Privacy Policy

Our contact details:

Name: LUMINARY INC Limited (“us”, “we”, or “our”)
Address: 7 Bell Yard, London, England, WC2A 2JR
DPO E-mail: dpo@luminaryinc.com

Introduction

We own and operate the website at https://luminaryinc.com/ and https://app.luminaryinc.com/ (the
“Websites”) and its content, where we collect and process particular personal data in order to be able
provide you our services via Websites (the “Services”).

It is important that you know exactly what we do with the personal data you make available to us, why
we collect it and what it means for you. This document outlines our approach to Data Privacy to fulfil
our obligations under the UK GDPR (UK General Data Protection Regulation 2021) and DPA (Data
Protection Act 2018).

This Privacy Policy describes our approach regarding the collection, use, and disclosure of personal
data when you use our Services and the choices you have associated with that data.

We use your data to provide and improve the Services. By using the Services, you agree to the
collection and use of information in accordance with this Policy. Unless otherwise defined in this
Policy, terms used in this Policy have the same meanings as in our Terms and Conditions, available at
https://luminaryinc.com/terms-conditions/

Our Services do not address anyone under the age of 18 (“Children”). We do not knowingly collect
personally identifiable information from anyone under the age of 18. If you are a parent or guardian
and you are aware that your Children have provided us with personal data, please contact us. If we
become aware that we have collected personal data from children without verification of parental
consent, we’ll take steps to remove that information from our servers.

Our Services may contain links to other sites that are not operated by us. If you click on a third-party
link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of
every site you visit. We have no control over and assume no responsibility for the content, privacy
policies or practices of any third-party sites or services.

We may also collect information on how the Services are accessed and used (“Usage Data”). This
Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of our Services that you visit, the time and date of
your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

For the use of “Cookies” please refer to our Cookies Policy available at:
https://luminaryinc.com/cookie-policy/

The type of personal information we collect

We collect and process different types of information for various purposes to provide and improve our
Services to you. The personal data we would like to collect from you may include, but is not limited to:

First Name and Surname;
Place and date of birth;
Tax residency (taxpayer number and country);
Email address;
Telephone number;
Address;
Data gained from your identity documents, including your personal ID number;
Information on source of income;
Other personal information such as telephone recordings; security questions, user ID;
Log-in credentials and data;
Biometrical data (during verification process);
Answers to requests and surveys;
Information about your finances, that includes bank accounts you have and details of
transactions you made, in particular, we also get your transaction data from EMERALD24 (see below);
How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following
reasons:

to provide and maintain the Services;
to verify your identity;
to notify you about changes to our Services;
to allow you to participate in interactive features of our Services when you choose to do so;
to provide customer care and support;
to provide analysis or valuable information so that we can improve the Services;
to monitor the usage of the Services;
to detect, prevent and address technical issues;
to comply with our legal obligations for prevention of fraud, money laundering, counter
terrorist financing and misuse of the Services;
where requested by law enforcement for investigation of crime

Use of personal information

The personal data we collect from you is used for, but not limited to:

providing the Services, including your account set up and its administration;
personalisation of content, business information and user experience;
delivering marketing and events communication;
carrying out polls and surveys;
internal research and development purposes;
legal obligations (e.g. prevention of fraud);
meeting internal audit requirements

Transfer of the information

Your information, including personal data, may be transferred, and maintained outside of your state,
province, country or other governmental jurisdiction where the data protection laws may differ than
those in your jurisdiction.

If you are located outside of the UK and choose to provide information to us, please note that we may
transfer the data and process it outside the UK. We will take all steps reasonably necessary to ensure
that your data is treated securely and in accordance with this Privacy Policy and no transfer of your
personal data will take place to an organisation or a country unless there are adequate controls in
place including the security of your data and other personal information.

Your consent to this Privacy Policy followed by your submission of such information represents your
agreement to that transfer.

We also may disclose your personal data in the good faith belief that such action is necessary to:

comply with a legal obligation;
protect and defend the rights or property of us;
prevent or investigate possible wrongdoing in connection with the Services;
protect the personal safety of users of the Services or the public;
protect against legal liability.

You should be aware that customers who, via our Websites, have requested account opening and
have been assigned with account number in the format GBxxEMFGxxxxxxxxxxxxxx although are still
going to access and receive the services through Websites, the electronic money issuance and/or
payment services will be provided by our business partner and service provider – EMERALD
FINANCIAL GROUP (UK) LTD (the “EMERALD24). EMERALD24 is incorporated and registered in
England & Wales with company number 11557885, with its head office at Hamilton House, 1 Temple
Avenue, London, United Kingdom, EC4Y 0HA. EMERALD24 is registered with the Information
Commissioner’s Office (ICO) reference number ZA553246.

As the result EMERALD24 shall gain access to and will use your personal data. Such data includes,
but not limited to your transactions and other operations, payment card data and transactions, log-in
data and communications.

In respect to Services provided in cooperation with EMERLAD24, we are the data processor and
EMERALD24 is the data controller. Where “processor” is responsible for processing personal data on
behalf of a controller, and “controller” in turn determines the purposes and means of processing
personal data.

Your data at EMERELAD24 will be processed according to their Privacy Policy available at
https://emerald24.co.uk/wp-content/uploads/2020/03/EMERALD_Privacy-Policy_Vers01.pdf

We may use third-party Service Providers to monitor and analyse the use of our Services, such as
Google Analytics.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.
Google uses the data collected to track and monitor the use of our Services. This data is shared with
other Google services. Google may use the collected data to contextualize and personalize the ads of
its own advertising network.

You can opt-out of having made your activity on the Services available to Google Analytics by
installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics
JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits
activity.

Grounds for processing of personal data

Under the UK GDPR, the lawful bases we rely on for processing this information are:

your consent. You are able to remove your consent at any time. You can do this by contacting
us;
we have a contractual obligation;
we have a legal obligation;
we have a legitimate interest.

How we store your personal information

Your information is securely stored. We use trusted cloud and data storage service providers. Access
to personal data is divided and assigned only to particular employees according to their job
responsibilities. Where possible we apply data encryption.

The security of your data is important to us but remember that no method of transmission over the
Internet, or method of electronic storage is 100% secure. While we strive to use commercially
acceptable means to protect your personal data, we cannot guarantee its absolute security.

We may employ third party companies and individuals to facilitate our Services, to provide the
Services on our behalf, to perform Service-related services or to assist us in analysing how our
Services are used.

These third parties have access to your personal data only to perform these tasks on our behalf and
are obligated not to disclose or use it for any other purpose.

We will keep your personal data not more than 5 years either from the moment a) you have been
rejected to open an account, or b) business relationship with you is terminated, except in cases where
there is a legal reason to hold it longer (e.g., due to AML reasons, claims, initiated court
proceedings).

We will then dispose of your information by deleting all data from our servers, except for those that
are required to be kept under the regulations.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – you have the right to ask us for copies of your personal information

Your right to rectification – you have the right to ask us to rectify personal information you think is
inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – you have the right to ask us to erase your personal information in certain
circumstances, to learn more or to request such action please follow the link:
https://luminaryinc.com/close-account/

Your right to restriction of processing – you have the right to ask us to restrict the processing of
your personal information in certain circumstances

Your right to data portability – you have the right to ask that we transfer the personal information
you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one
month to respond to you. Please contact us if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us
by emailing support@luminaryinc.com.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF, UK

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Changes to this Policy

We may update this Privacy Policy from time to time. When a material changes to this Privacy Policy
are made, we will notify you with prominent notice as appropriate under the circumstances (e.g. by
displaying a prominent notice on the Websites or by sending you an email).

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy
Policy are effective when they are posted on the Websites.

If you have any questions about this Privacy Policy, please contact us using the e-mail address set
above

This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.

We provide economic infrastructure for the Internet. Businesses of all sizes can our software and services to accept payments and manage their businesses online. Luminary cares about the security and privacy of the personal data that is entrusted to us.

This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us. Please visit the Luminary ‘Privacy’ link on our website for more information about our privacy practices.

“Luminary”, “we”, “our” or “us” means the Luminary entity responsible for the collection and use of personal data under this Privacy Policy. It may differ depending on your country.

“Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP address).

“Services” means the products and services that Luminary indicates are covered by this Policy, which may include Luminary-provided apps. Our “Business Services” are Services provided by Luminary to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services that Luminary directs to individuals (rather than entities) so that those individuals do business directly with Luminary. “Sites” means Luminary and the other websites that Luminary indicates are covered by this Policy. Collectively, we refer to Sites, Business Services, and End User Services as “Services”.

Depending on the context, “you” means End Customer, End User, Representative or Visitor:
When you directly use an End User Service (such as when you sign up for an eWallet, or make a payment to Luminary in your personal capacity), for your personal use, we refer to you as an “End User.”
When you do business with, or otherwise transact with, a Business User (typically a merchant using the Luminary eWallet, e.g. when you buy a pair of shoes from a merchant that uses Luminary for payment processing) but are not directly doing business with Luminary, we refer to you as an “End Customer.”
When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.”
When you visit a Site without being logged into a Luminary account or otherwise communicate with Luminary, we refer to you as a “Visitor.” (e.g. you send Luminary a message asking for more information because you are considering being a user of our products).
Depending on the activity, Luminary acts as a “data controller” or “data processor” and for more information about this and on the Luminary entity that is responsible under this Policy, please refer to our website.
1. Personal data that we collect and how we use and share it

1.1 End Users
We provide End User Services where we do not act as a service provider to Businesses but instead provide the Services directly to you for your personal use (e.g. Luminary eWallet user).

Using Link or Connecting your Bank Account.
Luminary offers you the opportunity to store your payment methods with Luminary so that you can conveniently use it across merchants who are our Business Users – we call this “link”. When you opt-in to the link, you agree to let us store your payment method so that you can more readily make purchases through the link with Business Users of our payment processing Business Services (e.g. name, card number, CVC, and expiration date). When you choose to pay with the link, we will also collect your Transaction Data.
If you choose to share bank account information (including for using the link) with us, Luminary will periodically collect and process your bank account information (e.g. account owner information, account balances, account number and details, account transactions, and in some cases, credentials) until you ask us to disconnect your bank account.

Paying Luminary.
If you are buying goods or services directly from Luminary, we receive Transaction Data. For example, when you make a payment to Luminary, we will collect contact information, payment method information, information about that transaction, and in some cases, shipping information.

Other Services.
We may offer other End User Services directly to you from time to time, including certain financial Services. For information about our collection and use of Personal Data.

More.
Please see below for information about additional types of Personal Data that we may collect, including about online activity.

How we use and share personal data of End User Services.
We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to do business with. The use of this Personal Data is subject to the Business Users’ privacy policies.

Our Business Users.
When you choose to connect your bank account with Luminary, you may also choose to share account information with certain Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.

Transactions.
For payment transactions with the Luminary link, End User Personal Data is shared with others to enable the transaction. For example, when you choose to use a payment method for the transaction with Luminary or with link (e.g. credit card, debit card, buy now pay later, or direct debit), that payment method will receive transaction information that includes your Personal Data. Please review your payment method’s privacy policy to learn more. When you use the Luminary link, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and with your permission, your bank account information. The merchant may share that Personal Data with others (see below regarding End Customers). Please review your merchant’s privacy policy for further information.

Fraud Detection Services.
We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users, and our financial partners, including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction.

Advertising.
We may use your Personal Data to assess your eligibility for and offer you other End User Services. With your permission or where allowed by law, we use and share End User Personal Data with others so that we may market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy on our website. We do not share End User Personal Data with third parties for their marketing or advertising unless you give us or the third-party permission to do so. We do not sell the data of End Users.
More.
Please see below for more information about additional ways in which we may use and share your Personal Data.

1.2 End Customers

Luminary offers Business Services to our Business Users (e.g. in-person checkout or online checkout). When we are acting as a Business User’s service provider (or data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process payment transactions for a Business User because you bought a product from them. Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer (e.g., a purchaser of a product at an online Business User site), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly. See our website for further information on the legal bases that we rely on for using (processing) your Personal Data.

a. Personal data that we collect about End Customers

Transaction Data.
If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation, or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information, or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number. We may also receive your transaction history with the Business User. We may collect information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User.

Identity/Verification Information.
Luminary provides a verification and fraud Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age-restricted goods) or your authorization to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image). We may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and third-party service providers.
More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share personal data of End Customers

We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Luminary’s own purposes to secure, improve and provide our Business Services, as described below.

Payments.
We use your Transaction Data to provide our Payments related Business Services to Business Users, including, to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. We may also use Personal Data to provide and improve our Business Services.
For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.
The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more.

Other Financial Services.
Some of our Business Users use our Services in order to offer financial services to you, through Luminary or its financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry the Luminary brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partner, if applicable, associated with the financial service (whose brands may be shown on the card).

Identity/Verification Services.
We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Luminary or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified.

Our Business Users (their Authorized Third Parties).
We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third-party application provider to access its Luminary account using the Luminary apps. For example, when the Business User uses Identity Services to verify an End Customer’s identity, Luminary shares with the Business User the information, documents, or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data with third parties they authorize. Please review your merchant’s privacy policy to learn more.

Advertising by Business Users.
If you have begun a purchase, we share Personal Data with that Business User in connection with our provision of Services, and that Business User may use your Personal Data to market and advertise their products or services. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. We do not use or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact. We do not sell the data of End Customers.

More.
Please see below for further information about additional ways in which we may use your Personal Data.

1.3 Representatives

To provide Business Services, we collect, use and share Personal Information from Representatives of our Business Users (e.g. a business owner). If the Representative is the only employee of a Business User, please see the End User and End Customer sections to understand additional ways in which we can collect and use your Personal Data when you use our Services. See our website for further information on the legal bases which we rely on for using (processing) your Personal Data.

a. Personal data that we collect about Representatives

Registration and Contact Information. If you register for a Luminary account for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. If you register for an event that Luminary organizes or attends or if you sign up for Luminary communications, we collect your registration and profile information. If you are a Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2.

Identification Information.
If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfill our financial partner and regulatory requirements. We may also collect financial and personal information about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your national registration or identity number, tax number, or Employer Identification Number). You may also choose to provide bank account information.
More. Please see below for more information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share Personal data of Representatives

We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users, as well as for the purposes described below.

Business Services.
We use and share Personal Data of Representatives with Business Users to provide the Services. For users of our tax Business Services, we may use your Personal Data to file taxes on behalf of your associated Business User. We may also use your Personal Data to submit forms to the tax office on your behalf and to file documents with other governmental authorities (e.g. articles of incorporation in your state of incorporation).
We share data with parties directly authorized by a Business User to receive Personal Data (e.g. financial partners servicing the financial product). The use of Personal Data by a Business User’s authorized third party is subject to the third party’s privacy policy. In some cases our Business Service will require us to submit your Personal Data to a government entity (e.g. incorporating a business, or paying applicable sales tax).

Advertising.
With your permission or where allowed by applicable law, we use and share Representative Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising subject to any consent requirements under applicable law. See our Cookie Policy. We do not sell Representative Personal Data.

More.
Please see below for more information about additional ways in which we may use and share your Personal Data.

1.4 Visitors (e.g. visitors to Luminary sites who are not an End User, End Customer or Representative)

See here for further information on the legal bases which we rely on for using (processing) your Personal Data.

a. Visitor personal data that we collect

When you visit our Sites, we generally receive your Personal Data either from you providing it to us or through our use of cookies and similar technologies. See our Cookie Policy also on our website.

Forms.
When you choose to fill in a form on the Site or on third-party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form, usually your contact information and other information about your question related to our Services.

More.
Please see below for more information about additional types of Personal Data that we may collect, including about online activity.

b. How we use and share visitor personal data

Personalization.
We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience and to tailor content about Luminary and our Services to you.

Advertising.
With your permission or where allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising where allowed by applicable law, including subject to any consent requirements. See our Cookie Policy also on our website.

2. More ways we collect, use and share personal data

In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows.

a. Personal Data Collection

Online Activity.
Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),
Usage data associated with those devices and browsers, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators, like mouse activity indicators, help us detect fraud.

Communication and Engagement Information.
We will collect any information you choose to provide to us, for example, through support tickets, emails, or social media. When you respond to Luminary emails or surveys, we collect your email address, name, and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Luminary, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Luminary events and other interactions with Luminary personnel,
Forums and Discussion Groups, where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.

b. Personal Data Usage.

In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways:

Improving and Developing our Services.
We use analytics on our Sites to help us analyze your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy on our website. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you.

Communications.
We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message, or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.

Social Media and Promotions.
If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. Based on your permission or opt-out, we will also use that Personal Data and Personal Data you make available on social media to market to you.
Fraud Prevention and Security.
We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Luminary and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised.
This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.

Compliance with Legal Obligations.
We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas, and other legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Luminary, our End Users, and their End Customers.

Minors.
The Services are not directed to minors, including children under the age of 13, and we request that they do not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of End Customers, Representatives, Visitors or End Users, including those aged between 13 to 16.

c. Personal Data Sharing.

In addition to the ways described above, we share Personal Data in the following ways:

Luminary Affiliates.
We share Personal Data with other Luminary-affiliated entities. When we share with these entities, it is for purposes identified in this Policy.

Service Providers or Processors.
In order to provide Services to our Business Users and End Users and to communicate, market, and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers (provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data of our Users that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United Kingdom.
Financial Partners.
“Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data of our Users with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase the Capital loans that we have made to the associated Business Users.

Others with Consent.
In some cases, we may not provide a service, but instead, refer you to, or enable you to engage with others to get services. In these cases, we will disclose the identity of the third party and the information that will be shared with them, and seek your consent to share the information.

Corporate Transactions.
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity that buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.

Compliance and Harm Prevention.
We share Personal Data as we believe necessary:
(i) to comply with applicable law, (ii) to comply with rules imposed by payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Luminary, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

3. Legal bases for processing data

For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data.

a. Contractual and Pre-Contractual Business Relationships.

We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include:
Creation and management of Luminary accounts and Luminary account credentials, including the evaluation of applications to commence or expand the use of our Services;
Creation and management of Luminary Checkout accounts;
Accounting, auditing, and billing activities; and
Processing of payments, including fraud detection and prevention, optimizing valid transactions, communications regarding such payments, and related customer service.

b. Legal Compliance.

We process Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention, and detection obligations and laws associated with the identification and reporting of illegal and illicit activity, such as "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and to submit to third-party verification audits.

c. Legitimate Business Interests.

Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:
Detect, monitor and prevent fraud and unauthorized payment transactions;
Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Luminary;
Determine eligibility for and offer new Luminary products and services;
Respond to enquiries, send Service notices and provide customer support;
Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
Analyze and advertise our Services;
Conduct aggregated analysis and develop business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of, our business;
Share Personal Data with third-party service providers that provide services on our behalf and business partners which help us operate and improve our business;
Enable network and information security throughout Luminary and our Services; and
Share Personal Data among our affiliates.

d. Consent.

We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services like our link and Luminary apps. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.

4. Your rights and choices

You may have choices regarding our collection, use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us, you may opt out via the unsubscribe link included in such emails or as described on our website. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.

b. Your data protection rights

Depending on your location and subject to applicable law, you may have the following rights described on our website with regard to the Personal Data we control about you:
The right to request confirmation of whether Luminary processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
The right to request that Luminary rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
The right to request that Luminary erase your Personal Data in certain circumstances provided by law;
The right to request that Luminary restrict the use of your Personal Data in certain circumstances, such as while Luminary considers another request that you have submitted (including a request that Luminary make an update to your Personal Data);
The right to request that we export your Personal Data that we hold to another company, where technically feasible;
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.

c. Process for exercising your data protection rights

To exercise your data protection rights please also see the Luminary Privacy Policy on our website or contact us as described below.

5. Security and retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Luminary account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

6. International data transfers

We are an international business. Personal Data may be stored and processed in any country where we do business, where our service providers do business or if you use an international payment method or financial partner service, the countries in which that payment method or financial partner operates. We may transfer your Personal Data to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities).

If you are located in the European Economic Area (“EEA”), the "United Kingdom ("UK")" or Switzerland, please see the specific Privacy issues on our website for more information. Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law. For transfers to third countries, we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA. You can obtain a copy of the relevant Standard Contractual Clauses.

While LUMINARY INC LIMITED remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of personal data to the U.S.

7. Updates and notifications

We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.

We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Luminary Dashboard, email address, and/or physical address listed in your Luminary account.

If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.

8. Jurisdiction-specific provisions

EEA and UK. To exercise your rights, you may contact our Data Privacy Officer. If you are a resident of the EEA or we have identified Luminary as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the appropriate Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, Luminary Payments Europe Limited and Luminary local regulated entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers.

9. Contact us

If you have any questions or complaints about this Policy, please contact us using the following email support@luminaryinc.com. If you are an End Customer (i.e. an individual doing business or transacting with a Business User), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices, and controls, or contact the Business User directly.

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