LunarG, Inc. and our subsidiaries and affiliates (collectively, “LunarG,” “we,” “our,” or “us”) is committed to protecting your privacy. LunarG has prepared this privacy policy (this “Privacy Policy”) to describe to you our practices regarding the collection, use, and sharing of personal information in connection with our website located at lunarg.com and our other websites that link to this Privacy Policy (collectively, the “Website”), our online services, and our marketing communications (together with the Website, the “Service”), as well as certain offline activities.

We may change this Privacy Policy from time to time by posting the updates to this page. We advise you to review this page regularly to stay informed and to make sure that you keep up to date with any changes. If we materially change this Privacy Policy, we’ll let you know by updating the Privacy Policy and its modification date on the Website. If required by law, we will notify you about material changes by email, through posting a notification on the Service, or through another manner that is reasonably expected to reach you. In all cases, your continued use of the Service following posting of changes constitutes your acceptance of such changes.

Collection

Categories of Personal Information.  The following are categories (with non-exhaustive examples) of personal information we may collect about you.

Categories	Examples
A. Individual Identifiers and Demographic Information	Contact data, such as first and last name, postal address, telephone number, and email address. Business data, such as your company name, business address, and business telephone number. Online identifiers, such as IP address and other unique identifiers. Device data, such as device ID, computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, and general location information such as city, state or geographic area. Account data, such as username, password, and profile information.
F. Commercial Information	Transaction data, such as order history and other records of products or services you have purchased from us, including your consuming histories or tendencies. Marketing data, such as your preferences for receiving marketing communications. Online activity data, such as browsing history, search history, IP address, operating system, browser type, identifiers for your computer or mobile device, your visit date and time, the website you visited before browsing to our website, your visit behavior and other information about your interaction with the Service.
G. Internet or Network Activity	Online activity data Device data Online identifiers
H. Professional or Employment-Related Information	Information collected in connection with your employment inquiries, such as information you provide when contacting us about potential opportunities.
J. Inferences Drawn from Personal Information	May be derived from your transaction data, business data and other information we collect as part of the Service.

Sources of Personal Information. We obtain the categories of personal information listed above via the following categories of sources:

• Personal Information you Provide to Us. You may provide us with personal information when subscribing to our email newsletter, completing the Contact Us form, submitting a customer service request, creating an account on the Service, or otherwise.
• Automatic Collection. LunarG and our service providers or partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Service and other sites and online services, such as the online activity data and device data listed above. Like many online services, we may use cookies and similar technologies to facilitate some of our automatic data collection described above, such as:
  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
  • Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Services, and remember your preferences.
  • Session-replay technologies, which are third-party software used to record a video replay of users’ interactions with the Service. The video replay may include users’ clicks, mouse movements, scrolls, mobile app touches, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Service, understand how users interact with and use the Services, and identify areas for improvement.
• For example, we receive personal information about you when you navigate to the Website and use the Service.  Like many online companies, we collect some personal information automatically using cookies or other online tracking technologies as described in our Cookie Policy, available at https://www.lunarg.com/cookie-policy/.
• Third Parties. We may receive personal information about you from other third party sources.  For example, we may receive personal information from our affiliates, business partners, social media sites, or companies that provide personal information to supplement what we already know about you. We may merge or combine such personal information with the other personal information we collect about you.

Use

We use personal information for various purposes, including for the purposes set out below and as otherwise described in this Privacy Policy or at the point of collection:

To Provide Our Products and Services. LunarG’s primary purpose in collecting information is to provide you with products and services, including to provide you with content, features, products, and services that you request, process your orders and transactions, facilitate delivery, establish and maintain your account on the Service, respond to your inquiries and requests, communicate with you about the Service (including by sending announcements, updates, security alerts, and support and administrative messages), respond to your inquiries for customer support, including to investigate and address your concerns and monitor and improve our responses, understand your interests, personalize your experience on the Service, and deliver information that match your interests.

For Research and Development. We may also use information to conduct research and analysis, such as to improve the Website or our products and services, to understand and analyze the usage trends and preferences of our users, and to develop new features, functionality, and services.

To Create Anonymous Data.  We may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

For Marketing and Advertising.  We, our business partners and our third party advertising partners may collect and use your personal information for direct marketing and interest-based advertising purposes.

• Direct marketing.  We may send you LunarG-related or other direct marketing communications as permitted by law.  You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.
• Interest-based advertising.  We also contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.

To Comply with Laws and Regulations.  We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For Compliance, Fraud Prevention, Safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Service, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Service; and (e) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent.  In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required

Sharing

We may share your personal information with the entities and individuals listed below or as otherwise described in this Privacy Policy or at the point of collection:

Related Companies. LunarG may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with LunarG).

Service Providers. We may disclose personal information to service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and other service providers for legitimate purposes permitted by applicable law.

Advertising Partners. We may also share personal information collected about you with third parties that collect information about your activity on the Website and other online services to help us advertise our products and service, and/or use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms.

Business Partners.  Our business partners, such as those that have joined our programs, participate in our events, or jointly offer content, promotions and other service offerings with us.

Professional Advisors. We may share your personal information with our professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and Others. There may be instances when LunarG may disclose personal information without providing you with a choice in order to protect the legal rights of LunarG, other affiliated companies or their employees, agents, and contractors; to protect the safety and security of other Users; to protect against fraud or for risk management purposes; to comply with the law or legal process; or as described above in the section titled “For Compliance, Fraud Prevention, Safety.”

Business Transferees. We may disclose or transfer your personal information to third parties as part of a business transaction (or potential transaction) involving a merger, sale of company shares or assets, financing, acquisition, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

Your Choices

You can make the following choices with respect to your personal information:

• Access Your Personal Information. If you would like to know whether we have collected personal information about you, please send us the activities and services that you participated in on the Website that requested personal information. After reviewing the relevant databases, we will confirm whether we have collected such information about your and provide a list of your personal information that we have on file.
• Correct Your Personal Information. If your personal information is incorrect, you may correct the personal information by sending a written request for correction to the address below. Your request must include: (a) all of the incorrect personal information that you wish to change, (b) the corrected personal information, and (c) your signature authorizing such changes. We will then correct the personal information in our database and send a written confirmation to you.
• Opt-Out of Marketing Communications. If you wish to stop receiving email marketing communications from us, please contact us at the address listed below or use the unsubscribe link at the bottom of any email marketing communication. If you opt out, we may still send you non-promotional communications, such as those about your account.
• Do Not Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, LunarG does not modify your experience based upon whether such a signal is broadcast. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Cookies.  Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings.  For more details, see the “Your Choices” section of our Cookie Policy https://www.lunarg.com/cookie-policy/.
• Advertising choices. You may opt-out of interest-based advertising. For more details, see the “Your Choices” section of our Cookie Policy https://www.lunarg.com/cookie-policy/.
• Declining to provide information. We need to collect personal information to provide certain services.  If you do not provide the information requested, we may not be able to provide those services.

If you request your registration information be changed or if you unsubscribe from communications, we may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access. When updating or deleting your personal information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable law.

Security

We use reasonable measures to help prevent personal information from becoming disclosed to individuals who are not described in this Privacy Policy. While LunarG attempts to protect the information in our possession, no security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.

Links

This Website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our Users to be aware when they leave our Website and to read the privacy statements of any other site that collects personal information.

International Operations

LunarG is based, and the Website is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

California Residents

This section applies only to residents of California and supplements the information provided elsewhere in this Privacy Policy. It describes how we collect, use, sell, share, and retain personal information of California residents, and their rights with respect to that personal information. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act (as amended, the “CCPA”) but does not include information exempted from the scope of the CCPA.

Personal Information Collected and Purposes of Collection and Use.  The section above titled “Collection” describes the personal information we collect, or have collected in the 12 months preceding the effective date of this Privacy Policy, and the categories of sources of such personal information.  These categories are used for the business/commercial purposes described in the section titled “Use,” above.

To the extent that we collect sensitive personal information, we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Website, detect security incidences and prevent fraud, and to verify and maintain the quality of the Website). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

Personal Information Disclosed for a Business Purpose, “Sold,” or “Shared.” Each of the categories of personal information listed above may have been disclosed for business purposes in the preceding 12 months to any of the third parties set forth in the section titled “Sharing,” above, which describes the categories of third parties to whom the personal information was disclosed.

The CCPA defines a “sale” of personal information to mean when a business discloses a California resident’s personal information to a third party for monetary or other valuable consideration. Where a business discloses personal information for purposes of cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under the CCPA.

In the 12 months preceding the effective date of this Privacy Policy, we have “sold” or “shared” Individual Identifiers and Demographic Information (online identifiers and device data), Commercial Information (online activity data), and Internet or Network Activity with Service Providers and Advertising Partners for purposes of advertising our business on other sites and services (including tracking the success of our advertising campaigns), identifying new users, and measuring activity on our Website, and as further described in this Privacy Policy under in the section above titled “Interest-based advertising.”

We do not knowingly “sell” or “share” the personal information of California residents under 16 years of age.

Retention of Personal Information. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Notice of Disclosure for Direct Marketing.  Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by writing us at LunarG, Attn: Privacy, P.O. Box 770224, Steamboat Springs, Colorado 80477.

Your California Privacy Rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Know/Access.  You can request the following information about how we have collected, and used, your Personal Information:
  • The categories of personal information that we have collected.
  • The categories of sources from which we collected personal information.
  • The business or commercial purpose for collecting, selling, or sharing personal information.
  • The categories of third parties with whom we disclose personal information.
  • A copy of the personal information that we have collected about you.
• Deletion.  You can ask us to delete the Personal Information that we have collected from you.
• Correction. You can ask us to correct inaccurate personal information that we maintain about you.
• Opt-out of sales/sharing. If we “sell” or “share” your personal information, you can opt-out.
• Nondiscrimination.  You are entitled to exercise the rights described above free from discriminatory treatment.

How to Exercise Your California Privacy Rights. You may request to exercise your California privacy rights described above by calling us at (800) 228-1105 or emailing [email protected].

We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise your know/access, correction, or deletion rights. The identity verification process may vary based upon how you submit your request. We may also contact you to ask you for further information in relation to your request to speed up our response.

Consistent with California law, You may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

European Users

The information provided in this “Notice to European Users” section applies only to individuals in the European Union, the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”).

Personal information.  Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is LunarG, P.O. Box 770224, Steamboat Springs, Colorado 80477.

Data Protection Representative. LunarG, which processes the personal data of individuals in the European Union and the UK, in the role of data controller, has appointed DataRep as its Data Protection Representative for the purposes of GDPR.

LunarG takes the protection of personal data seriously and has appointed DataRep as their Data Protection Representative in the European Union, Switzerland, and the UK so that you can contact them directly in your home country. If you want to raise a question to LunarG, or otherwise exercise your rights in respect of your personal data, you may do so by contacting DataRep. Click here to learn how to contact DataRep.

Our data protection representative in Switzerland may also be contacted by sending an email to DataRep at [email protected] and quoting “LunarG, Inc.” in the subject line, contacting DataRep via the online webform at www.datarep.com/data-request, or by mailing your inquiry to the following address: DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland.

Legal bases for processing.  The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below.  We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at [email protected].

Processing Purpose (see the “Use” section above for details about each processing purpose)	Legal Basis
To Provide Our Products and Services	Processing is necessary to perform the contract governing our operation of the Sites or the provision of the Service, or to take steps that you request prior to engaging our services.  Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.
For Marketing and Advertising	Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business, and showing you tailored relevant content.
For Research and Development To Create Anonymous Data For Compliance, Fraud Prevention and Safety	These activities constitute our legitimate interests.
To Comply with Laws and Regulations	Processing is necessary to comply with our legal obligations.
With Your Consent	Processing is based on your consent.  Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.

Use for new purposes.  We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information.  Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.

Retention.  LunarG retains your personal information:

• For so long as your account is active or as needed to provide you with services or to fulfill our contractual obligations;
• As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
• For so long as is necessary for the legitimate purposes for which we collected such personal information.

Your rights.  European data protection laws give you certain rights regarding your personal information.  You may ask us to take the following actions in relation to your personal information that we hold:

• Access.  Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct.  Update or correct inaccuracies in your personal information.
• Delete.  Delete your personal information.
• Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict.  Restrict the processing of your personal information.
• Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to [email protected] or our postal address provided in the “Contact” section below.  We may request specific information from you to help us confirm your identity and process your request.  Applicable law may require or permit us to decline your request.  If we decline your request, we will tell you why, subject to legal restrictions.  If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.  In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Cross-Border Data Transfer.  If we transfer your personal information out of Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so.  Please contact us at [email protected] for further information about any such transfers or the specific safeguards applied.

Contact

If you have questions or concerns about our privacy practices or this Privacy Policy, please contact us via telephone at (800) 228-1105 or via [email protected]. You may also write to us via postal mail at:

LunarG
Attn: Privacy
P.O. Box 770224
Steamboat Springs, Colorado 80477
USA