Collection of Your Personal Information
In order to better provide the products and services offered on our Site to you, Luhnar may collect personally identifiable information about you, such as your:
- First and Last Name
- Email Address
- Phone Number
If you subscribe to Luhnar’s services, we collect billing and credit card information. This information is used to complete subscription transactions each month.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Luhnar’s comment sections, this information may be collected and used by others.
We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain services available on the Site. These may include: (a) registering for an account on our Site; (b) sending us an email message; (c) contacting support (d) submitting your credit card or other payment information when subscribing to services on our Site. We will use your information for, but not limited to, communicating with you in relation to the services your have requested from us. We also may gather additional personal or non-personal information in the future.
Use of Your Personal Information
Luhnar collects and uses your personal information to operate its website and deliver the services you have requested.
Luhnar may also use your personal information to inform you of other products or services available from Luhnar and its affiliates.
Sharing Information with Third Parties
Luhnar does not sell, rent or lease its customer lists to third parties
Luhnar may share data with trusted partners to help perform statistical analysis, send you email or postal mail, or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to Luhnar and they are required to maintain the confidentiality of your information.
Luhnar may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Luhnar or the site; (b) protect and defend the rights or property of Luhnar; and/or (c) act under exigent circumstances to protect the personal safety of users of Luhnar or the public.
The following are trusted partners whose systems transfer, process, and/or store visitor and customer data:
Amazon Web Services
- Purpose / Legal Basis: Luhnar uses AWS for storing and serving optimized site assets (such as images and pages), as well as visitor logs.
- Legitimate Interest: AWS is an important component of Luhnar’s global cloud network. Visitor logs are used in aggregate to operate Luhnar services, not to personally identify any user or site visitor.
- Personal Data Stored: Log data may occasionally include site visitors’ IP addresses, but this information is not used to personally identify site visitors and is only shared with security partners on an as-needed basis during system audits. Luhnar does not control what data is stored in customer’s cached assets, but these typically do not include personally identifiable information. Cached assets are encrypted at rest and all data transferred between AWS and Luhnar is encrypted.
- Length of Data Storage: Assets may be cached for up to 180 days, depending on a number of factors including the origin server cache headers.
- Locations: Luhnar leases cloud services in several of AWS’s worldwide data centers.
- Purpose / Legal Basis: Anvil is used for some of our backend features suche as the Luhnar control panel, site health notifications, and billing integration.
- Legitimate Interest: Anvil is necessary for you to manage your account.
- Personal Data Stored: Anvil interacts with databases and files that store account settings and information.
- Length of Data Storage: Most of your data is removed 30 days after your account is deleted, but some is legally required to be stored for up to 7 years for tax and accounting purposes.
- Locations: Anvil’s hosting is located in London, England
- Purpose / Legal Basis: Website visitor data is recorded and analyzed so Luhnar can determine the most popular parts of the Website and those which are performing poorly.
- Legitimate Interest: Luhnar uses Website visitor data to improve your experience
- Personal Data Stored: IP address(es)
- Length of Data Storage: 26 months or until removal is requested.
- Locations: Google Analytics data is stored in the United States
Google Cloud Platform
- Purpose / Legal Basis: Luhnar uses the Google Cloud Platform (GCP) to optimize, cache, and serve customer websites.
- Legitimate Interest: Without GCP’s global server network, Luhnar would not be able to reduce ping and latency for your site visitors’ connections.
- Length of Data Storage: By default, site data is cached on our GCP servers for up to 30 days but may be cached for a longer or shorter duration (depending on a number of factors such as the origin server’s cache headings and how often cached assets are accessed). Optimized assets are cached in second-tier GCP storage for up to 180 days.
- Locations: Luhnar utilizes GCP compute, networking, and other services around the world.
Google G Suite
- Purpose / Legal Basis: Email communications with Luhnar to maintain customer relationships.
- Legitimate Interest: Email is the most timely and efficient method to communicate with Luhnar.
- Personal Data Stored: Contents of emails sent by customers and site visitors.
- Length of Data Storage: Until removal is requested; some emails (e.g. those containing transaction details) must be retained by law.
- Locations: United States
- Applicable Policies: Google’s G Suite uses the same security center as Google Cloud, which includes a section devoted to the GDPR
- Purpose / Legal Basis: MailChimp is used to create and maintain segmented lists of subscribers and send them company and marketing communications.
- Legitimate Interest: Our lists and emails are double opt-in only—subscribers have asked to receive communications from us.
- Personal Data Stored: First name, last name, and email address.
- Length of Data Storage: Until the subscriber chooses to unsubscribe by clicking the unsubscribe link in the email footer.
- Locations: United States
- Purpose / Legal Basis: We use Stripe to process your payments for Luhnar services.
- Legitimate Interest: After your free trial, your payments fund current Luhnar services and future development.
- Personal Data Stored: Stripe retains transaction information for as long as is required by law. Automatic monthly billing requires the use of an encrypted token (that does not contain your credit card information) that is stored for as long as your account is active.
- Length of Data Storage: As required by law. Please see Stripe’s statement about security and retention.
- Locations: Please see Stripe’s statement about their international business and GDPR compliance
- Purpose / Legal Basis: Luhnar uses Vultr servers and systems to provide backend automation and asset optimization services.
- Legitimate Interest: Vultr provides cost-effective compute resources and increases system resilience.
- Personal Data Stored: Data may be stored temporarily on Vultr servers as needed to generate invoice PDFs and to optimize public website assets. Luhnar does not control whether or not its customers store personally identifiable information on their sites that would be subject to optimization and caching.
- Length of Data Storage: Data is stored in temporary files that are erased immediately after a given invoice has been generated, or an asset has been optimized.
- Locations: Luhnar utilizes secure Vultr servers around the world.
- Purpose / Legal Basis: Luhnar’s Website is hosted by WPEngine and most interactions with Luhnar begin on the Website.
- Legitimate Interest: If you want to learn about Luhnar and its products or become a customer, you need to access our Website.
- Personal Data Stored: None
- Length of Data Storage: N/A
- Locations: Form data submitted on the Website is transferred through WPEngine servers in the United States.
Tracking User Behavior
Luhnar may keep track of the websites and pages our users visit within Luhnar in order to determine which Luhnar services or content are the most popular. This data is used to improve our site and services.
Luhnar uses browser session recording software to capture mouse movements and clicks on our website and in our control panel. This data is used to improve our site and services. These sessions are not personally identifiable because all personally identifiable information has been filtered out.
Automatically Collected Information
Information about your computer hardware and software may be automatically collected by Luhnar. This information can include: your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding use of the Luhnar website and services. We do not sell this information to third parties, however we may share it with partners when performing security audits.
Right to Access
Upon request, we will show you the personally identifiable information we have stored about you.
Right to Be Forgotten
Upon request, we will delete the personally identifiable information we have stored about you (as far as is legally permissable. Some customer transaction data must be retained by law).
The Luhnar website may use “cookies” to help you personalize your online experience and to maintain a browser session. A cookie is a text file that is placed on your hard drive by a web server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that you issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to help Luhnar recall your specific information while you are browsing the site or when you return to the site or service.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Luhnar website or services.
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Security of Your Personal Information
Luhnar secures your personal information from unauthorized access, use, or disclosure. Luhnar uses the following methods for this purpose:
- HTTPS protocol with TLS (aka SSL)
- Encryption of information at rest
- Not storing credit card information
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Children Under Thirteen and Other Minors
Luhnar does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
Luhnar offers its services on a monthly, contractual basis. Users under the age of 18 cannot legally enter into a contractual agreement with Luhnar and thus are ineligible to utilize Luhnar services unless an adult subscribes to the services on their behalf.
From time to time, Luhnar may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Luhnar or click on a link therein.
If you would like to stop receiving marketing or promotional communications from Luhnar via email, you may opt out of such communication by clicking on the unsubscribe link in the email.
External Data Storage Sites
We may store your data on servers provided by third-party hosting vendors with whom we have contracted.
Changes to This Statement
Effective April 1, 2018. Updated March 8, 2019.