Privacy policy

Applicable regulatory framework

INVESTNOA WELLNESS, SLU processes users’ personal data in accordance with the regulations in force on personal data protection and, in particular, with:

• Law 29/2021, of 28 October, qualified law on personal data protection of the Principality of Andorra (LQPD);
• Law 12/2024, of 15 July, qualified law amending Law 29/2021;
• the implementing Regulation of Law 29/2021, approved by Decree 391/2022; and
• where applicable, Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Data Protection Regulation – GDPR).

The Principality of Andorra has its own personal data protection framework and has been recognised by the European Union as a territory that ensures an adequate level of protection for international transfers of personal data.

Accordingly, INVESTNOA WELLNESS, SLU undertakes to process personal data applying the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and proactive accountability established by applicable regulations.

 

1. Data controller

In accordance with Law 29/2021, of 28 October, qualified law on personal data protection of the Principality of Andorra, users are informed that personal data provided through lunnecircle.com will be processed by:

Controller: INVESTNOA WELLNESS, SLU
Trademark: LÜNNE
Address: Carrer dels Paraires, 21, AD700 Escaldes-Engordany, Principality of Andorra
Tax ID (NRT): L-721791-H
Email: hello@lunnecircle.com
Telephone: +376 646 111
Website: lunnecircle.com

INVESTNOA WELLNESS, SLU is the controller responsible for the personal data collected through the website and undertakes to process it lawfully, fairly, transparently and securely.

 

2. What personal data may we collect?

Depending on the user’s relationship with LÜNNE and the features used on the website, we may process the following categories of data.

Identification data

• First name.
• Surname(s).
• Date of birth, where necessary.
• Identity document, where necessary to provide a service.

Contact data

• Email address.
• Telephone number.
• City or country of residence.
• Postal address, where necessary.

Data related to enquiries

• Reason for the enquiry.
• Messages sent through the forms.
• Information voluntarily provided by the user.

Data related to bookings

When the booking system is enabled:

• Experience booked.
• Date and time.
• Number of people.
• Data of the people included in the booking where necessary.
• Preferences relating to the visit.
• History of bookings, changes or cancellations.

Financial and payment data

When bookings or purchases are made:

• Payment-related information.
• Transaction amount.
• Payment status.
• Information necessary to manage refunds, charges or incidents.

Where payment is processed through an external payment gateway or provider, LÜNNE will not directly store the full bank card details unless technically appropriate and there is a legal basis for doing so.

Data relating to preferences and communications

When authorised by the user:

• Communication preferences.
• Interest in LÜNNE experiences, activities or news.
• Waiting-list sign-up.
• Communications linked to the LÜNNE CIRCLE.
• Interaction with commercial communications.

Technical and browsing data

Depending on the cookies and technologies authorised by the user, we may obtain:

• IP address.
• Device type.
• Browser.
• Operating system.
• Pages visited.
• Session duration.
• Traffic source.
• Interactions with the website.
• Technical or cookie identifiers.

For more detailed information, please see the Cookie Policy.

 

3. For what purposes do we process the data?

3.1. Managing enquiries and information requests

When the user contacts LÜNNE through the forms, email, telephone or other enabled channels.

Purpose: to handle and respond to the enquiry, request or application made.

Legal basis: implementation of pre-contractual measures at the request of the data subject, or legitimate interest in handling communications received, as applicable.

3.2. Managing bookings and contracting of services

When the user makes a booking or contracts a LÜNNE experience.

The data may be used to:

• Manage the booking.
• Confirm availability.
• Coordinate the client’s arrival.
• Manage payments.
• Send confirmations and reminders.
• Manage changes or cancellations.
• Properly deliver the experience contracted.
• Manage incidents relating to the service.

Legal basis: performance of a contract or implementation of pre-contractual measures.

3.3. Managing payments

Data necessary for invoicing and financial management will be processed to collect payment for the contracted services.

Legal basis: performance of the contract and compliance with applicable legal obligations.

3.4. Managing the waiting list and LÜNNE’s opening

When the user voluntarily provides their data to receive information about the opening, first available dates or priority access.

Purpose: to communicate information relating to LÜNNE’s opening, initial availability or preferential access.

Legal basis: consent of the data subject.

The user may withdraw this consent at any time.

3.5. Managing the LÜNNE CIRCLE

When the user expresses interest in or requests to join the LÜNNE CIRCLE, their data may be processed to:

• Manage their request.
• Maintain the relationship with members.
• Provide information linked to the CIRCLE.
• Communicate access, invitations, experiences or associated activities.

Legal basis: consent of the data subject and, where a contractual relationship exists, performance of that relationship.

3.6. Sending commercial communications

When expressly authorised by the user, LÜNNE may send information about:

• Experiences.
• News.
• New itineraries.
• Events.
• Night experiences.
• Availability.
• LÜNNE CIRCLE.
• Other brand-related content.

These communications may be sent by email or other expressly authorised channels.

Legal basis: user consent.

Consent may be withdrawn at any time using the mechanism provided in the communications or by contacting LÜNNE directly.

3.7. Analysing and improving the website

Where the user has authorised the relevant cookies, we may analyse use of the website in order to:

• Understand the performance of the different pages.
• Detect technical issues.
• Analyse aggregate user behaviour.
• Improve browsing.
• Optimise content.
• Improve the digital experience.

Legal basis: user consent for those cookies or technologies that require it.

 

4. Health-related data

Certain LÜNNE experiences may involve water, heat, steam, thermal contrast, floating or other stimuli that make it necessary to know certain circumstances before the visit.

If, in the context of a booking or enquiry, the user provides information relating to their health status, pregnancy, contraindications or other similar circumstances, this information may be considered a special category of personal data.

LÜNNE will only process this information when strictly necessary to:

• Assess the suitability of the experience.
• Adapt the itinerary where possible.
• Protect the person’s safety.
• Adopt the necessary preventive measures.

This data will not be used for commercial purposes.

Where required by law, processing will be based on the explicit consent of the data subject.

LÜNNE will apply the principle of minimisation and will seek to collect only the information essential for the relevant purpose.

 

5. Data relating to minors

In general, LÜNNE’s services and experiences are aimed at adults, without prejudice to any experiences, products or specific slots LÜNNE may enable for accompanied minors.

Where it is necessary to process personal data of minors, such data will be collected and processed in accordance with the requirements set out in Andorran regulations and, where applicable, with the involvement or authorisation of the father, mother, guardian or legal representative.

LÜNNE does not intend to deliberately collect personal data from minors outside services expressly enabled for this group.

 

6. How long do we retain the data?

Personal data will be retained only for as long as necessary to fulfil the purpose for which it was collected and, thereafter, for the periods necessary to address any applicable legal obligations or potential liabilities arising from the processing.

In general:

Enquiries and requests: for as long as necessary to handle them and thereafter for the periods applicable to address potential liabilities.

Bookings and contracting: for the duration of the contractual relationship and thereafter for the applicable legal periods.

Invoicing and financial information: for the periods required by applicable tax, accounting or commercial regulations.

Waiting list and commercial communications: until the user withdraws consent or requests to unsubscribe.

LÜNNE CIRCLE: for as long as the relevant relationship is maintained and thereafter for the periods necessary to address potential obligations or liabilities.

Cookies and analytical data: for the periods indicated in the Cookie Policy.

Once the relevant periods have ended, the data will be deleted or, where legally necessary, duly blocked.

 

7. Who may we share the data with?

LÜNNE does not sell, rent or trade users’ personal data.

Data may be disclosed to:

• Public administrations.
• Competent authorities.
• Courts and tribunals.
• Tax authorities.
• Law enforcement bodies.
• Other third parties where there is a legal obligation.

Likewise, certain providers may access personal data where necessary to provide services to LÜNNE, such as:

• Hosting and technology infrastructure.
• Web development and maintenance.
• Booking system.
• Payment gateway.
• CRM.
• Email services.
• Communication delivery platforms.
• Web analytics tools.
• Cybersecurity services.
• Administrative, accounting, tax or legal providers.

When these providers process data on behalf of INVESTNOA WELLNESS, SLU, they will act as data processors and will be subject to the corresponding contractual and legal obligations.

 

8. International data transfers

Some technology providers used by LÜNNE may be located outside the Principality of Andorra or process information from other countries.

In such cases, INVESTNOA WELLNESS, SLU will adopt the safeguards required by applicable regulations to ensure an adequate level of protection for personal data.

Where necessary, mechanisms recognised by applicable regulations will be used, such as:

• Adequacy decisions.
• Appropriate contractual safeguards.
• Applicable contractual clauses.
• Other legally permitted mechanisms.

Users may request additional information about the applicable safeguards by contacting LÜNNE.

 

9. Rights of data subjects

Andorran data protection regulations grant data subjects various rights against the data controller. The APDA identifies, among others, the rights of access, rectification and the other rights provided for by the LQPD.

Data subjects may exercise, where applicable:

Right of access

To know whether LÜNNE is processing their personal data and to obtain information about the processing.

Right of rectification

To request the correction of inaccurate or incomplete personal data.

Right of erasure

To request the deletion of personal data where the legally established requirements are met.

Right to object

To object to the processing of data in certain cases.

Right to restriction of processing

To request that processing be restricted in the circumstances provided for by the regulations.

Right to data portability

To receive certain personal data in a structured, commonly used and machine-readable format, where applicable.

Right to withdraw consent

Where processing is based on consent, the data subject may withdraw it at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal.

Rights relating to automated decisions

Where applicable, the data subject may exercise the rights recognised by the regulations regarding automated individual decisions.

 

10. How can these rights be exercised?

The data subject may exercise their rights by sending a request to:

INVESTNOA WELLNESS, SLU · LÜNNE
Carrer dels Paraires, 21
AD700 Escaldes-Engordany
Principality of Andorra
Email: hello@lunnecircle.com

The request must sufficiently identify the data subject and indicate the right they wish to exercise.

Where there are reasonable doubts about the identity of the person making the request, LÜNNE may request the additional information strictly necessary to verify it.

 

11. Complaints to the Andorran Data Protection Agency

If a person considers that the processing of their personal data does not comply with applicable regulations, they may lodge a complaint with the Andorran Data Protection Agency (APDA), the supervisory authority for data protection in the Principality of Andorra.

Without prejudice to this right, we recommend contacting LÜNNE beforehand so that we can review and resolve any matter relating to the processing of personal data.

 

12. Information security

INVESTNOA WELLNESS, SLU will adopt appropriate technical and organisational measures to protect personal data against:

• Unauthorised access.
• Loss.
• Alteration.
• Destruction.
• Improper disclosure.
• Unlawful processing.

These measures will be established taking into account the nature of the information processed, existing risks, the state of technology and the characteristics of the services provided.

 

13. Accuracy and updating of data

The user guarantees that the personal data provided is true, accurate, complete and up to date.

It will be the user’s responsibility to notify LÜNNE of any changes necessary to keep the information up to date.

Where a user provides personal data of third parties, they must have a legitimate basis for doing so and must comply, where applicable, with the relevant information obligations.

 

14. Third-party services and links

The website may include links to or integrations with services provided by third parties.

When the user accesses these services, the processing of their data may be subject to the privacy policy of the relevant third party.

INVESTNOA WELLNESS, SLU will not be responsible for the privacy practices of independent third-party websites or platforms.

 

15. Amendment of this Privacy Policy

INVESTNOA WELLNESS, SLU may amend or update this Privacy Policy where necessary to adapt it to:

• Legislative or regulatory changes.
• Criteria issued by the competent authorities.
• New data processing activities.
• The addition of products or services.
• Technological changes.
• The evolution of LÜNNE’s activity.

Where amendments are material, users will be informed through appropriate means.

The current version will at all times be the one published at lunnecircle.com.

 

16. Privacy contact

For any query relating to personal data protection:

INVESTNOA WELLNESS, SLU · LÜNNE
Carrer dels Paraires, 21
AD700 Escaldes-Engordany
Principality of Andorra

Tax ID (NRT): L-721791-H
Email: hello@lunnecircle.com
Telephone: +376 646 111

Last updated: August 2026