Privacy Policy

Last updated: 29 April 2026

The short version: PositionPro does not collect, transmit, or store any personal data. All application data is stored locally on your computer. We have no servers receiving your data, no analytics, no tracking, and no advertising. The positionpro.uk website does not even keep access logs — we don't record your IP, pages requested, or any other visit data. We cannot see your data because we never receive it.

1. Who this policy applies to

This Privacy Policy is published by Lunaire Labs Limited ("Lunaire Labs", "we", "us") and covers:

Although Lunaire Labs is established in the United Kingdom and the UK GDPR is the primary regulatory framework for our processing, PositionPro is offered to users worldwide through the Microsoft Store, including the European Economic Area. Where you are located in the EEA, the EU General Data Protection Regulation (Regulation (EU) 2016/679, "EU GDPR") also applies in parallel to the limited processing described in this policy.

2. Data Controller

For the purposes of the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR, where applicable to EEA users) and the Data Protection Act 2018, the data controller is Lunaire Labs Limited, a company registered in England and Wales (company no. 17137604), the publisher of PositionPro. Lunaire Labs Limited is not VAT-registered. Registered office and other statutory details are publicly available on the Companies House register at Companies House. Contact: .

In practice, because PositionPro does not collect, receive, or process any personal data on any Lunaire Labs server — and because the positionpro.uk website retains no access logs or other record of your visit (see Section 8(a)) — the obligations of a data controller in respect of personal data are minimal. All app processing occurs exclusively on your Windows PC under your sole control. This policy is provided in the interests of full transparency.

3. Data We Collect

We collect no personal data whatsoever. Specifically:

Data TypeCollected?Details
Name, email, addressNoNever requested, never stored
Device identifiersNoNo hardware IDs, UUIDs, or fingerprints
IP addressNoSoftware makes no independent network connections
Usage/behavioural dataNoNo analytics, telemetry, or event tracking
Crash reportsNoNo crash reporting SDK or service
Location dataNoNever requested
Cookies or tracking pixelsNoNot applicable (desktop app)
Advertising identifiersNoNo advertising SDK
Payment informationNoHandled entirely by the Microsoft Store

4. Data Stored Locally on Your Device

PositionPro stores the following data locally in your Windows user profile directory (%AppData%\PositionPro\). This data never leaves your computer:

None of this data constitutes personal data under the UK GDPR. It contains no names, identifiers, account details, or information that could be used to identify you.

5. No Independent Network Communication

PositionPro does not independently make any network connections. The Software does not contact any server, API, cloud service, or remote resource. No data — personal or otherwise — is ever transmitted by the Software. All core functionality operates entirely offline.

The Software includes a convenience menu option that opens the Microsoft Store's Downloads and Updates page, allowing you to check for available updates. This action launches the Microsoft Store application — it is not a network connection made by PositionPro itself. Any network activity involved in checking for or downloading updates is performed by the Microsoft Store and is subject to Microsoft's Privacy Statement.

6. Analytics, Tracking, and Advertising

PositionPro does not include, integrate, or utilise any of the following:

7. Third-Party Services

(a) Microsoft Store

If you purchase PositionPro through the Microsoft Store, that transaction is processed and managed entirely by Microsoft Corporation. Microsoft may collect data in accordance with their own privacy policy. We do not have access to your payment details, Microsoft account information, or any personal data held by Microsoft. Please refer to the Microsoft Privacy Statement for details.

8. Website Visitors

When you visit the PositionPro website (positionpro.uk), the following applies:

(a) Web Server Logs

We do not retain access logs of your visit. Our web server (nginx) is configured with access_log off for positionpro.uk, which means no per-request log line — including your IP address, the page you requested, the time of your visit, the referring URL, or your user-agent string — is written to disk for any visit. Routine error events that would normally include client IPs are also discarded (error_log /dev/null crit); only critical-level events such as nginx startup or fatal server errors reach the global error log, and those entries are not associated with any individual visitor.

Because no personal data is collected in connection with your visit, no Article 6 legal basis is required for this processing — there is no processing of personal data to base. Your IP address may transit the server in memory while a TCP connection is open, in the same way it must transit any router between you and the server, but it is not recorded, retained, analysed, profiled, shared, or used for any purpose.

Hosting provider. The positionpro.uk website is hosted by Hostinger International Ltd on a virtual private server currently located in Manchester, United Kingdom. Hostinger does not receive any personal data from us in connection with your visit, because we collect none. Hostinger's own infrastructure logging (e.g. firewall, DDoS protection) is governed by their privacy policy and is outside our control.

(b) Fonts

Fonts used on this website (Manrope) are self-hosted by Lunaire Labs and served from the same domain as the rest of the site. No third-party font CDN is contacted. The PositionPro desktop application uses native Windows system fonts only.

(c) Microsoft Store Badge

Pages that link to the Microsoft Store display the official "Get it from Microsoft Store" badge. This badge is provided by Microsoft and is loaded from get.microsoft.com. When your browser loads the badge script or you click the badge, your IP address and standard HTTP headers may be visible to Microsoft. An anonymous campaign identifier is attached to the link so that, when you click through, Microsoft's analytics can attribute the visit to the referring page — this is an aggregated, non-personal measurement and contains no information about you. All such processing is governed by Microsoft's Privacy Statement. Lunaire Labs Limited does not receive your IP address, browser data, or any individually identifiable click data.

(d) Cookies and Tracking

The PositionPro website does not use cookies, local storage, session storage, or any other browser-based tracking mechanism. No consent banner is displayed because none is required.

(e) No Analytics or Advertising

The website does not use any analytics services (e.g., Google Analytics), advertising networks, social media tracking pixels, heat mapping tools, A/B testing frameworks, or any other form of visitor tracking or behavioural profiling.

9. Children's Privacy

PositionPro collects no personal data from anyone, including children under 13 (the UK age of consent for information-society services under s.9 Data Protection Act 2018). Users in EU jurisdictions where the age of consent under Article 8 UK/EU GDPR is set higher (up to 16) must meet that local minimum. No age-verification mechanism is necessary because no personal data is collected on our end. If you believe that a child has somehow provided personal data to us, please contact us at and we will investigate.

10. Your Rights Under UK GDPR and EU GDPR

Under the UK GDPR, the EU GDPR (where you are located in the EEA) and the Data Protection Act 2018, you have the following rights in relation to your personal data:

In practice, these rights have little to act on because Lunaire Labs does not collect, receive, or hold any personal data from you. PositionPro does not transmit any personal data to Lunaire Labs — all app data is under your sole control on your PC and can be removed at any time (see Section 11). The positionpro.uk website does not retain access logs or any other record of your visit, as described in Section 8(a). If you nonetheless wish to make a formal data-protection request, email with "Data request" in the subject and we will respond within one month as required by Article 12(3) UK GDPR / EU GDPR.

11. Data Deletion

Since all data is stored locally on your device, you have complete and sole control over it at all times. You can delete all PositionPro data by:

We cannot delete your data for you because we do not have it and have never had it.

12. Data Security

Because PositionPro stores all data locally and does not transmit personal data, the security of your data is determined by the security measures on your own device (e.g., Windows login credentials, disk encryption, firewall settings). We recommend that you keep your operating system and security software up to date.

13. Data Breach Notification

PositionPro does not collect, process, or store personal data on any server or cloud service. The Software makes no independent network connections and all data is stored locally on your device. Accordingly, a data breach originating from the Software is not possible. In the unlikely event that the Developer becomes aware of any security incident affecting its website or infrastructure, the Developer will promptly assess the situation and, if required by applicable law, notify affected individuals and the Information Commissioner's Office (ICO) within the timeframes prescribed by the UK GDPR.

14. International Data Transfers

Lunaire Labs does not transfer any personal data internationally or otherwise, because PositionPro does not collect personal data and the Software makes no independent network connections. The positionpro.uk website retains no access logs or other record of your visit. As a matter of factual disclosure, the website is operated by Hostinger International Ltd from a data centre in Manchester, United Kingdom (see Section 8(a)). The Microsoft Store may perform its own network activity when checking for or delivering updates; this is governed by Microsoft's Privacy Statement.

15. Legal Basis for Processing

Under Article 6 of the UK GDPR / EU GDPR, any processing of personal data requires a legal basis. Because Lunaire Labs does not collect or process personal data — including IP addresses or other web-visit data — on any server or remote system in connection with PositionPro, no legal basis is required on our part. This section is included for completeness and transparency.

16. Complaints

If you have any concerns about how your data is handled, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

If you are located in the European Economic Area, you may also lodge a complaint with the data protection supervisory authority of your country of habitual residence, your place of work, or the place of an alleged infringement, in accordance with Article 77 EU GDPR. A list of EEA supervisory authorities is maintained by the European Data Protection Board at edpb.europa.eu.

We would appreciate the opportunity to address your concerns before you contact a supervisory authority. Please reach out to us first at .

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The most current version will always be available at positionpro.uk/privacy. Material changes will be indicated by updating the "Last updated" date at the top of this page. Since we do not collect any contact information, we cannot notify you directly of changes; we encourage you to review this page periodically.

18. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: