Lumina Privacy Policy

1. PRIVACY POLICY

1.1 Overview

Apex Lumina Payment, Inc is a financial technology company providing software and technology services.

We do not operate as a bank and do not hold customer deposits.

This Privacy Policy explains how we collect, use, and protect personal data.

1.2 Information We Collect

Information you provide:

• Name
• Phone number
• Email
• Business information
• Identity verification information
• Bank account information (via partners)

Information automatically collected:

• IP address
• Device information
• Operating system
• Browser
• App usage data

Information from third parties:

• Payment partners
• Identity verification providers
• Financial institutions

1.3 How We Use Information

We use data to:

• Provide services
• Verify identity (KYC)
• Prevent fraud
• Improve services
• Communicate with you
• Meet legal obligations

1.4 Legal Basis

We process data under:

• Contractual necessity
• Legal obligation
• Legitimate interest
• User consent

1.5 Data Sharing

We share data only with:

• Licensed payment partners
• Banks
• Identity verification providers
• Regulators (when required)

We do NOT sell personal data.

1.6 Data Security

We implement encryption, access control, and secure infrastructure. However, no system is 100% secure.

1.7 Data Retention

We retain data as long as account is active, as required by law, and as needed for compliance.

1.8 Your Rights

You may access your data, request correction, request deletion, or object to processing.

Contact: legal@luminaa.app

2. COOKIE POLICY

2.1 What Are Cookies

Cookies are small files stored on your device.

2.2 How We Use Cookies

We use cookies for authentication, security, analytics, and performance.

2.3 Types of Cookies

• Essential Cookies - Required
• Analytics Cookies - Improve performance
• Functional Cookies - Improve experience

2.4 Managing Cookies

You can disable cookies in your browser. Some features may not work properly.

3. ACCEPTABLE USE POLICY

You agree NOT to use services for fraud, money laundering, terrorism financing, illegal transactions, sanctions violations, adult illegal services, weapons sales, drug trafficking, unauthorized access, system abuse, reverse engineering, or security attacks.

Violation may result in immediate suspension, account termination, and reporting to authorities.

4. MERCHANT TERMS AND CONDITIONS

4.1 Role of Apex Lumina

Apex Lumina provides technology only, is NOT a bank, is NOT a payment processor, and does NOT hold customer funds. All regulated services are provided by licensed partners.

4.2 Merchant Responsibilities

Merchants must provide legitimate goods/services, honor refunds, avoid fraud, follow card network rules, and maintain compliance.

4.3 Prohibited Merchants

Includes illegal goods, scams, counterfeit goods, sanctioned activities, and high-risk illegal businesses.

4.4 Settlement

Funds are settled by licensed financial partners, not Apex Lumina.

4.5 Merchant Risk Monitoring

We may suspend merchants for fraud risk, compliance risk, or legal risk.

5. API TERMS OF USE

Limited API license only. You may not resell access, abuse the API, or reverse engineer. You must secure API keys and are responsible for misuse. We may apply rate limits. API is provided "AS IS" with no uptime guarantee.

6. AI TERMS OF SERVICE

AI output may be inaccurate, incomplete, or contain errors. You are responsible for decisions made using AI output. We are not liable for AI errors, business decisions, or financial losses.

7. PAYMENT AND FINANCIAL SERVICES DISCLAIMER

Apex Lumina is NOT a bank, is NOT a licensed financial institution, and does NOT hold funds. All financial services are provided by licensed partners.

8. DATA SECURITY POLICY

We implement encryption, access controls, least privilege access, secure cloud infrastructure, monitoring and logging.

9. LEGAL REPRESENTATIONS

Apex Lumina owns its intellectual property, operates as a technology provider, partners with licensed institutions, applies security best practices, and complies with applicable laws.

10. INTELLECTUAL PROPERTY

All rights belong to Apex Lumina including software, technology, AI systems, logos, and content. Unauthorized use is prohibited.

11. LIMITATION OF LIABILITY

To the maximum legal extent, we are not liable for indirect losses, lost profits, lost revenue, or lost business.

12. TERMINATION

We may terminate access for violation, legal requirement, or security risk.

13. GOVERNING LAW

Governed by the State of Delaware, USA and the Federal Republic of Nigeria.

14. CONTACT

Legal Department
legal@luminaa.app
Delaware, USA
Lagos, Nigeria