular recipient in this policy unless we have confirmed it in that provider’s current terms. If you want to know which mechanism covers a specific recipient, email office@hellolunr.com and we will tell you what their terms say and give you a copy of the relevant clauses.

10How long we keep data

Website, correspondence, and accounts

• Contact-form messages and email correspondence — kept while we deal with your request and for up to 24 months after our last exchange, then deleted.
• Analytics — Vercel’s daily visitor hash is discarded after 24 hours; Google Analytics retention is set to 14 months; Clarity retains session data up to 12 months.
• Adara account data — kept for the life of your account, then deleted or anonymized.
• API tokens & connected-account data — kept only while the connection is active; revoked and deleted when you disconnect or ask us to delete.
• Adara activity and attention records — current foreground-use and Brand-attention records are kept for the life of your Adara account. They are overwritten as your current state changes and are deleted with your account.
• Attention required preferences and delivery records — kept for the life of your Adara account and deleted with your account. This includes your per-Brand preference, saved destination, delivery records, related provider-event records, unsubscribe credentials and destination digests.
• Suppression records — records showing that you unsubscribed, reported a message as spam, or that delivery to an address bounced or was suppressed are kept while your account exists so that deleting the record does not silently restart the email. They are deleted with your account.
• Contracts, invoices, and accounting records — kept for the period Finnish accounting law requires, currently six years from the end of the accounting year.

Leads from LUNR’s own campaigns

• Lead records we download into our own systems — kept while we are dealing with your enquiry and for up to 24 months from our last contact with you, then deleted. If you go on to become a customer, the record becomes part of the customer relationship and is kept under the contract and accounting rules above.
• Consent records, where you gave an optional consent — kept for as long as we rely on that consent and for 3 years after it is withdrawn or lapses, as evidence under Art. 7(1). Nothing more is kept for that purpose.
• Suppression records — if you ask us never to contact you again, we keep the minimum needed to honour that (normally a one-way hash of your email address) for as long as we operate, because deleting it would defeat your own request.

Customer lead exports through Adara

• Lead content — not retained. Held only for the duration of the export request, then discarded.
• Export and audit metadata (who exported what, when — no lead content) — kept for 12 months, then deleted.

What our retention does not reach. Deleting a connection, or closing an Adara account, does not delete a CSV that has already been downloaded — that file lives wherever it was saved, in the hands of whoever downloaded it. Nor does it delete the leads still held by Meta, Google, or TikTok in their own systems, which they keep under their own retention rules. To have those removed, you need to go to the platform, or to the advertiser who ran the form.

11Your rights under the GDPR

Whether you visited the site, wrote to us, use Adara, or submitted a lead form, you have the right to:

• Access the personal data held about you.
• Rectify data that is wrong or incomplete.
• Erase your data (“right to be forgotten”) — see our Data Deletion Instructions.
• Restrict processing, or object to processing based on legitimate interests.
• Object to direct marketing at any time — an absolute right under Art. 21(2), with no balancing test.
• Port your data to another service in a machine-readable format.
• Withdraw consent at any time, without affecting processing that already happened.

Who to ask depends on whose data it is.

• If you used this site, wrote to us, use Adara, or submitted one of LUNR’s own lead forms — email office@hellolunr.com. We respond within one month.
• If you submitted a lead form for another brand that uses Adara — that advertiser is your controller, not us. Contact them using the privacy notice linked from the form you submitted. If you cannot work out who they were, write to us with the platform, roughly when, and what the ad was for; where we can identify the right controller we will point you to them or pass your request on. Under our Data Processing Agreement we assist our customers with these requests — but we cannot decide them, and we will not disclose or delete another controller’s data without their instruction.
• Where an export has been made — the export metadata described in section 07 lets us tell a customer which exports covered a given form and period, so they can act on the copies they hold. We cannot reach into files stored outside our systems.

To make a request, tell us what you want and enough to find your record — the email address you used, the platform, and roughly when. Where a request concerns sensitive detail we may ask you to confirm your identity; that is only to check it is you, and we delete whatever you send for that check once it is done.

If you believe we have not handled your data lawfully, you may lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi (opens in a new tab)) or your local supervisory authority.

12Security

We protect personal data with technical and organizational measures appropriate to the risk: encryption in transit, encrypted token storage, access controls limited to people who need it, and data minimization by design — including, for customer lead exports, not storing the lead content at all. No system is perfectly secure, but we treat your data the way we would want ours treated.

13Children

Our services are not directed at children under 16, and we do not knowingly collect their data. If you believe a child has provided us personal data, contact us and we will delete it.

14Changes to this policy

We will post any changes on this page and update the date above. For material changes, we will provide a clear notice on the site before the change takes effect.

A policy update is not a permission slip. We will not use a revision of this page to authorize a new use of data you have already given us. Where a new purpose needs consent, we ask you for it separately, before we start.

September 5, 2026 — added disclosures covering Adara’s foreground activity and Brand-attention records, optional Attention required emails, Resend’s operational email-delivery role, delivery and suppression metadata, unsubscribe controls, and the corresponding retention and deletion rules.

August 31, 2026 — added lead-generation forms (section 03), separated LUNR’s controller and processor roles (01), split purposes and legal bases per purpose (05), added marketing consent and withdrawal (06), described Adara’s fetch-and-export processing (07), corrected recipient roles and transfer wording (09), and added lead-specific retention (10). Removed the waitlist, which no longer exists.

15Contact