Privacy Policy
Summary: We collect only the data necessary to provide our services. We do not sell your personal data to third parties. LunarSense technology collects no personally identifiable information. You have full rights over your data under GDPR.
Contents
1. Who We Are
Lunar Network ("we", "us", "our") is an IT services company registered in Kosovo, providing IT support, networking infrastructure, web development, cloud solutions, and the LunarSense RF sensing product.
Data Controller: Lunar Network
Address: Pristina, Kosovo
Email: info@lunar-ks.com
Website: https://lunar-ks.com
2. Data We Collect
2.1 Account & Portal Data
When you register for or use our client portal, we collect:
- Full name and email address
- Company name (optional)
- Password (stored as a bcrypt hash — we never store plaintext passwords)
- Service plan selected
- Support ticket content you submit
- Session activity logs (login times, actions taken)
2.2 Consultation Requests
When you submit a consultation or demo request via our website, we collect: name, email, company, phone number (if provided), and the content of your message.
2.3 Technical Data (Automatically Collected)
Our server logs collect IP addresses, browser type, referring URL, and pages accessed. This data is used for security monitoring and is not linked to your profile.
2.4 LunarSense Sensing Data
LunarSense collects WiFi channel state information (CSI) metrics — signal variance and frequency amplitudes. This data contains no personal identifiers whatsoever. It cannot be used to identify any individual. See Section 8 for full details.
3. How We Use Your Data
- To provide, operate, and support the services you have purchased or enquired about
- To send transactional emails (account creation, ticket updates, security alerts)
- To respond to consultation and demo requests
- To improve our services and detect/prevent fraud or abuse
- To comply with legal obligations
We do not use your data for profiling, targeted advertising, or automated decision-making that produces legal effects.
4. Legal Basis for Processing
- Contract (Art. 6(1)(b) GDPR): Processing necessary to deliver the services you have contracted with us
- Legitimate interests (Art. 6(1)(f) GDPR): Security monitoring, fraud prevention, improving our services
- Legal obligation (Art. 6(1)(c) GDPR): Where we are required to retain or disclose data by law
- Consent (Art. 6(1)(a) GDPR): For any optional communications (e.g. marketing emails, if we introduce them). You may withdraw consent at any time.
5. Data Sharing
We do not sell, rent, or trade personal data. We share data only in these limited circumstances:
- Service delivery: Our hosting provider (Hostinger) stores data on servers in accordance with their data processing agreement
- Email delivery: Transactional emails are sent via Zoho Mail (EU data centres)
- Legal requirements: Where required by applicable law, court order, or regulatory authority
All third-party processors are contractually bound to process data only as instructed and in compliance with GDPR.
6. Data Retention
- Active client accounts: Retained for the duration of the contractual relationship plus 3 years
- Support tickets: Retained for 3 years from closure
- Consultation requests: Retained for 12 months if no engagement results
- Server logs: Retained for 90 days
- LunarSense sensing data: Retained for the duration of the service contract. Deleted within 30 days of contract termination.
7. Your Rights Under GDPR
If you are located in the EU/EEA or Kosovo (which applies GDPR-equivalent legislation), you have the following rights:
- Right of access (Art. 15): Request a copy of all personal data we hold about you
- Right to rectification (Art. 16): Correct inaccurate or incomplete data
- Right to erasure (Art. 17): Request deletion of your personal data (subject to legal retention obligations)
- Right to restrict processing (Art. 18): Limit how we use your data in certain circumstances
- Right to data portability (Art. 20): Receive your data in a structured, machine-readable format
- Right to object (Art. 21): Object to processing based on legitimate interests
- Right to withdraw consent: Where processing is based on consent, withdraw it at any time
To exercise any of these rights, email info@lunar-ks.com. We will respond within 30 days.
8. LunarSense & Privacy
LunarSense does not collect personal data. The system measures WiFi signal properties (channel state information) — numerical values representing how radio waves travel through space. These measurements cannot identify, profile, or be attributed to any specific individual.
LunarSense sensing data consists of:
- Signal variance values (floating point numbers)
- Frequency amplitude readings at specific Hz bands
- Derived occupancy counts (e.g. "2 people detected")
- Estimated vital sign ranges (e.g. "breathing: 16/min")
None of this data constitutes personal data as defined by GDPR Article 4(1). No individual can be identified, singled out, or linked to LunarSense readings. No biometric data (as defined by GDPR Article 9) is processed. Accordingly, LunarSense deployments do not require a Data Protection Impact Assessment (DPIA) solely on the basis of the sensing technology, though customers are advised to assess their overall deployment context.
Clients deploying LunarSense in workplaces are responsible for notifying their staff or visitors that RF sensing technology is in use, as a matter of transparency best practice (and in some jurisdictions, as a legal requirement under employment law).
9. Cookies
Our client portal uses one session cookie (a secure, HTTP-only cookie) to maintain your authenticated session. This cookie contains no personal information — only an encrypted session identifier. It expires when you log out or after 7 days of inactivity.
We do not use advertising cookies, tracking pixels, or third-party analytics cookies on our portal. Our public website (lunar-ks.com) does not currently deploy any third-party tracking.
10. Security
We implement the following technical and organisational measures to protect your data:
- HTTPS (TLS 1.2+) for all data in transit
- bcrypt password hashing (cost factor 10)
- Session tokens stored in HTTP-only, secure cookies
- Server access restricted by IP and key-based authentication
- Regular security patching of server software
In the event of a data breach affecting your personal data, we will notify you and the relevant supervisory authority within 72 hours of becoming aware, as required by GDPR Article 33.
11. Contact Us
For any privacy-related questions, data subject requests, or concerns:
Email: info@lunar-ks.com
Subject line: "Privacy Request — [your name]"
Response time: Within 30 calendar days
If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority in your country of residence.