Document

Privacy Policy

Last Revised: May —, 2026 (Same as the last revision date of the LUMY Terms of Service)

LUMY Project (hereinafter referred to as “LUMY,” “we,” “our,” or “us”) is committed to safeguarding your privacy. This Privacy Policy is part of the LUMY Terms of Service and describes the collection and processing of your personal data when you use the Services. We ask that you carefully review this Privacy Policy, as it applies to the information LUMY collects from and about you, whether online or offline, wherever this Privacy Policy appears or is referenced. This includes information we collect when you: (a) visit our websites (“Sites”); (b) use our mobile applications (“Apps”). By using or accessing the Sites, Apps (collectively, “Platform”), Offers and our related services (collectively, the “Services”), you agree to the collection, use, and disclosure of your information, as described in this Privacy Policy. If you do not agree, please do not access or use the Services.

1.Information We Collect

A. Data We Do Collect

LUMY (and the vendors and other parties we use to perform services on our behalf) collects the following limited categories of personal information from or about you when you use the Services:

Names
Phone numbers
Email addresses
Home addresses

We do not perform KYC (Know Your Customer) or identity verification.

B. Data We Process

In addition to the personal data above, we only process non-personally identifiable technical information necessary for the operation of the Services. This includes:

Blockchain Data (Public, On-chain):

Wallet public address
On-chain transaction history
Token balances (read-only)

Note: Some jurisdictions may consider wallet addresses as “personal data.” We process this data without linking it to real-world identity.

C. Information Passively Collected

Whenever you visit or interact with the Platform, LUMY or its vendors may use technologies such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies to passively collect technical information about your interaction with the Platform, including:

Computer or Device Information: IP address, browser type, device type, operating system, software version, device ID, and the domain name from which you accessed the Services.
Usage Information: The date and time you visit the Platform, the areas or pages you visit, the amount of time you spend, click-stream or usage data, and interaction with emails or communications we send.
Use of Analytic Technologies: We and our vendors may use analytics vendors and tracking tools to better understand who is using the Platform, how people are using the Platform, and how to improve the effectiveness of the Platform.

2.Information Use

A. Use by or for LUMY

LUMY may use the information we collect from and about you for the following business purposes:

To provide you with and administer the Services;
To fulfill and comply with our contractual and other obligations;
To provide support and respond to your inquiries, contact and communicate with you when necessary;
To review the usage and operations of our Platform, develop new products or services, improve the Services, and conduct analyses to enhance our content, products, and services;
For security, safety, compliance, and due diligence purposes;
For other purposes disclosed at the time you provide your information or otherwise with your consent.

LUMY may use the information we collect from and about you for the following commercial purposes:

To provide you with customized content;
To provide you with information, newsletters and promotional materials from LUMY; and
To use your data in an aggregated non-specific format for analytical and demographic purposes.

B. Processing of Blockchain Data

We process blockchain data solely for operational purposes related to the Services. Because blockchain data is inherently public and recorded on a distributed ledger, we cannot modify, delete, or alter on-chain records. We do not attempt to link wallet addresses to your real-world identity.

3.Information We Share with Others

We may share your personal information with the following:

Vendors: We may share your information with vendors that provide business, professional, or technical support functions for us, help us operate our business and the Platform, or administer activities on our behalf.
Business Partners and Affiliates: We may share your information with our select partners and affiliates for their business, operational, promotional, and marketing purposes. These entities’ use of such information is subject to their respective privacy policies.
Legal Matters; Safety: We may access and disclose your information to comply with law, or to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law. We may disclose your information to protect the security of our Services, Platform, servers, network systems, databases, and business.
Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business. If another entity acquires or intends to acquire us or any of our assets, information we have collected about you may be transferred to such entity.

4.Your Choices and Opt-Outs

A. Use of Tracking Cookies

Certain parts of our Sites and Apps require cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features of the Services. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable cookies. We may use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.

B. Interest-Based Advertising Choices

We and third-party advertising networks, social media companies, and other services may collect information about your use of the Platform so that they or we may display interest-based advertising. To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit http://optout.aboutads.info. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

5.External Links

The Platform may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

6.Publication of User Submissions

Any information you may disclose on our Platform (e.g., ratings and reviews), in blogs, on message boards, in chat rooms, on social media, or in other public areas becomes public information. Please exercise caution when disclosing personal information in these public areas. Additionally, please be aware that blockchain transactions are inherently public and permanent.

7.Revisions to This Privacy Policy

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) on the Platform. Your continued use of the Services or Platform following the posting of changes to these terms means you accept these changes.

8.How to Contact Us

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at:

[email protected]