Privacy Notice

This Privacy Notice ("Notice") describes how Lumina Wallet ("Lumina Wallet", "we", "us", "our", "ourselves") collects and processes your Personal Data ("you", "your") through our websites (https://luminawallet.org/) and applications or other services (collectively, together with our websites and apps, our "Services"). In addition, we may also process your Personal Data for specific purposes, where applicable, such as processing your job applications or administering your employment with us. By using our Services or engaging with us, you consent to the collection, storage, processing, and transfer of your Personal Data as described in this Privacy Notice.

This Privacy Notice applies together with our Terms of Use, any terms of business or other contractual documents, including but not limited to any agreements we may have with you.

1. Our Relationship with You

Your right to privacy and the protection of your Personal Data is important to us. Lumina Wallet is committed to the best practices in privacy, and we will only collect data when it's strictly necessary to provide our Services.

By using Lumina Wallet's Services, including, for example, visiting our website, using our application, interacting on social media or community forum, participating in our offline events (and this list is not exhaustive), you acknowledge and accept the use, disclosure, and procedures outlined in this Privacy Notice.

The following sections provide further details as to how we process your Personal Data through Lumina Wallet as the Data Controller.

2. Collection and Use of Your Personal Data

"Personal Data" is information that may identify an individual or relates to an identifiable individual. This includes information you provide voluntarily to us, information which is collected or created automatically in the natural course of provision of our Services, or otherwise when you contact us. Following best practices in privacy such as data minimisation, we endeavour to collect only the amount of Personal Data that is necessary to provide our Services to our users.

When you Use Our Self-Custody Wallet

As a user of our wallet application, whether through the app or browser extension, you have the option to create or import wallet information, which is stored locally on your device. We do not collect email addresses or any other categories of personal data for this purpose.

Below, we present a table that outlines the personal data the application uses and the purposes for processing that information.

When You Visit Our Website

When you use our website, read our blog, request customer support, participate in our community forum or campaigns, you may provide personal data. Please note that we do not ask for your wallet information for this purpose.

Recruitment and Employment

If you apply for a position with us or become employed by us, we collect and process your Personal Data for purposes including recruitment, onboarding, employment administration, compliance with legal obligations, and other employment-related activities. Personal Data may be collected directly from you, from third-party recruitment agencies, or from publicly available sources such as LinkedIn.

We process the following categories of Personal Data for recruitment and employment purposes:

1. Contact Information: We will collect your name, email address, and other relevant contact details to communicate with you about your job application and, where applicable, your employment.
2. Education and Employment Information: We collect your Curriculum Vitae (CV), resume, LinkedIn profile, academic certificates and transcripts, employment history, and (where relevant) salary and bonus details. We use this information to assess your suitability, process your application, conduct background checks, and manage your employment relationship.

During recruitment, we rely on your consent to process your Personal Data. Once employed, we rely on the necessity to perform your contract, comply with legal obligations, and our legitimate interests in managing the employment relationship. If we are unable to offer you a position, we may retain your personal data for up to two years based on our legitimate interest in considering you for future roles, unless you object.

Participation in Our Events

When you register or attend our event, we collect some Personal Data to help manage your participation. This may include your name, contact details, company information, job title, industry, location, LinkedIn profile, payment details, and billing address.

We use this information to:

1. Process your event registration and ticketing
2. Communicate important updates about the event
3. Analyze participation to improve future events

We process your Personal Data based on the agreement you enter when registering, and on our legitimate interest in delivering and improving our events. Please note that photography and videography may take place during the event for promotional and archival purposes. By attending our event, you agree that Lumina Wallet and our partners may use your image in marketing materials, social media posts, or future event promotions.

Push Notification

We may send you optional push notifications through our app to provide alerts, updates, or news relevant to your interests. These notifications are sent based on your choices, which you can manage or withdraw at any time through the notification settings within the app.

Biometric Authentication (Face ID & Fingerprint Scan)

We offer optional biometric authentication (such as Face ID or fingerprint recognition) as a secure and convenient method for logging into your wallet. If you choose to enable biometric authentication, your biometric data is processed directly on your device using its built-in security features on the mobile operating system. Your biometric authentication information is never transmitted to our servers or any third party.

Interaction with Our AI Services

When you use our Services that involve artificial intelligence ("AI Services"), such as our AI Chatbot, we process the content you provide in your inputs or feedback so that we can respond and deliver the AI functionality you have chosen to use.

Voice Input (Optional): Where available, you may choose to interact with the AI Services using voice input. Your voice is processed in real time to create a text transcription, which is then handled in the same way as any other text-based input.

We process this content on the basis of contract performance, as it is necessary to provide the AI Services you request. To deliver these features, we may use trusted third-party AI service providers acting on our instructions. They are bound by contractual and confidentiality obligations and are not permitted to use your data for their own purposes.

Personal Data collected automatically from you

In certain circumstances, we may collect Personal Data automatically from you when you use our Services, in accordance with applicable laws. This may include device, log, and usage data, which helps us enhance your experience, provide customer support, improve the performance of our sites and Services, and safeguard your account by detecting unauthorized access and preventing fraud.

When you use our self-custody wallet or visit our website, your IP address may be processed on a transient basis. This limited processing is used solely (a) to route traffic and facilitate service localization in accordance with regulatory requirements, and (b) to establish secure connections with third-party platforms when you choose to connect with them. Your privacy remains protected at all times, and we do not log, retain or otherwise access your IP address beyond these temporary uses.

Aggregated and Anonymized Data

We also use aggregated or anonymized data to improve our Services. This involves analyzing general usage trends, gathering feedback, and conducting research without identifying individual users. We may also share or disclose such aggregated or anonymized data with trusted service providers, business partners, or other third parties for purposes including demonstrating the performance of our Services, supporting business development, or informing strategic decisions.

We will not use your Personal Data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest to do so.

3. Use of Cookies and Analytics

We use a minimal number of technical cookies and analytics tools required to deliver our services and understand how visitors use our website. We do not use advertising cookies, cross-site tracking, or third-party ad networks.

Cookies and tools currently used:

• Technical session cookies — set by our hosting provider Emergent to keep our site secure and functional (login state, security tokens). Duration: session or up to 30 days.
• PostHog product analytics — self-hosted analytics that measure page views, feature usage and errors. IP addresses are truncated. No advertising profiling. Data retained for up to 12 months.
• Language preference cookie — stores your selected language (i18nextLng). Duration: 12 months.

What we do NOT do:

• ❌ No advertising cookies or tracking pixels
• ❌ No cross-site tracking
• ❌ No selling of user data
• ❌ No fingerprinting

Depending on your region, a cookie banner may allow you to accept or refuse analytics cookies. Technical cookies necessary for the service to function do not require consent under most jurisdictions (GDPR Article 6(1)(f), ePrivacy Directive Article 5(3)).

You can also disable cookies through your browser settings at any time.

4. How and Why We Share Your Data

Information about our users is an important part of our business and we are not in the business of selling our user's Personal Data to others. We may transfer Personal Data to our service providers or third parties in connection with Lumina Wallet's operation of its business, as certain features on Lumina Wallet rely on various third-party products and services (collectively "Third Party Services").

Third party services providers only have access to Personal data, such as your public Wallet addresses, to perform their functions, provide services and may not use it for other purposes.

We may also share personal data with the following persons or in the following circumstances:

• Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy notice.
• Legal Authorities: We may be required by law or by Court to disclose certain information to relevant regulatory, law enforcement and/or other competent authorities. We will disclose Personal Data to legal authorities to the extent we are obliged to do so according to the law.
• Protection of Us and Others: We will share Personal Data outside of Lumina Wallet if we have a reasonable belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to cooperate with law enforcement; to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of Lumina Wallet, our employees, our users, or others.

Our Services and websites may contain links that enable you to connect with various third-party websites, applications, and other external platforms. These Third Party Platforms act as independent data controllers and their processing of your Personal Data will be subject to their privacy notices and policies. This Privacy Notice does not cover the privacy practices of these Third Party Platforms.

5. International Transfers of Personal Data

We maintain servers hosted by our trusted service providers, and your information may be processed on servers located outside of your country of residence. In instances where we process your Personal Data on servers outside your country or transfer it to third countries, we implement appropriate technical, organizational, and contractual safeguards to ensure that your Personal Data remains protected. This includes, but is not limited to, the use of Standard Contractual Clauses.

6. Data Security

We recognize that information security is a crucial component of data privacy. We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. Although no data transmission can be guaranteed to be entirely secure, we employ a range of commercially reasonable physical, technical, and procedural measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.

If you are our self-custody wallet user, please be aware that your wallet information and private key are stored locally on your device and remains under your personal control. To protect your wallet information, ensure that access controls and a passcode are enabled on both your device and the wallet application.

7. Data Retention

We keep your Personal Data to enable your continued use of our Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice as may be required by law such as for tax and accounting purposes, or to resolve disputes and/or legal claims or as otherwise communicated to you.

When we have no ongoing legitimate business or legal requirement to retain your Personal Data, we will either delete or anonymise such information, or, if this is not possible, then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Please note that even if you delete your wallet addresses from the Lumina Wallet mobile application or uninstall it from your device, the right to deletion/erasure of your personal data is not absolute in some circumstances. This is because blockchains are public decentralised networks and blockchain technology does not generally allow for data to be deleted.

8. What Privacy Rights Do You Have?

Subject to applicable law, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to request access to, correct, and delete your personal data, and to ask for data portability. In addition, when you consent to our processing of your personal data for a specified purpose, you may withdraw your consent at any time.

• Right to access: You have the right to obtain a copy of the Personal Data that we hold about you as well as certain information related to its processing.
• Right to correct: You can request the rectification of inaccurate Personal Data and you may also provide additional information to complete your records.
• Right to delete: You can request the deletion of your Personal Data. Please note that Personal Data may still need to be retained for compliance with applicable legal obligations.
• Right to object: You can object, for reasons relating to your situation, to the processing of your Personal Data.
• Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your Personal Data by us, provided there are valid grounds for doing so.
• Right to withdraw consent: You have the right to withdraw your consent and request us to stop collecting, using and/or disclosing your Personal Data. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal.
• Right to portability: You can also request us to provide your information in a structured way so you can send it to another service provider.

We will respond as quickly as possible. If we are unable to respond within 10 working days, we will inform you in writing of the timeline for our response.

9. Children

We are especially sensitive about children's information. Our Services are not targeted towards children, and our users must be at least eighteen (18) years old to use our services. We do not knowingly solicit data from or market to any persons under 18 years of age. If we become aware that we have collected Personal Data from someone under 18, we will deactivate the account in question and take reasonable measures to promptly delete all such data from our records.

10. Conditions of Use, Notices and Revisions

If you choose to use our Services, your use and any dispute over privacy is subject to this Privacy Notice and our Terms of Use. We reserve the right to update and revise this Notice at any time. We will review this Privacy Notice from time to time to make sure it complies with applicable laws and conforms to changes in our business. If we do revise this Privacy Notice, we will update the "Last Updated" date at the beginning of this Notice.

Please review this Privacy Notice regularly to ensure that you are aware of its terms. Your continued use of our Services after an amendment to our Privacy Notice constitutes your acceptance to the amended terms.

11. Privacy Team Contact Information

If you have any privacy related questions, please contact us through our online form. For any other Wallet App-related inquiries and customer support, please contact our support for assistance at support@luminawallet.org.

Thanks for reading our Privacy Notice!