PRIVACY POLICY
Last updated: April 2026
1. Introduction
Luna Systems (Zentrack Ltd.) (“Luna”, “we”, “our”, or “us”) is committed to protecting your privacy and handling your data responsibly.
This Privacy Policy explains how we collect, use, store and protect your information when you use our products such as “Luna Oculus” and related services.
2. Luna Oculus:
Luna Oculus operates as a device-first system:
- The camera device records video locally
- The mobile app acts as the user interface
- Only safety event clips (e.g. “close passes”) may be uploaded to the cloud with explicit user consent (see below).
Full trip recordings are stored locally on your device and are not automatically uploaded to the cloud, meaning you retain control over your recordings.
3. Information We Collect
3.1 Video Data
We process two types of video data:
a) Full Journey Recordings
- Recorded continuously on your camera
- Stored locally on the device’s internal storage
- Not automatically uploaded to the cloud
- Automatically overwritten as storage fills
b) Event Clips
- Short clips generated when safety events occur (e.g. close passes)
- Automatically uploaded to Luna’s cloud services
- Associated with metadata such as time and location
3.2 Location & Sensor Data
We collect:
- GPS location
- Speed and movement data
- Event locations
This data is used to:
- Provide users with real-time safety alerts
- Generate aggregated safety insights (e.g. identifying high-risk areas)
3.3 Account Information & deletion
When you create an app user account, we may collect:
- Email address
- Basic account identifiers
To delete your account or for any related queries, please email:
4. How We Use Your Data
We use your data to:
- Deliver real-time safety alerts
- Provide video playback and event history
- Enable cloud storage of event clips
- Improve product performance and reliability
- Generate anonymised safety insights
5. AI Model Improvement and User Control
Luna may use event clip video data (e.g. “close pass” or “tailgating” events) to improve its AI models, including enhancing detection accuracy and safety features.
Users are provided with the ability to enable or disable the use of this data for AI model improvement at any time within the app.
- This setting can be changed at any time
- Changes apply to future data processing only
- Previously processed data is not affected
If you choose to disable this setting:
- Your event clip data will not be used for AI training or model development
Where data is used for model improvement:
- It is processed internally only by Luna
- We run facial and license plate blurring in the cloud before video data is used by the team
- Appropriate safeguards are applied based on the sensitivity of the data
6. Data Storage & Retention
6.1 On-Device Storage
- Full journey recordings are stored on the device
- Older footage is automatically overwritten as storage fills
- Users can manually delete recordings
6.2 Cloud Storage (Event Clips)
- Event clips are stored in the cloud
- Users are provided with a free storage tier (1 GB)
- Additional storage may be available via paid plans
Users can manage, download, or delete stored clips via the app.
Additional management tools (including web access) may be introduced in future versions.
6.3 Retention Periods
- Standard journey data is retained on the camera device for a limited period, typically around one week depending on device usage and storage capacity
- Users can delete their data at any time
7. User Control
You have control over your data, including the ability to:
- Download or export videos
- Delete videos
- Adjust privacy and data usage settings at any time
8. Data Sharing
8.1 Aggregated Insights
We may share aggregated and anonymised data, including:
- Safety event locations (explicitly: mapped GPS coordinates only)
- Statistical insights (e.g. heatmaps identifying high-risk areas)
This data does not identify individual users.
8.2 User-Initiated Sharing
Users may choose to share videos externally (e.g. social media).
- This is fully controlled by the user themselves
- Luna is not responsible for how users choose to share their data externally
9. Personal Data in Video
Video recordings may contain personal data such as:
- Faces
- Vehicle license plates
Our approach:
- Raw video remains on the device and is controlled by the user
- Event clips uploaded to the cloud may contain personal data
Where such data is processed by Luna (e.g. for system improvement):
- We apply safeguards such as blurring faces and license plates and access controls to minimise exposure
- Processing is limited to what is purely necessary for system functionality and improvement
Participation in AI model improvement is optional and controlled separately via in-app settings.
10. Data Security
We implement appropriate technical and organisational measures to protect your data, including:
- Encryption in transit
- Secure cloud infrastructure
- Access controls and internal data handling procedures
11. Your Rights
If you are located in the EU or UK, you have the right to:
- Access your data
- Correct inaccurate data
- Request deletion of your data
- Restrict or object to processing
- Request data portability
To exercise these rights, contact:
12. Legal Basis for Processing
We process personal data based on:
- Contractual necessity (to provide the service)
- Legitimate interests (product improvement and safety insights)
- User control and settings (including AI model improvement preferences)
13. International Data Transfers
Your data may be processed in jurisdictions outside your country, using appropriate safeguards.
14. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify users of material changes where required.
15. Contact
For any questions or concerns:
📧 info@luna.systems
🌐 www.luna.systems