PRIVACY POLICY

We collect Personal Data from Users to enable the provision of services on the Lumen Platform and fulfill Our legal obligations. The data We collect may include personal identity information such as full name, place and date of birth, identification numbers such as ID card, Passport, or Tax ID, including photos, signatures, and biometric data if required for verification processes. In addition, We also collect contact information including email address, phone number, and residential or mailing address used for official communications related to services. To support account opening and transaction execution, We collect financial information and account data such as bank account numbers, source of funds, investment objectives, and transaction history or activity conducted by Users. When Users use the Platform, Our systems automatically record technical data such as IP addresses, device types used, operating systems, browser types, device identifiers (device IDs), cookies data, and activity logs and User interactions with the Platform. In executing transactions, We also collect information related to User trading activities, including transaction instructions, trading history, and balance information necessary to fulfill operational functions. Additionally, in certain situations We may receive or verify data through third parties, such as electronic identity verification service providers, payment partners, financial institutions, affiliates, or other parties providing supporting services, as well as government agencies or regulators in accordance with applicable provisions.

Personal Data processing is carried out to enable Us to provide optimal services to Users, including but not limited to registration processes, identity verification, account opening, transaction feature activation, and fulfillment of legal and regulatory obligations. Personal Data is used to ensure that all services operate safely, reliably, and in accordance with applicable laws and regulations, including Know Your Customer (KYC) obligations, Anti-Money Laundering and Counter-Terrorism Financing (AML-CFT), transaction reporting, and supervisory provisions imposed by regulators. In the context of services, Users understand that Personal Data will be processed by Us, and some or all of User Personal Data will be forwarded if necessary for account opening, identity verification, eligibility evaluation, transaction execution, data storage, legal compliance, and reporting to relevant regulators as stipulated in applicable legal provisions. Personal Data may also be used for operational communication purposes, sending notifications regarding service changes, feature updates, security information, or requests for additional documents. Furthermore, Personal Data may be processed to enhance User experience, including internal analysis, system usage monitoring, feature development, content personalization, and service performance evaluation. In order to maintain Platform security and integrity, We may use Personal Data for additional verification, risk mitigation, fraud prevention, investigation of suspicious activities, and other actions necessary to protect Users and the Platform. Where necessary, We may cooperate with third parties that provide supporting services, such as electronic identification services (e-KYC), technology service providers, financial institutions, data infrastructure partners, analytics service providers, or other parties assisting in Application operations. The use or transfer of Personal Data to such third parties is conducted in a limited, measured manner and in accordance with legitimate processing purposes, and is subject to agreements and adequate data protection mechanisms.

We store User Personal Data for as long as necessary to provide services, complete transactions, and fulfill legal obligations. Data may be stored by Us in accordance with data retention requirements mandated by regulators and other laws and regulations. Data storage is conducted by ensuring adequate security protections. We implement technical and organizational security measures to protect Personal Data from unauthorized access, loss, or misuse. If Personal Data is no longer needed or no longer required to be retained, We will delete or anonymize it in accordance with retention policies and applicable legal provisions. Users have the right to access, review, and request copies of Personal Information stored in Our systems, as long as such requests comply with applicable legal provisions. Users may also request correction or updates if there is incomplete, inaccurate, or no longer relevant data. Such requests can be made through customer service or mechanisms available within the Application. Users may submit requests for deletion of Personal Information or account closure, however such requests can only be fulfilled if they do not conflict with data retention obligations mandated by laws and regulations, including reporting and data storage requirements by regulators. Account closure does not eliminate User obligations for transactions or other ongoing obligations.

We are committed to protecting User Personal Information by implementing reasonable technical, physical, and organizational security measures to prevent unauthorized access, misuse, alteration, or disclosure without permission. These security efforts include the use of encryption, access controls, system monitoring, internal audits, and data protection policies that are strictly enforced in Our operational environment as well as Our strategic partners. Although We make maximum efforts to maintain data security, Users acknowledge that no system is completely risk-free, therefore Users are also responsible for maintaining the security of their accounts, devices, One-Time Passwords (OTP), and login credentials.

We may change, update, or adjust this Privacy Policy at any time to adapt to service changes, operational needs, technological developments, or applicable legal provisions. Any changes will be notified through the Application, website, email, or other reasonable means of communication. Users are advised to review this Privacy Policy periodically. By continuing to use the Application after any changes, Users are deemed to have read, understood, and agreed to the latest version of this Privacy Policy. If the changes are material in nature, We may request additional consent in accordance with applicable legal obligations.