Privacy Policy

Luna Market Inc. D.B.A Insomnia Labs ("Luna Market," "we" or "us") is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at creatorfi.finance (the "Site") and online services (collectively, the "Service").

Types of Data We Collect

"Personal Data" means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. "Anonymous Data" means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Information You Provide Us

We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, social media, 3rd party platform connection, blockchain addresses, Luna Market password when you create an account to log in to our network ("Account").

If you use our Services on your mobile device, we may collect your phone number and the unique device id number.

Our Service lets you store preferences like how your content is displayed, your location, safe search settings, notification settings, and favorite widgets. We may associate these choices with your ID, browser or mobile device, and you can edit these preferences at any time.

When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.

Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, blockchain address, and other requested information if you contact us via e-mail regarding support for the Services.

We may also collect Personal Data at other points in our Service that state that Personal Data is being collected.

Information Collected via Technology

As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Information Collected by Our Servers

To make our Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol ("IP") address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, blockchain address, wallet type, and/or a date/time stamp for your visit.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Service, track users' movements around the Service, gather demographic information about our user base as a whole, and better tailor our Services to our users' needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.

Cookies

"Cookies" are small pieces of information that a website sends to your computer's hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service. This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs.

Pixel Tag

In addition, we use "Pixel Tags" (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user's computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users' Personal Data.

How We Respond to Do Not Track Signals

We do not currently respond to "do not track" signals or other mechanisms that might enable Users to opt out of tracking on our site.

Analytics Services

In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Service. This includes third party analytics services, including but not limited to Google Analytics ("Analytics Services"), that we engage to help analyze how users use the Service. We may receive reports based on these parties' use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the "Analytics Information") is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services' ability to use and share Analytics Information is restricted by such Analytics Services' Terms of Use and Privacy Policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at the address given in paragraph (1).

Information Collected from Third Party Companies

We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Service. These third party companies may supply us with Personal Data. We may add this to the information we have already collected from you via our Service in order to improve it. We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us.

Financial Information

Examples: Bank name, account name, type and number, routing number, account owner name, account balance and transaction history, and payment amounts, dates and status.

Business Purpose(s) for Which Information is Used: (i) Servicing financing, including recognising and applying repayments (ii) Monitoring financing in accordance with its terms (iii) Verifying an account before sending funds (iv) Complying with legal and record-keeping obligations (v) Sending funds under your financing and taking payments you authorize.

Categories of Sources from Which Information Received: You, through Plaid Inc., from your financial institution.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) Plaid Inc. (ii) IT vendors, cloud computing and database providers that need access to perform services for us (iii) Financial institutions party to a deposit account control agreement for your financing (iv) Our payment processor and the banks that carry payments.

Bank Account Information and Plaid

Why we collect it. CreatorFi provides revenue-based financing. To service that financing, we ask businesses we finance to connect the bank account their revenue and repayments are paid into. We may also ask you to connect a bank account so we can confirm it belongs to you before we send funds to it.

How we collect it. We use Plaid Inc. ("Plaid") to connect to your bank. When you connect an account, you enter your bank sign-in details directly into Plaid's interface; CreatorFi never sees or stores your bank username or password.

By connecting an account, you grant CreatorFi and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid End User Privacy Policy (https://plaid.com/legal/#end-user-privacy-policy).

What we receive. Depending on what you connect and what your financing requires:

the name of your bank, and the account's name, type (for example checking or savings) and the last digits of its number;
the account's transactions (date, amount, description and, where available, the name of the payer) and its balance;
where needed to verify an account before we pay into it, the full account and routing numbers and the name(s) your bank holds for the account owner.

How we use it. We use bank account information only to provide and service your financing: to recognise repayments and apply them to what you owe, to monitor that your financing remains in good standing under its terms, to verify an account before sending funds to it, and to keep records we are required to keep. We do not sell it and do not use it for advertising.

Who we share it with. Plaid, as described above; the service providers that host and secure our systems; and, where your financing involves them, the bank holding an account subject to a deposit account control agreement. We may also disclose it where the law requires, as described in "Disclosure of Your Personal Data".

How we protect it. Access credentials Plaid issues to us are encrypted at rest. Access to bank data within CreatorFi is limited to staff who need it to service your financing.

How long we keep it. For as long as your financing is outstanding, and afterwards for as long as we are required to keep records of it by law.

Your choices. You can disconnect a bank account at any time by contacting support@creatorfi.finance, or through Plaid at https://my.plaid.com. Disconnecting stops new information from being collected; information already received is kept as described above. If your financing agreement requires a connected account, disconnecting it may affect that agreement.

Use of Your Personal Data

General Use

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

Facilitate the creation of and secure your Account on our network;
Identify you as a user in our system;
Provide improved administration of our Service;
Provide the Services you request, including but not limited to facilitating facilitating loan matching with qualified lenders;
Improve the quality of experience when you interact with our Service;
Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
Protect you and other users from any conduct that violates the Terms of Use or to prevent abuse or harassment of any user;
Display your username send you administrative e-mail notifications, such as security or support and maintenance advisories;
send you e-mail notifications related to actions on Service, including notifications of offers on your digital assets;
respond to your inquiries related to employment opportunities or other requests;
make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
in any other way we may describe when you provide the Personal Data; and
send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Luna Market.

We may use your Personal Data to contact you about our own and third parties' goods and services that may be of interest to you.

Anonymous Data

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

Disclosure of Your Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third Party Service Providers

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Service; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Luna Market.

Affiliates

We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.

Corporate Restructuring

We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

As Legally Required

Regardless of any choices you make regarding your Personal Data (as described below), Luna Market may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Luna Market; (c) to protect or defend the rights or property of Luna Market or users of the Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Other Disclosures

We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent. We do not sell your Personal Data.

Third Party Websites

Our Service may contain links to third party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data or Anonymous Data from you. You may also find marketplaces powered by the Service on other websites. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Your Choices Regarding Information

You have several choices regarding the use of information on our Services:

Email Communications

We will periodically send you free, opt-in newsletters and e-mails that directly promote the use of our Service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information in paragraph (1)). Despite your indicated e-mail preferences, we may send you occasional service related communications, including notices of updates to our Terms of Use or Privacy Policy.

If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser's technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the address given in paragraph (1).

Data Access and Control

You can view, access, edit, or delete your personal data for many aspects of the Service via your account settings page. You can also make choices about Luna Market's use of your data. You can always choose whether you want to receive marketing communications from us. You can also opt out from receiving marketing communications from us by using the opt-out link on the communication, or by visiting your account settings page. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Data Access

You can access your Personal Data on your account settings page.

Data Portability

You can request a copy of your Personal Data by contacting us here and including "Please send me my Personal Data" in the subject line. Luna Market will verify your ability to access that email, then send you a digital export of the data we hold that is associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.

Data Erasure

You can delete your Personal Data on your account settings page. Alternatively, you may request that Luna Market delete your personal data by contacting us at data and including "Please delete my Personal Data" in the subject line. Luna Market will verify your ability to access that email, then delete the Personal Data associated with your email address. We will use reasonable efforts to respond to your request within 7 days, but in all events within 28 days of our receipt of the request.

Data Correction

You can modify your Personal Data on your account settings page.

Data Retention

We may retain your Personal Data as long as you continue to use the Service, have an account with us, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. You can ask to close your account by contacting us as described above, and we will delete your Personal Data on request. We may, however, retain Personal Data for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

Data Protection

We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

A Note About Children

We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Luna Market and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address indicated in Section 1 above.

A Note to Users Outside of the United States

If you are a non-U.S. user of the Service, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at creatorfi.finance/privacy-policy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Service and this Privacy Policy to check for any changes.

13. Additional Notice to California Residents

In accordance with the California Consumer Privacy Act (the "CCPA"), the following table summarizes our personal information collection, use, and sharing practices in the preceding twelve (12) months since we last updated this Privacy Policy.

Personal Identifiers & Contact Information

Examples: Name, username, password, email address, customer number, IP address, unique device ID, tracking technologies (e.g., pixel tags, cookies) to collect usage information.

Business Purpose(s) for Which Information is Used: (i) Maintaining and servicing Accounts (ii) Processing and fulfilling orders and transactions (iii) Register you as a customer or a candidate (iv) Process and deliver or accept services (v) Notify you about changes to our terms and conditions of use or privacy policies (vi) Request that you write a review or take a survey (vii) Administer and protect our business website (viii) Deliver relevant Website content and advertisements and measure or understand the effectiveness of the advertising (ix) Make suggestions and recommendations about services that may interest you (x) Respond to inquiries through the Website and (xi) Verify and respond to consumer requests.

Categories of Sources from Which Information Received: Users of our Website, App, or Services.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that need access to such information to perform services for us (ii) Data analytics providers and (iii) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes.

Internet Activity & Technical Data

Examples: Domain information, pages visited, cookie information, session information (such as time spent on certain pages and page interaction information), date and time of your visit, webpages visited, links clicked, browser ID, browser type, device ID, operating system, form information downloaded, domain name from which our site was accessed, and cookies.

Business Purpose(s) for Which Information is Used: (i) Improve the Website experience for all visitors (ii) Understand the demographics of our Website visitors (iii) Operate and maintaining the Website (iv) Detect security incidents (v) Debug to identify and repair errors that impair existing intended functionality of the Website (vi) Protect against malicious or illegal activity and prosecuting those responsible and (vii) Verify and responding to consumer requests.

Categories of Sources from Which Information Collected: Users of our Website, App, or Services and the devices or browsers they used.

Geolocation Data

Examples: IP Address.

Business Purpose(s) for Which Information is Used: (i) Improve the Website experience for all visitors (ii) Understand the demographics of our Website visitors (iii) Detect security incidents (iv) Debug to identify and repair errors that impair existing intended functionality of the Website (v) Protect against malicious or illegal activity and prosecuting those responsible and (vi) Verify and responding to consumer requests.

Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used.

Financial Data

Examples: Card number.

Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges and (ii) Collect and recover funds.

Categories of Sources from Which Information Received: Users of our Website, App, or Services.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, third-party payment processors, and service providers that need access to such information to perform services for us (ii) Data analytics providers and (iii) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes.

Financial Information

Examples: Bank name, account name, type and number, routing number, account owner name, account balance and transaction history.

Categories of Sources from Which Information Received: You, through Plaid Inc., from your financial institution.

Transaction Data

Examples: Details about your payment and details about the services you considered, purchased or provided.

Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges and (ii) Collect and recover funds.

Categories of Sources from Which Information Received: Users of our Website, App, or Services.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, third-party payment processors, and service providers that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes (iii) Data analytics providers and (iv) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes.

Profile Data

Examples: Username, email address, password, purchases, orders, customer interests, customer preferences, customer feedback, and survey responses.

Business Purpose(s) for Which Information is Used: (i) Notify you about changes to our terms and conditions of use and privacy policy (ii) Request that you write a review or take a survey (iii) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising and (iv) Make suggestions and recommendations about services that may interest you.

Categories of Sources from Which Information Received: Users of our Website, App, or Services.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes (iii) Data analytics providers and (iv) Luna Market Customers requiring this information to obtain services and/or for safety and security purposes.

Usage Data

Examples: Information about how you use our Website, App, or Services.

Business Purpose(s) for Which Information is Used: (i) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising and (ii) To use data analytics to improve of website, product/services, marketing, and customer relationships.

Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes and (iii) Data analytics providers.

Marketing and Communications Data

Examples: Your preferences in receiving marketing from Luna Market and your communication preferences.

Business Purpose(s) for Which Information is Used: (i) Manage payments, fees, and charges (ii) Collect and recover funds and (iii) Notify you about changes to our terms and conditions of use and privacy policy (iv) Request that you write a review or take a survey and (v) Deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising.

Categories of Sources from Which Information Received: Users of our Website, App, or Services and the devices or browsers they used.

Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months: (i) IT vendors, cloud computing providers, database providers, customer service vendors, and service providers that need access to such information to perform services for us (ii) Business customers who require information for safety or security purposes and (iii) Data analytics providers.

We do not knowingly sell or otherwise disclose the PII or PI of minors under 16.

Choices for Access, Deletion, Opt-Out of Sale, and Right to Non-Discrimination for California Residents or As Required by Law

If you are a California resident, you have the right to know what personal information we collect, disclose, and "sell" about you (as that term is defined in the CCPA). Additionally, you have the right to access, delete and opt out from the "sale" of your personal information.

Your Rights

Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
Right to Opt-Out. The right to opt-out of the sale of your personal information to third parties (Note: we do NOT sell your personal information to third parties.);
The right to designate an authorized agent to submit one of the above requests on your behalf; and
The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

To exercise these privacy rights and choices, please follow the instructions below:

How to Request That We Identify or Provide You Access to Personal Information

You may request that we identify or provide you access to your personal information twice in a 12-month period. To do so, please email us at privacy@creatorfi.finance. In response to a request to identify your personal information, we will identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months. In response to a request to access your personal information, we will produce an "Access Report" detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request.

How to Request Deletion of Personal Information

You may request that Luna Market delete the personal information it has collected and/or maintained about you. To do so, please email us at: privacy@creatorfi.finance. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

How to Opt-Out of the Sale of Personal Information

We do not sell, share, or rent your personal information in any way.

Verification

Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an Account with us, we will verify your identity through existing authentication practices for the Account (e.g., login and password). If you are not a registered Website, App, or Services user, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.

Questions; Contacting Luna Market; Reporting Violations

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address: 71 Broadway, Suite 14L New York, NY 10006.