Privacy Policy
1. General Provisions
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by Alexander Viktorovich Perminov (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of rights to privacy and personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://lunora.mom.
2. Basic Terms Used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data using computer technology.
2.2. Blocking of Personal Data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://lunora.mom.
2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means used for their processing.
2.5. Depersonalization of Personal Data — actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed on personal data.
2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://lunora.mom.
2.9. Personal Data Permitted for Distribution by the Personal Data Subject — personal data to which an unlimited number of persons has been granted access by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as "Personal Data Permitted for Distribution").
2.10. User — any visitor to the website https://lunora.mom.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication in the media, posting in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-Border Transfer of Personal Data — transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring its content in a personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or submits a request to cease processing, provided that grounds specified in the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects' rights with the necessary information within 10 days from receipt of its request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the cases and manner provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent when personal data is processed for the purpose of promoting goods, works, or services on the market;
— withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
— appeal unlawful actions or omissions of the Operator in relation to the processing of personal data to the authorized body for the protection of personal data subjects' rights or in court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or if the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending electronic communications.
Personal data: surname, first name, patronymic, email address, telephone numbers.
Legal basis: Federal Law No. 149-FZ dated July 27, 2006 "On Information, Information Technologies and Information Protection".
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
Sending informational messages to an email address.
7. Conditions of Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice and the execution of judicial acts, acts of other authorities, or officials subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as "publicly available personal data") may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except where required by applicable law or where the personal data subject has consented to the transfer of data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at inbox@lunora.mom with the subject line "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by agreement or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to inbox@lunora.mom with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such entities (Operators) in accordance with their User Agreements and Privacy Policies. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except granting access), processing, or conditions of processing (except obtaining access) of personal data permitted for distribution shall not apply where personal data is processed in state, public, or other public interests as determined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during processing.
8.8. The Operator shall store personal data in a form allowing identification of the personal data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with and/or without transmission of information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of personal data subjects' rights of its intention to carry out such transfer (such notification shall be submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator shall obtain the relevant information from foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification regarding issues related to the processing of their personal data by contacting the Operator via email at inbox@lunora.mom.
12.2. Any changes to the Operator's personal data processing policy shall be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://lunora.mom/privacy.
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by Alexander Viktorovich Perminov (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of rights to privacy and personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://lunora.mom.
2. Basic Terms Used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data using computer technology.
2.2. Blocking of Personal Data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://lunora.mom.
2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means used for their processing.
2.5. Depersonalization of Personal Data — actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed on personal data.
2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://lunora.mom.
2.9. Personal Data Permitted for Distribution by the Personal Data Subject — personal data to which an unlimited number of persons has been granted access by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as "Personal Data Permitted for Distribution").
2.10. User — any visitor to the website https://lunora.mom.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication in the media, posting in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-Border Transfer of Personal Data — transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring its content in a personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or submits a request to cease processing, provided that grounds specified in the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects' rights with the necessary information within 10 days from receipt of its request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the cases and manner provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent when personal data is processed for the purpose of promoting goods, works, or services on the market;
— withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
— appeal unlawful actions or omissions of the Operator in relation to the processing of personal data to the authorized body for the protection of personal data subjects' rights or in court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or if the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending electronic communications.
Personal data: surname, first name, patronymic, email address, telephone numbers.
Legal basis: Federal Law No. 149-FZ dated July 27, 2006 "On Information, Information Technologies and Information Protection".
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
Sending informational messages to an email address.
7. Conditions of Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice and the execution of judicial acts, acts of other authorities, or officials subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as "publicly available personal data") may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except where required by applicable law or where the personal data subject has consented to the transfer of data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at inbox@lunora.mom with the subject line "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by agreement or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to inbox@lunora.mom with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such entities (Operators) in accordance with their User Agreements and Privacy Policies. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except granting access), processing, or conditions of processing (except obtaining access) of personal data permitted for distribution shall not apply where personal data is processed in state, public, or other public interests as determined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during processing.
8.8. The Operator shall store personal data in a form allowing identification of the personal data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with and/or without transmission of information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of personal data subjects' rights of its intention to carry out such transfer (such notification shall be submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator shall obtain the relevant information from foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification regarding issues related to the processing of their personal data by contacting the Operator via email at inbox@lunora.mom.
12.2. Any changes to the Operator's personal data processing policy shall be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://lunora.mom/privacy.
AI-powered assistant for parents. Helping families build healthy sleep routines and support independent sleep.
Lunora's recommendations are for informational purposes only and do not replace professional medical advice from your pediatrician. Every baby is unique, so use these recommendations as guidance rather than medical instructions. For safe sleep, the American Academy of Pediatrics (AAP) recommends placing babies on their backs to sleep, on a firm sleep surface free of pillows, blankets, and soft toys. If you have any concerns about your baby's health or well-being, please consult your healthcare provider.