1. Who is responsible for your data

The data controller is:

Horison Marketing Group CY Ltd
1 Kalymnou Street, Q Merito, 4th Floor
Agios Nikolaos, Kamares, Cyprus

Contact: support@selluna.ai

2. What data we collect

We may collect:

a) Account & contact data

Name
Email address
Password (hashed)
Company/brand name (if provided)
Role (if provided)

b) Product & brand data

Logos, brand colors, fonts
Product URLs (e.g. Amazon listings)
Product images and descriptions you upload
Other assets you upload to generate images

c) Usage data

Actions in the app (e.g. images generated, features used)
Log data (IP address, browser type, device info, timestamps)
General usage patterns (e.g. which pages or sections users interact with)

d) Waitlist & marketing data

Name and email when you join the waitlist
Your website/store link (if you provide it)
Your preferences for receiving updates and marketing emails

e) Cookies and similar technologies

We use cookies and similar technologies to:

Remember your login session
Understand how people use our website and app
Improve performance and user experience
(Where relevant) support analytics and advertising/retargeting

You can manage cookies in your browser settings. Some cookies are necessary for the Service to work.

3. Why we process your data (and legal bases)

We use your data for the following purposes:

To provide and operate Selluna

Creating and managing your account
Letting you add brands and products, generate images, and use credits

Legal basis: Contract (we need this to provide the Service you signed up for)

To improve and secure the Service

Monitoring performance, detecting errors, preventing abuse
Analysing usage patterns to make Selluna better

Legal basis: Legitimate interest (running and improving our product)

To communicate with you

Sending onboarding emails, support replies, and important service updates

Legal basis: Contract and legitimate interest

To send you marketing and product updates

Emails about new features, launches, and relevant content

Legal basis: Consent (where required) or legitimate interest (for existing B2B relationships). You can unsubscribe at any time.

To manage early access and waitlists

Letting you join early access
Notifying you about your access status
Inviting you to calls or feedback sessions

Legal basis: Contract and legitimate interest

To comply with legal obligations

Keeping necessary records
Responding to lawful requests

Legal basis: Legal obligation

4. AI, training and your data

We use your:

Brand inputs (logo, colors, fonts)
Product URLs and content
Generated outputs

to:

Generate and serve your images
Improve Selluna's own models and features internally
Test reliability and performance

We do not:

Use your data to train general public models for third parties
Sell your personal data to data brokers

We may: Use anonymised or aggregated data (where individual users or brands are not identifiable) for analytics, product improvement, and marketing statistics.

For marketing visuals (like examples on our website): We either use demo products, or we use generated outputs in a way that does not reveal your brand, unless you have explicitly agreed to a case where it does.

5. Sharing your data

We may share your data with:

Hosting and infrastructure providers (e.g. Vercel)
Analytics and monitoring tools (to be defined, e.g. in the future Google Analytics, PostHog, etc.)
Email and communication tools (for onboarding, updates, support)
Payment processor (Stripe) once paid plans are live
Community platforms (e.g. Discord) if you choose to join

All such providers act as processors under contract and only process data on our instructions, for the purposes listed above.

We may also share data:

If required by law, court order, or legal process
In connection with a merger, acquisition, or sale of business assets (we'll aim to notify you if this happens, where possible)

We do not sell your personal data.

6. International transfers

We are based in Cyprus and use providers that may store or process data in the EU, UK, USA, or other countries.

When data is transferred outside the EU/EEA or UK, we will:

Use appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent lawful mechanisms, where required by law.

7. Data retention

We keep:

Your account and profile data for as long as your account is active.
If you close your account, we may keep certain records where required by law or for legitimate business purposes (e.g. invoices, security logs).
We keep log and technical data for up to 24 months, unless we need to keep it longer for security, legal, or operational reasons.

We may keep anonymised or aggregated data longer, as it can no longer be linked back to you.

8. Your rights (EU/UK users)

If you are in the EU/EEA or UK, you have the right to:

Access your personal data
Correct inaccurate or incomplete data
Delete your data in certain circumstances
Restrict or object to processing in some cases
Data portability (receive your data in a structured, commonly used format)
Withdraw your consent where processing is based on consent
Lodge a complaint with your local data protection authority

To exercise these rights, contact us at support@selluna.ai. We may need to verify your identity before acting on your request.

9. Children

Selluna is not intended for users under 16.

We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, contact us and we will take appropriate steps to delete it.

10. Cookies and tracking

We use cookies and similar technologies to:

Keep you logged in
Remember preferences
Measure performance and usage
Support analytics and (where enabled) advertising

You can control cookies via your browser settings. Some cookies are necessary for the Service to function and cannot be disabled without affecting basic functionality.

When required by law, we will show a cookie banner and ask for your consent for non-essential cookies (such as analytics or ads).

11. Security

We take reasonable technical and organisational measures to protect your data, including:

Secure hosting and infrastructure
Access controls and authentication
Encryption in transit (HTTPS)
Limiting access to personal data to staff and providers who need it

However, no system is completely secure. Use of the Service is at your own risk.

12. Changes to this Privacy Notice

We may update this Privacy Notice from time to time.

If we make significant changes, we will:

Update the "Last updated" date, and
Where appropriate, notify you via the app, email, or our website.

13. Contact

For any questions or requests about your privacy, you can contact us at:

support@selluna.ai