LUNA Bot Privacy Policy

1. About this policy

This Privacy Policy explains how we process the personal data of people who use LUNA, our Telegram bot for tracking the menstrual cycle (the "Bot").

Data controller:
DIGICOM GROUP OÜ, registry code 16260513
Lembitu tn 14, 10114 Tallinn, Estonia
Email: info@rosaluna.eu

By using the Bot, you agree to the terms of this Privacy Policy.

2. What data we collect

2.1 When you sign up

The first time you use the Bot, we ask for:

  1. Your first name, so the Bot can talk to you personally;
  2. The current day of your cycle, for accurate tracking;
  3. Your age, so our recommendations fit you;
  4. How long your period lasts (in days), to predict your cycle;
  5. Your average cycle length (in days), to calculate your future periods;
  6. Whether you use hormonal contraception (yes/no), as it affects how your cycle behaves;
  7. The period products you prefer, for personalised tips:
    • menstrual cup
    • period underwear
    • reusable pads
    • disposable pads
    • tampons
    • other
  8. How heavy your periods are, so our advice suits you:
    • light (changing 1 to 2 times a day)
    • medium (changing every 3 to 4 hours)
    • heavy (changing every 2 to 3 hours)
    • very heavy (changing every 1 to 2 hours)

2.2 While you use the Bot

  • Chat messages: we keep only your last 50 messages, so the Bot can follow the conversation;
  • The start and end dates of your periods, to keep your cycle calendar;
  • Additional notes: symptoms, mood and any other information you choose to share.

2.3 Technical data

  • Your Telegram ID, to identify you in our system;
  • The time of your last interaction, so reminders work correctly.

3. Why we use your data

We use your data to:

  • track your menstrual cycle and build your personal calendar;
  • give you personalised recommendations on health and wellbeing;
  • send you reminders about important dates in your cycle;
  • adapt what the Bot tells you to your individual situation;
  • keep the Bot's features working properly;
  • tell you about our own products (period underwear) in the Bot's first messages.

4. Legal basis

We process your personal data on the basis of:

  • Your consent, which you give when you start using the Bot. Information about your cycle is health data, so we only process it with your explicit consent;
  • Contract, to provide the cycle-tracking service you asked for;
  • Legitimate interests, to keep the service secure and improve it.

5. Storage and security

5.1 Where your data is stored

All data is stored on secure servers in the European Union, rented from our hosting provider.

5.2 How we protect it

We use the following measures to protect your data:

  • encryption of data in transit and at rest;
  • access limited to authorised staff only;
  • regular backups;
  • security monitoring.

5.3 How long we keep it

  • Your profile answers: kept until you delete your data, so your cycle tracking stays continuous;
  • Message history: only your last 50 messages;
  • Cycle data: kept until you delete your account.

6. Sharing your data

We do not sell your personal data or pass it to third parties, except:

  • Telegram, the platform the Bot runs on, which carries our conversation;
  • the AI model provider that powers the Bot, which receives the text of your messages so the Bot can reply to you;
  • where a public authority requires it on a lawful basis.

We do not use your data for:

  • research;
  • third-party marketing campaigns;
  • selling or passing it to advertisers.

7. Advertising in the Bot

In its first few messages, the Bot tells you about our period underwear, with a link to our shop. This only ever concerns our own products. We do not use your personal data to personalise advertising. If you would rather not receive these messages, write to us at info@rosaluna.eu.

8. Your rights

8.1 Access

  • Ask what data we hold about you;
  • Get a copy of your personal data.

8.2 Correction

  • Correct inaccurate information at any time, directly in the Bot;
  • Update details that have changed.

8.3 Deletion

  • Delete your account and all related data: just ask the Bot to delete everything;
  • Withdraw your consent to the processing of your personal data.

8.4 Restriction

  • Limit how certain data is used;
  • Pause processing while a disagreement is being resolved.

8.5 Portability

  • Receive your data in a structured format;
  • Move it to another service provider.

You also have the right to lodge a complaint with the data protection authority in your country of residence.

9. Contact us

For any question about how we process your personal data, write to us:

Email: info@rosaluna.eu
Response time: within 10 working days of receiving your request.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will tell you about significant changes by:

  • a message in the Bot;
  • publishing the updated version with the date of the changes.

If you keep using the Bot after changes are made, you accept the updated terms.

11. Your consent

By starting to use the Bot, you confirm that you:

  • have read and understood this Privacy Policy;
  • consent to the processing of your personal data for the purposes described above;
  • are at least 16 years old, or have the consent of a parent or guardian.

Last updated: 24 September 2026