Lumanu Service Level Agreement

Lumanu Service Level Agreement

Effective Date: January 1, 2026

1.  Scope and Applicability

This Service Level Agreement (this “SLA”) sets out Lumanu, Inc.’s (“Lumanu”) availability commitment for the Platform. It applies to a client (“Client”) that has entered into a Master Services Agreement with Lumanu (the “Agreement”) and has one or more Workspaces provisioned under an executed Order Form.

This SLA does not apply to:

(a)     self-service, trial, evaluation, sandbox, or no-charge access to the Platform;

(b)     access to Lumanu’s application programming interfaces, except to the extent expressly provided in an Order Form; or

(c)     any product, feature, or service identified by Lumanu as alpha, beta, preview, pilot, or evaluation.

Capitalized terms used but not defined in this SLA have the meanings given to them in the Agreement. This SLA does not amend the Agreement. In the event of any conflict between this SLA and the Agreement, the Agreement governs.

2.  Version Control and Amendment

Lumanu may update this SLA from time to time. The version of this SLA in effect as of the date of Client’s Order Form governs for the Initial Service Term of that Order Form and for each renewal term then in progress.

Any changA to this SLA that is materially adverse to Client will take effect only at the commencement of Client’s next renewal term, and only where Lumanu has given Client written notice of the change not less than thirty (30) days before the start of that renewal term. Changes that are not materially adverse to Client — including clarifications, additional or improved commitments, and updates to contact or status page details — take effect upon posting. Lumanu will make prior versions of this SLA available to Client on request.

3.  Definitions

“Platform” means the Lumanu web application and the authenticated client-facing interfaces made available to Client and its Authorized Users under the Agreement.

“Available” means that Client’s Authorized Users are able to log in to and access the Platform. The Platform is “Unavailable” during any period in which it is not Available.

Availability is measured at the Lumanu application layer only. The initiation, processing, completion, timing, or settlement of any payment, funds transfer, currency conversion, identity verification, bank account verification, or sanctions or compliance screening is not part of the availability measurement, and no service level is provided under this SLA in respect of any such matter.

“Downtime” means the aggregate number of whole minutes during a calendar month during which the Platform was Unavailable, excluding Excluded Downtime.

“Excluded Downtime” has the meaning given in Section 7.

“Monthly Uptime Percentage” means, for a given calendar month, the result of the following calculation, expressed as a percentage: (Total Minutes − Downtime) ÷ Total Minutes × 100, where “Total Minutes” is the total number of minutes in that calendar month.

“Availability Commitment” has the meaning given in Section 4.

“Credit Base” has the meaning given in Section 8.

“Service Credit” has the meaning given in Section 8.

“Scheduled Maintenance” and “Emergency Maintenance” have the meanings given in Section 6.

4.  Availability Commitment

Lumanu will use commercially reasonable efforts to make the Platform Available with a Monthly Uptime Percentage of at least ninety-nine and one-half percent (99.5%) during each calendar month (the “Availability Commitment”).

5.  Measurement

Monthly Uptime Percentage is measured by Lumanu’s monitoring systems, which test the availability of the Platform from outside Lumanu’s production network at intervals not exceeding five (5) minutes. A period of Downtime begins at the first failed measurement and ends at the first subsequent successful measurement. Periods of Unavailability lasting less than five (5) consecutive minutes are not counted as Downtime.

Lumanu’s monitoring records are the sole basis for determining Monthly Uptime Percentage and for resolving any matter under this SLA. Lumanu will make relevant measurement data available to Client on reasonable request in connection with a Service Credit claim submitted under Section 9.

Lumanu maintains a status page at status.lumanu.com, on which it will post information regarding material incidents affecting the availability of the Platform and regarding Scheduled Maintenance.

6.  Scheduled and Emergency Maintenance

Scheduled Maintenance. Lumanu will give Client not less than five (5) business days’ advance notice of planned maintenance affecting the availability of the Platform (“Scheduled Maintenance”), by posting to the status page, by email to Client’s designated contact, or both. Lumanu will schedule such maintenance during periods of historically low usage where reasonably practicable. Scheduled Maintenance will not exceed eight (8) hours in the aggregate in any calendar month.

Emergency Maintenance. Lumanu may perform maintenance at any time and without advance notice where necessary to address a security vulnerability, a data integrity risk, a legal or regulatory requirement, or a condition that materially threatens the stability or security of the Platform (“Emergency Maintenance”). Lumanu will notify Client as soon as reasonably practicable in the circumstances.

Both Scheduled Maintenance and Emergency Maintenance constitute Excluded Downtime.

7.  Exclusions

Downtime does not include, and no Service Credit is available in respect of, any period of Unavailability or degraded performance arising from or in connection with any of the following (collectively, “Excluded Downtime”):

(a)     Scheduled Maintenance or Emergency Maintenance;

(b)     any event constituting force majeure under the Agreement;

(c)     any act or omission of, or any delay, interruption, degradation, or failure in the systems of, any financial institution, payment network, automated clearing house, card network, banking-as-a-service provider, electronic money institution, foreign exchange or payment service provider, identity verification provider, bank account verification provider, authentication, single sign-on, or identity and access management provider, or other third party on whose services the Platform depends;

(d)     any failure, interruption, or degradation of the public internet, domain name services, telecommunications services, cloud hosting infrastructure, or other facilities outside Lumanu’s reasonable control;

(e)     any act or omission of Client or any Authorized User, including misconfiguration, misuse of the Platform, use of the Platform other than in accordance with the Agreement or Lumanu’s documented requirements, or any access obtained using Client’s or an Authorized User’s credentials;

(f)      Client equipment, software, network connectivity, or other technology not provided or controlled by Lumanu;

(g)     any suspension or termination of Client’s access to the Platform in accordance with the Agreement, including for non-payment;

(h)     Client’s failure to fund a Workspace, or any delay in Client’s funding, payment instruction, authorization, or approval;

(i)      any product, feature, or service identified by Lumanu as alpha, beta, preview, pilot, or evaluation; or

(j)      Lumanu’s compliance with applicable law, a court or governmental order, or any sanctions screening, anti-money laundering, or other regulatory requirement, including any hold, review, restriction, or freeze applied to an account or transaction.

 

8.  Service Credits

Where the Monthly Uptime Percentage for a calendar month falls below the Availability Commitment, Client is entitled, subject to Section 9, to a credit calculated as a percentage of the Credit Base for that month (a “Service Credit”), as follows:

Monthly Uptime Percentage

Service Credit

Less than 99.5% but equal to or greater than 99.0%

10% of the Credit Base

Less than 99.0% but equal to or greater than 97.0%

25% of the Credit Base

Less than 97.0%

50% of the Credit Base

 

Credit Base. The “Credit Base” for a calendar month is:

(a)     the Platform Fee payable by Client in respect of that calendar month, with any Platform Fee billed on an annual or other multi-month basis prorated on a monthly basis; or

(b)     where no Platform Fee is payable by Client in respect of that calendar month, whether because the Platform Fee is zero, waived, discounted to nil, or included at no charge, the total Funding Fees actually paid by Client to Lumanu in respect of that calendar month, provided that the Credit Base determined under this paragraph (b) shall not in any event exceed two thousand five hundred dollars ($2,500).

Monthly cap. The aggregate Service Credits payable in respect of any single calendar month shall not exceed one hundred percent (100%) of the Credit Base for that month.

Excluded amounts. Implementation fees, any other one-time fees, taxes, third-party or pass-through charges, and any amounts funded by Client for payment to Vendors are excluded from the Credit Base.

Form of credit. Service Credits are applied against fees payable by Client under the next invoice issued following Lumanu’s determination of the claim, or, where no further invoice is expected, against the final invoice. Service Credits are not refundable and have no cash value, are not transferable, and will not be paid to Client in cash or otherwise. Lumanu is not required to issue a Service Credit while any amount payable by Client under the Agreement is past due.

9.  Claim Procedure

To claim a Service Credit, Client must submit a written request to support@lumanu.com within thirty (30) days after the end of the calendar month to which the claim relates. The request must include:

(a)     “SLA Credit Request” in the subject line;

(b)     the calendar month to which the claim relates;

(c)     the dates, times, and duration of each period of Unavailability that Client experienced;

(d)     the Workspaces and Authorized Users affected; and

(e)     any logs, screenshots, support ticket references, or other evidence in Client’s possession that support the claim.

Lumanu will evaluate each request in good faith against its monitoring records and will respond within thirty (30) days of receipt. Client’s failure to submit a request meeting the requirements of this Section within the thirty (30) day period constitutes a waiver of Client’s right to a Service Credit in respect of that calendar month.

10.  Sole and Exclusive Remedy

Except for the termination right set out in Section 11, Service Credits are Client’s sole and exclusive remedy, and Lumanu’s sole and exclusive liability, for any failure to meet the Availability Commitment and for any unavailability, interruption, degradation, or deficiency in the performance of the Platform.

Service Credits are subject to, and count toward, the limitations of liability set out in the Agreement. Nothing in this SLA creates any liability of Lumanu that is separate from or additional to the liability provided for under the Agreement, and nothing in this SLA increases Lumanu’s aggregate liability beyond the limits set out in the Agreement.

11.  Chronic Failure

If the Monthly Uptime Percentage falls below the Availability Commitment in each of three (3) consecutive calendar months, Client may terminate the affected Order Form and the Agreement without penalty and without further liability, by giving written notice to Lumanu within thirty (30) days after the end of the third such month. Termination takes effect thirty (30) days after Lumanu’s receipt of the notice.

Where Client terminates under this Section, Lumanu will refund to Client, on a pro rata basis, any Platform Fees prepaid by Client in respect of the period after the effective date of termination. Client’s failure to give notice within the thirty (30) day period constitutes a waiver of the termination right under this Section in respect of those three months.

The right set out in this Section is in addition to Client’s right to Service Credits and is Client’s sole termination right arising from the availability of the Platform.

12.  General

This SLA is for the sole benefit of Client. It confers no rights on any Authorized User, Vendor, affiliate, or other third party, and no person other than Client is entitled to claim a Service Credit or to exercise any right under this SLA. Section headings are for convenience only. This SLA is governed by, and construed in accordance with, the governing law and dispute resolution provisions of the Agreement.

Questions regarding this SLA may be directed to support@lumanu.com.

Effective Date: December 5, 2024

Introduction


At Lumanu, we take your privacy seriously. This Privacy Policy explains how Lumanu ("we," "us," or "our") collects, uses, and protects your personal information when we process payments between buyers and vendors, assist vendors in opening bank accounts, file taxes on their behalf, and provide other related services. This policy complies with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Gramm-Leach-Bliley Act (GLBA), and the Right to Financial Privacy Act (RFPA). By using or visiting any Lumanu website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and agree to the terms of this policy unless we must specifically obtain your permission under any applicable law.


Information We Collect


To provide our services, Lumanu may collect the following types of personal information:


  • Contact Information: Name, email address, phone number, and physical address.

  • Payment Information: Bank account details, payment history, and transaction data to process payments between buyers and vendors.

  • Tax Information: Tax identification numbers, Social Security Numbers (SSNs), or Employer Identification Numbers (EINs) for tax filing purposes.

  • Business Information: Vendor business name, legal structure, and ownership details.

  • Identification Documents: Government-issued IDs, such as passports or driver’s licenses, to verify identity when opening bank accounts or facilitating payments, including compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations under the USA Patriot Act.

  • Credit-Related Information: Under the FCRA and FACTA, we may collect information related to your creditworthiness, including credit reports, for identity verification and fraud prevention purposes when opening financial accounts.

  • Social Media Information: With your explicit consent, we may collect information from your connected social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting access purposes. This may include username, profile details, and certain permissions necessary to provide the whitelisting services.

  • Technical Information: Device and usage data, such as IP address, browser type, and cookies, for enhancing our website and services.

  • Access to Personal Information:  Customer support and software engineers have access to the data we collect. Our banking partner will also have access to information for know your customer requirements. We also use third parties for filing taxes and for making international payments as well as identity verification.

  • We may collect non-personally identifiable information about you when you visit the Website. Non-personally identifiable information may include technical and measurement information concerning, for example, your connection to and usage of the Website. We may use this information for internal purposes, such as usage analysis and improving the Website. This information does not include your Personal Information.


How We Use Your Information


Lumanu collects and uses personal information for the following purposes:


  • Payment Processing: To facilitate transactions between buyers and vendors, including sending and receiving payments on behalf of both parties.

  • Account Management: To assist vendors in opening and maintaining business bank accounts.

  • Tax Compliance: To file tax documentation for vendors and comply with applicable tax laws.

  • Social Media Whitelisting Access: To enable vendors and buyers to connect their social media accounts for whitelisting purposes, such as granting authorized users access to advertising tools or media assets.

  • Credit Reporting and Verification: To comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA), we may use credit-related information to verify identity and protect against fraud when facilitating financial services.

  • Legal Compliance: To meet legal obligations, including those under the USA Patriot Act (e.g., KYC and AML regulations), as well as anti-fraud measures, tax laws, and identity verification processes together with use to enforce the terms of our user agreement or to protect third party rights, safety or property.

  • Service Improvement: To improve our website, customer support, and overall service offering.

  • Customer Requests. Customers are permitted to request we stop processing their data. Customers provide the data we use.


Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


Lumanu will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, whether it be to register, use the Service, communicate with others, request information, etc. We may also use the information you provide to contact you for reasons related to use of the Service.

Legal Basis for Processing


Under GDPR, Lumanu processes personal information on the following legal bases:

  • Contractual Necessity: We process your data as required to fulfill our contractual obligations (e.g., processing payments and filing taxes).

  • Legal Obligation: We process your data to comply with legal obligations, such as tax regulations, anti-fraud requirements, and obligations under the USA Patriot Act (including identity verification for AML and KYC).

  • Legitimate Interest: We process data for our legitimate interests, such as improving services and preventing fraud, provided that such interests are not overridden by your data protection rights.

  • Consent (For Social Media Whitelisting): We process your social media account information only with your explicit consent, which is necessary to provide whitelisting access services.


Your Rights


As a user, you have the following rights regarding your personal data:

  • Access and Portability: You can request access to your personal data and obtain a copy in a machine-readable format.

  • Rectification: You can request corrections to any inaccurate or incomplete personal data we hold about you.

  • Erasure: You have the right to request the deletion of your personal data, subject to certain exceptions (e.g., compliance with legal obligations such as those under AML/KYC laws).

  • Restriction and Objection: You may request that we restrict the processing of your data or object to processing under certain circumstances.

  • Data Protection Rights for California Residents (CCPA): California residents have the right to request information about the collection, use, and sharing of their personal data and to opt out of the sale of their personal data (Note: Lumanu does not sell personal data). California residents also have the right not to be discriminated against in the use of data.

  • Right to Financial Privacy (RFPA): Lumanu adheres to the RFPA, which protects the confidentiality of your financial records and requires that your financial information can only be disclosed to government authorities if a formal written request or legal subpoena is provided, or with your express consent.

  • FCRA and FACTA Rights: You have the right to access and dispute the accuracy of credit-related information we collect under the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA). If any adverse action is taken based on your credit report, you will be informed, and you have the right to dispute inaccuracies with the reporting agency.

To exercise any of these rights, please contact us at privacy@lumanu.com or call us at 415-702-2980. If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Data Protection Commission via their website at dataprotection.ie.


How far our responsibility extends


This Privacy Policy applies to services that are owned and operated by us. It does not necessarily apply to sites our customers create using our software, even if operated by us. We do not exercise control over other users or third party websites that may link to our Service. They may place their own or other files on their website, collect data or solicit personal information from you. We accept no responsibility or liability for these other sites or services. Third party websites.

Connecting Social Media Accounts for Whitelisting Access


Lumanu provides the option for vendors and buyers to connect their social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting services. This allows authorized parties to access certain advertising tools and media assets.


  • Permissions and Information Collected: When connecting your social media account, Lumanu may request permissions to access specific information, such as your username, profile, and any relevant settings or media assets required for whitelisting.

  • Consent: Connecting your social media account is entirely voluntary, and you will be asked to provide explicit consent before any data is accessed or used for whitelisting purposes.

  • Data Usage: The information collected will only be used for the purpose of enabling and managing social media whitelisting access. Lumanu will not share or use this data for any other purpose without your consent.


Do Not Track & Disabling Cookies


Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. However, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, although we may recognize a DNT signal for visitors from certain jurisdictions and/or certain browsers, we do not currently commit to responding to browsers’ DNT signals with respect to our Sites. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

With regard to information we collect via cookies as described above, for further information about cookies, including how to see and manage what cookies have been set on your computer or mobile device, you can visit www.allaboutcookies.org. You can also manage your cookie settings on our Site by clicking on the Cookie Settings below. If you do not accept our cookies or later disable cookies, you may experience some inconvenience in your use of our Sites.


Sharing Your Information


Lumanu only shares your personal information under the following circumstances:

  • Service Providers: We may share your data with trusted third-party vendors and service providers who assist in payment processing, tax filing, identity verification, and other essential business services. We cannot accept customers who do not wish to permit this sharing. Do not sign up if this concerns you.

  • Legal Compliance: We may disclose your information to regulatory bodies, law enforcement, or other third parties when required by law, such as for compliance with anti-money laundering (AML) laws under the USA Patriot Act, the Gramm-Leach-Bliley Act (GLBA), tax regulations, or under the Right to Financial Privacy Act (RFPA) when mandated by government authorities or law enforcement. Additionally, we comply with the FCRA and FACTA regulations regarding credit-related information sharing and protection.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity, subject to the same privacy protections outlined in this policy.


Data Security


We take the protection of your data seriously and implement appropriate technical, administrative, and physical safeguards to prevent unauthorized access, use, disclosure, or destruction of your personal data. These measures include encryption, secure access controls, and ongoing security assessments. We take appropriate organizational and technical measures to protect the data provided to us or collected by us, and do not retain it any longer than permitted in order to perform our services or as required under relevant legislation, with due observance of the applicable obligations and exceptions under the relevant legislation. You should be aware that internet communications are not always secure. You are responsible for maintaining the security and confidentiality of your account passwords. It is a condition of your use that you agree we are not liable for any such disclosure.

Data Retention


Lumanu retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. For example, we may retain transaction records for tax filing, AML/KYC compliance, or credit-related documentation as required by law.


International Transfers


Lumanu may transfer your personal data to countries outside of your home jurisdiction, including to data centers or third-party service providers located in other regions. When transferring data internationally, we ensure adequate data protection measures are in place, such as standard contractual clauses approved by the European Commission (for GDPR compliance).


Children's Privacy


Lumanu’s services are not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it.


Changes to This Privacy Policy


We reserve the right to and may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent. We encourage you to review this policy regularly to stay informed about how we protect your privacy.


Contact Us


If you have any questions or concerns about this Privacy Policy or wish to exercise your rights regarding your personal data, please contact us at:


Email: privacy@lumanu.com

Mailing Address: 1528 Webster St, Oakland, CA 94612


Our EU Representative:


Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :


Instant EU GDPR Representative Ltd.

Adam Brogden
contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD
Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland


Our UK Representative:


Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.


Adam Brogden
contact@gdprlocal.com

Tel +44 1772 217800

1st Floor Front Suite, 27-29 North Street, Brighton, England


Compliance Notices


  • GDPR Notice: Users in the European Economic Area (EEA) have rights related to their personal data under the General Data Protection Regulation (GDPR).

  • CCPA Notice: California residents have specific rights regarding their personal data under the California Consumer Privacy Act (CCPA).

  • GLBA Notice: This policy also complies with the Gramm-Leach-Bliley Act (GLBA), which governs the collection, disclosure, and safeguarding of nonpublic personal information in the financial services industry.

  • RFPA Notice: The Right to Financial Privacy Act (RFPA) provides protections over your financial records by requiring government authorities to have a formal written request or subpoena to access your financial information, unless you give express consent.

  • USA Patriot Act Notice: We comply with the USA Patriot Act by implementing AML and KYC processes for identity verification and financial crime prevention.

  • FCRA and FACTA Notice: We comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA) by protecting credit-related information and providing users the right to access and dispute their credit information.


Disclosure Policy


Data security is a priority for Lumanu. If you believe you’ve found a security vulnerability in Lumanu’s service, please notify us. We will work with you to resolve the issue promptly.

  • We will maintain standard confidentiality in our communications with you. 

  • We commit to thoroughly investigate and make every reasonable effort to address confirmed issues in a way that prioritizes the safety and security of those who may be impacted by a reported vulnerability.

  • We will work with you to confirm and address your disclosure appropriately.


What we ask of Researchers


If you believe you’ve discovered a potential vulnerability, please let us know by emailing security@lumanu.com and including the subject line Lumanu Security - (issue found). We will acknowledge your email within ten business days.

  • We ask researchers to supply adequate technical details and context required for our team to verify reported issues, including screen recordings where relevant.

  • Make a good faith effort to avoid violating privacy, interrupting or degrading Lumanu.com service, or destroying data. Please only interact with accounts you own or for which you have explicit permission from the account holder.

  • ‍Provide us with a reasonable amount of time to resolve the issue before disclosing it to the public or a third party. We aim to resolve critical issues within 24 hours of disclosure.


Exclusions


  • While researching, we’d like you to refrain from:

  • Distributed Denial of Service (DDoS)

  • Spamming

  • Social engineering or phishing of Lumanu employees

Thank you for helping to keep Lumanu.com and our users safe!

© 2024 Lumanu, Inc. All Rights Reserved.

Effective Date: December 5, 2024

Introduction


At Lumanu, we take your privacy seriously. This Privacy Policy explains how Lumanu ("we," "us," or "our") collects, uses, and protects your personal information when we process payments between buyers and vendors, assist vendors in opening bank accounts, file taxes on their behalf, and provide other related services. This policy complies with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Gramm-Leach-Bliley Act (GLBA), and the Right to Financial Privacy Act (RFPA). By using or visiting any Lumanu website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and agree to the terms of this policy unless we must specifically obtain your permission under any applicable law.


Information We Collect


To provide our services, Lumanu may collect the following types of personal information:


  • Contact Information: Name, email address, phone number, and physical address.


  • Payment Information: Bank account details, payment history, and transaction data to process payments between buyers and vendors.


  • Tax Information: Tax identification numbers, Social Security Numbers (SSNs), or Employer Identification Numbers (EINs) for tax filing purposes.


  • Business Information: Vendor business name, legal structure, and ownership details.


  • Identification Documents: Government-issued IDs, such as passports or driver’s licenses, to verify identity when opening bank accounts or facilitating payments, including compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations under the USA Patriot Act.


  • Credit-Related Information: Under the FCRA and FACTA, we may collect information related to your creditworthiness, including credit reports, for identity verification and fraud prevention purposes when opening financial accounts.


  • Social Media Information: With your explicit consent, we may collect information from your connected social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting access purposes. This may include username, profile details, and certain permissions necessary to provide the whitelisting services.


  • Technical Information: Device and usage data, such as IP address, browser type, and cookies, for enhancing our website and services.


  • Access to Personal Information:  Customer support and software engineers have access to the data we collect. Our banking partner will also have access to information for know your customer requirements. We also use third parties for filing taxes and for making international payments as well as identity verification.


  • We may collect non-personally identifiable information about you when you visit the Website. Non-personally identifiable information may include technical and measurement information concerning, for example, your connection to and usage of the Website. We may use this information for internal purposes, such as usage analysis and improving the Website. This information does not include your Personal Information.


How We Use Your Information


Lumanu collects and uses personal information for the following purposes:


  • Payment Processing: To facilitate transactions between buyers and vendors, including sending and receiving payments on behalf of both parties.


  • Account Management: To assist vendors in opening and maintaining business bank accounts.


  • Tax Compliance: To file tax documentation for vendors and comply with applicable tax laws.


  • Social Media Whitelisting Access: To enable vendors and buyers to connect their social media accounts for whitelisting purposes, such as granting authorized users access to advertising tools or media assets.


  • Credit Reporting and Verification: To comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA), we may use credit-related information to verify identity and protect against fraud when facilitating financial services.


  • Legal Compliance: To meet legal obligations, including those under the USA Patriot Act (e.g., KYC and AML regulations), as well as anti-fraud measures, tax laws, and identity verification processes together with use to enforce the terms of our user agreement or to protect third party rights, safety or property.


  • Service Improvement: To improve our website, customer support, and overall service offering.


  • Customer Requests. Customers are permitted to request we stop processing their data. Customers provide the data we use.


Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


Lumanu will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, whether it be to register, use the Service, communicate with others, request information, etc. We may also use the information you provide to contact you for reasons related to use of the Service.


Legal Basis for Processing


Under GDPR, Lumanu processes personal information on the following legal bases:

  • Contractual Necessity: We process your data as required to fulfill our contractual obligations (e.g., processing payments and filing taxes).


  • Legal Obligation: We process your data to comply with legal obligations, such as tax regulations, anti-fraud requirements, and obligations under the USA Patriot Act (including identity verification for AML and KYC).


  • Legitimate Interest: We process data for our legitimate interests, such as improving services and preventing fraud, provided that such interests are not overridden by your data protection rights.


  • Consent (For Social Media Whitelisting): We process your social media account information only with your explicit consent, which is necessary to provide whitelisting access services.


Your Rights


As a user, you have the following rights regarding your personal data:


  • Access and Portability: You can request access to your personal data and obtain a copy in a machine-readable format.


  • Rectification: You can request corrections to any inaccurate or incomplete personal data we hold about you.


  • Erasure: You have the right to request the deletion of your personal data, subject to certain exceptions (e.g., compliance with legal obligations such as those under AML/KYC laws).


  • Restriction and Objection: You may request that we restrict the processing of your data or object to processing under certain circumstances.


  • Data Protection Rights for California Residents (CCPA): California residents have the right to request information about the collection, use, and sharing of their personal data and to opt out of the sale of their personal data (Note: Lumanu does not sell personal data). California residents also have the right not to be discriminated against in the use of data.


  • Right to Financial Privacy (RFPA): Lumanu adheres to the RFPA, which protects the confidentiality of your financial records and requires that your financial information can only be disclosed to government authorities if a formal written request or legal subpoena is provided, or with your express consent.


  • FCRA and FACTA Rights: You have the right to access and dispute the accuracy of credit-related information we collect under the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA). If any adverse action is taken based on your credit report, you will be informed, and you have the right to dispute inaccuracies with the reporting agency.


To exercise any of these rights, please contact us at privacy@lumanu.com or call us at 415-702-2980. If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Data Protection Commission via their website at dataprotection.ie.


How far our responsibility extends


This Privacy Policy applies to services that are owned and operated by us. It does not necessarily apply to sites our customers create using our software, even if operated by us. We do not exercise control over other users or third party websites that may link to our Service. They may place their own or other files on their website, collect data or solicit personal information from you. We accept no responsibility or liability for these other sites or services. Third party websites.


Connecting Social Media Accounts for Whitelisting Access


Lumanu provides the option for vendors and buyers to connect their social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting services. This allows authorized parties to access certain advertising tools and media assets.


  • Permissions and Information Collected: When connecting your social media account, Lumanu may request permissions to access specific information, such as your username, profile, and any relevant settings or media assets required for whitelisting.


  • Consent: Connecting your social media account is entirely voluntary, and you will be asked to provide explicit consent before any data is accessed or used for whitelisting purposes.


  • Data Usage: The information collected will only be used for the purpose of enabling and managing social media whitelisting access. Lumanu will not share or use this data for any other purpose without your consent.


Do Not Track & Disabling Cookies


Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. However, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, although we may recognize a DNT signal for visitors from certain jurisdictions and/or certain browsers, we do not currently commit to responding to browsers’ DNT signals with respect to our Sites. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

With regard to information we collect via cookies as described above, for further information about cookies, including how to see and manage what cookies have been set on your computer or mobile device, you can visit www.allaboutcookies.org. You can also manage your cookie settings on our Site by clicking on the Cookie Settings below. If you do not accept our cookies or later disable cookies, you may experience some inconvenience in your use of our Sites.


Sharing Your Information


Lumanu only shares your personal information under the following circumstances:


  • Service Providers: We may share your data with trusted third-party vendors and service providers who assist in payment processing, tax filing, identity verification, and other essential business services. We cannot accept customers who do not wish to permit this sharing. Do not sign up if this concerns you.


  • Legal Compliance: We may disclose your information to regulatory bodies, law enforcement, or other third parties when required by law, such as for compliance with anti-money laundering (AML) laws under the USA Patriot Act, the Gramm-Leach-Bliley Act (GLBA), tax regulations, or under the Right to Financial Privacy Act (RFPA) when mandated by government authorities or law enforcement. Additionally, we comply with the FCRA and FACTA regulations regarding credit-related information sharing and protection.


  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity, subject to the same privacy protections outlined in this policy.


Data Security


We take the protection of your data seriously and implement appropriate technical, administrative, and physical safeguards to prevent unauthorized access, use, disclosure, or destruction of your personal data. These measures include encryption, secure access controls, and ongoing security assessments. We take appropriate organizational and technical measures to protect the data provided to us or collected by us, and do not retain it any longer than permitted in order to perform our services or as required under relevant legislation, with due observance of the applicable obligations and exceptions under the relevant legislation. You should be aware that internet communications are not always secure. You are responsible for maintaining the security and confidentiality of your account passwords. It is a condition of your use that you agree we are not liable for any such disclosure.


Data Retention


Lumanu retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. For example, we may retain transaction records for tax filing, AML/KYC compliance, or credit-related documentation as required by law.


International Transfers


Lumanu may transfer your personal data to countries outside of your home jurisdiction, including to data centers or third-party service providers located in other regions. When transferring data internationally, we ensure adequate data protection measures are in place, such as standard contractual clauses approved by the European Commission (for GDPR compliance).


Children's Privacy


Lumanu’s services are not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it.


Changes to This Privacy Policy


We reserve the right to and may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent. We encourage you to review this policy regularly to stay informed about how we protect your privacy.


Contact Us


If you have any questions or concerns about this Privacy Policy or wish to exercise your rights regarding your personal data, please contact us at:


Email: privacy@lumanu.com

Mailing Address: 1528 Webster St, Oakland, CA 94612


Our EU Representative:


Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is :


Instant EU GDPR Representative Ltd.

Adam Brogden
contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD
Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland


Our UK Representative:


Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.


Adam Brogden
contact@gdprlocal.com

Tel +44 1772 217800

1st Floor Front Suite, 27-29 North Street, Brighton, England


Compliance Notices


  • GDPR Notice: Users in the European Economic Area (EEA) have rights related to their personal data under the General Data Protection Regulation (GDPR).


  • CCPA Notice: California residents have specific rights regarding their personal data under the California Consumer Privacy Act (CCPA).


  • GLBA Notice: This policy also complies with the Gramm-Leach-Bliley Act (GLBA), which governs the collection, disclosure, and safeguarding of nonpublic personal information in the financial services industry.


  • RFPA Notice: The Right to Financial Privacy Act (RFPA) provides protections over your financial records by requiring government authorities to have a formal written request or subpoena to access your financial information, unless you give express consent.


  • USA Patriot Act Notice: We comply with the USA Patriot Act by implementing AML and KYC processes for identity verification and financial crime prevention.


  • FCRA and FACTA Notice: We comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA) by protecting credit-related information and providing users the right to access and dispute their credit information.


Disclosure Policy


Data security is a priority for Lumanu. If you believe you’ve found a security vulnerability in Lumanu’s service, please notify us. We will work with you to resolve the issue promptly.


  • We will maintain standard confidentiality in our communications with you. 


  • We commit to thoroughly investigate and make every reasonable effort to address confirmed issues in a way that prioritizes the safety and security of those who may be impacted by a reported vulnerability.


  • We will work with you to confirm and address your disclosure appropriately.


What we ask of Researchers


If you believe you’ve discovered a potential vulnerability, please let us know by emailing security@lumanu.com and including the subject line Lumanu Security - (issue found). We will acknowledge your email within ten business days.


  • We ask researchers to supply adequate technical details and context required for our team to verify reported issues, including screen recordings where relevant.


  • Make a good faith effort to avoid violating privacy, interrupting or degrading Lumanu.com service, or destroying data. Please only interact with accounts you own or for which you have explicit permission from the account holder.


  • ‍Provide us with a reasonable amount of time to resolve the issue before disclosing it to the public or a third party. We aim to resolve critical issues within 24 hours of disclosure.


Exclusions


  • While researching, we’d like you to refrain from:

  • Distributed Denial of Service (DDoS)

  • Spamming

  • Social engineering or phishing of Lumanu employees

Thank you for helping to keep Lumanu.com and our users safe!

© 2024 Lumanu, Inc. All Rights Reserved.

Effective Date: December 5, 2024

Introduction

At Lumanu, we take your privacy seriously. This Privacy Policy explains how Lumanu ("we," "us," or "our") collects, uses, and protects your personal information when we process payments between buyers and vendors, assist vendors in opening bank accounts, file taxes on their behalf, and provide other related services. This policy complies with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Gramm-Leach-Bliley Act (GLBA), and the Right to Financial Privacy Act (RFPA). By using or visiting any Lumanu website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and agree to the terms of this policy unless we must specifically obtain your permission under any applicable law.

Information We Collect

To provide our services, Lumanu may collect the following types of personal information:

  • Contact Information: Name, email address, phone number, and physical address.

  • Payment Information: Bank account details, payment history, and transaction data to process payments between buyers and vendors.

  • Tax Information: Tax identification numbers, Social Security Numbers (SSNs), or Employer Identification Numbers (EINs) for tax filing purposes.

  • Business Information: Vendor business name, legal structure, and ownership details.

  • Identification Documents: Government-issued IDs, such as passports or driver’s licenses, to verify identity when opening bank accounts or facilitating payments, including compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations under the USA Patriot Act.

  • Credit-Related Information: Under the FCRA and FACTA, we may collect information related to your creditworthiness, including credit reports, for identity verification and fraud prevention purposes when opening financial accounts.

  • Social Media Information: With your explicit consent, we may collect information from your connected social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting access purposes. This may include username, profile details, and certain permissions necessary to provide the whitelisting services.

  • Technical Information: Device and usage data, such as IP address, browser type, and cookies, for enhancing our website and services.

  • Access to Personal Information:  Customer support and software engineers have access to the data we collect. Our banking partner will also have access to information for know your customer requirements. We also use third parties for filing taxes and for making international payments as well as identity verification.

  • We may collect non-personally identifiable information about you when you visit the Website. Non-personally identifiable information may include technical and measurement information concerning, for example, your connection to and usage of the Website. We may use this information for internal purposes, such as usage analysis and improving the Website. This information does not include your Personal Information.

How We Use Your Information

Lumanu collects and uses personal information for the following purposes:

  • Payment Processing: To facilitate transactions between buyers and vendors, including sending and receiving payments on behalf of both parties.

  • Account Management: To assist vendors in opening and maintaining business bank accounts.

  • Tax Compliance: To file tax documentation for vendors and comply with applicable tax laws.

  • Social Media Whitelisting Access: To enable vendors and buyers to connect their social media accounts for whitelisting purposes, such as granting authorized users access to advertising tools or media assets.

  • Credit Reporting and Verification: To comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA), we may use credit-related information to verify identity and protect against fraud when facilitating financial services.

  • Legal Compliance: To meet legal obligations, including those under the USA Patriot Act (e.g., KYC and AML regulations), as well as anti-fraud measures, tax laws, and identity verification processes together with use to enforce the terms of our user agreement or to protect third party rights, safety or property.

  • Service Improvement: To improve our website, customer support, and overall service offering.

  • Customer Requests. Customers are permitted to request we stop processing their data. Customers provide the data we use.

Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Lumanu will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, whether it be to register, use the Service, communicate with others, request information, etc. We may also use the information you provide to contact you for reasons related to use of the Service.

Legal Basis for Processing

Under GDPR, Lumanu processes personal information on the following legal bases:

  • Contractual Necessity: We process your data as required to fulfill our contractual obligations (e.g., processing payments and filing taxes).

  • Legal Obligation: We process your data to comply with legal obligations, such as tax regulations, anti-fraud requirements, and obligations under the USA Patriot Act (including identity verification for AML and KYC).

  • Legitimate Interest: We process data for our legitimate interests, such as improving services and preventing fraud, provided that such interests are not overridden by your data protection rights.

  • Consent (For Social Media Whitelisting): We process your social media account information only with your explicit consent, which is necessary to provide whitelisting access services.

Your Rights

As a user, you have the following rights regarding your personal data:

  • Access and Portability: You can request access to your personal data and obtain a copy in a machine-readable format.

  • Rectification: You can request corrections to any inaccurate or incomplete personal data we hold about you.

  • Erasure: You have the right to request the deletion of your personal data, subject to certain exceptions (e.g., compliance with legal obligations such as those under AML/KYC laws).

  • Restriction and Objection: You may request that we restrict the processing of your data or object to processing under certain circumstances.

  • Data Protection Rights for California Residents (CCPA): California residents have the right to request information about the collection, use, and sharing of their personal data and to opt out of the sale of their personal data (Note: Lumanu does not sell personal data). California residents also have the right not to be discriminated against in the use of data.

  • Right to Financial Privacy (RFPA): Lumanu adheres to the RFPA, which protects the confidentiality of your financial records and requires that your financial information can only be disclosed to government authorities if a formal written request or legal subpoena is provided, or with your express consent.

  • FCRA and FACTA Rights: You have the right to access and dispute the accuracy of credit-related information we collect under the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA). If any adverse action is taken based on your credit report, you will be informed, and you have the right to dispute inaccuracies with the reporting agency.

To exercise any of these rights, please contact us at privacy@lumanu.com or call us at 415-702-2980. If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Data Protection Commission via their website at dataprotection.ie.

How far our responsibility extends

This Privacy Policy applies to services that are owned and operated by us. It does not necessarily apply to sites our customers create using our software, even if operated by us. We do not exercise control over other users or third party websites that may link to our Service. They may place their own or other files on their website, collect data or solicit personal information from you. We accept no responsibility or liability for these other sites or services. Third party websites.

Connecting Social Media Accounts for Whitelisting Access

Lumanu provides the option for vendors and buyers to connect their social media accounts (such as Facebook, Instagram, or TikTok) for whitelisting services. This allows authorized parties to access certain advertising tools and media assets.

  • Permissions and Information Collected: When connecting your social media account, Lumanu may request permissions to access specific information, such as your username, profile, and any relevant settings or media assets required for whitelisting.

  • Consent: Connecting your social media account is entirely voluntary, and you will be asked to provide explicit consent before any data is accessed or used for whitelisting purposes.

  • Data Usage: The information collected will only be used for the purpose of enabling and managing social media whitelisting access. Lumanu will not share or use this data for any other purpose without your consent.

Do Not Track & Disabling Cookies

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. However, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, although we may recognize a DNT signal for visitors from certain jurisdictions and/or certain browsers, we do not currently commit to responding to browsers’ DNT signals with respect to our Sites. We will continue to monitor developments around DNT browser technology and the implementation of a standard.

With regard to information we collect via cookies as described above, for further information about cookies, including how to see and manage what cookies have been set on your computer or mobile device, you can visit www.allaboutcookies.org. You can also manage your cookie settings on our Site by clicking on the Cookie Settings below. If you do not accept our cookies or later disable cookies, you may experience some inconvenience in your use of our Sites.


Sharing Your Information


Lumanu only shares your personal information under the following circumstances:

  • Service Providers: We may share your data with trusted third-party vendors and service providers who assist in payment processing, tax filing, identity verification, and other essential business services. We cannot accept customers who do not wish to permit this sharing. Do not sign up if this concerns you.

  • Legal Compliance: We may disclose your information to regulatory bodies, law enforcement, or other third parties when required by law, such as for compliance with anti-money laundering (AML) laws under the USA Patriot Act, the Gramm-Leach-Bliley Act (GLBA), tax regulations, or under the Right to Financial Privacy Act (RFPA) when mandated by government authorities or law enforcement. Additionally, we comply with the FCRA and FACTA regulations regarding credit-related information sharing and protection.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity, subject to the same privacy protections outlined in this policy.


Data Security


We take the protection of your data seriously and implement appropriate technical, administrative, and physical safeguards to prevent unauthorized access, use, disclosure, or destruction of your personal data. These measures include encryption, secure access controls, and ongoing security assessments. We take appropriate organizational and technical measures to protect the data provided to us or collected by us, and do not retain it any longer than permitted in order to perform our services or as required under relevant legislation, with due observance of the applicable obligations and exceptions under the relevant legislation. You should be aware that internet communications are not always secure. You are responsible for maintaining the security and confidentiality of your account passwords. It is a condition of your use that you agree we are not liable for any such disclosure.

Data Retention


Lumanu retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. For example, we may retain transaction records for tax filing, AML/KYC compliance, or credit-related documentation as required by law.


International Transfers


Lumanu may transfer your personal data to countries outside of your home jurisdiction, including to data centers or third-party service providers located in other regions. When transferring data internationally, we ensure adequate data protection measures are in place, such as standard contractual clauses approved by the European Commission (for GDPR compliance).


Children's Privacy


Lumanu’s services are not intended for use by individuals under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it.


Changes to This Privacy Policy


We reserve the right to and may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent. We encourage you to review this policy regularly to stay informed about how we protect your privacy.


Contact Us


If you have any questions or concerns about this Privacy Policy or wish to exercise your rights regarding your personal data, please contact us at:


Email: privacy@lumanu.com


Mailing Address: 1528 Webster St, Oakland, CA 94612


Our EU Representative:


Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:


Instant EU GDPR Representative Ltd

Adam Brogden
contact@gdprlocal.com

Tel +35315549700

INSTANT EU GDPR REPRESENTATIVE LTD
Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland


Our UK Representative:


Under Article 27 of the UK Data Privacy Act, we have appointed a UK Representative to act as our data protection agent. Our nominated UK Representative is: GDPR Local Ltd.


Adam Brogden
contact@gdprlocal.com

Tel +44 1772 217800

1st Floor Front Suite, 27-29 North Street, Brighton, England


Compliance Notices

  • GDPR Notice: Users in the European Economic Area (EEA) have rights related to their personal data under the General Data Protection Regulation (GDPR).

  • CCPA Notice: California residents have specific rights regarding their personal data under the California Consumer Privacy Act (CCPA).

  • GLBA Notice: This policy also complies with the Gramm-Leach-Bliley Act (GLBA), which governs the collection, disclosure, and safeguarding of nonpublic personal information in the financial services industry.

  • RFPA Notice: The Right to Financial Privacy Act (RFPA) provides protections over your financial records by requiring government authorities to have a formal written request or subpoena to access your financial information, unless you give express consent.

  • USA Patriot Act Notice: We comply with the USA Patriot Act by implementing AML and KYC processes for identity verification and financial crime prevention.

  • FCRA and FACTA Notice: We comply with the Fair Credit Reporting Act (FCRA) and the Fair and Accurate Credit Transactions Act (FACTA) by protecting credit-related information and providing users the right to access and dispute their credit information.


Disclosure Policy


Data security is a priority for Lumanu. If you believe you’ve found a security vulnerability in Lumanu’s service, please notify us. We will work with you to resolve the issue promptly.


  • We will maintain standard confidentiality in our communications with you. 

  • We commit to thoroughly investigate and make every reasonable effort to address confirmed issues in a way that prioritizes the safety and security of those who may be impacted by a reported vulnerability.

  • We will work with you to confirm and address your disclosure appropriately.


What we ask of Researchers


If you believe you’ve discovered a potential vulnerability, please let us know by emailing security@lumanu.com and including the subject line Lumanu Security - (issue found). We will acknowledge your email within ten business days.

  • We ask researchers to supply adequate technical details and context required for our team to verify reported issues, including screen recordings where relevant.

  • Make a good faith effort to avoid violating privacy, interrupting or degrading Lumanu.com service, or destroying data. Please only interact with accounts you own or for which you have explicit permission from the account holder.

  • ‍Provide us with a reasonable amount of time to resolve the issue before disclosing it to the public or a third party. We aim to resolve critical issues within 24 hours of disclosure.


Exclusions


  • While researching, we’d like you to refrain from:

  • Distributed Denial of Service (DDoS)

  • Spamming

  • Social engineering or phishing of Lumanu employees

Thank you for helping to keep Lumanu.com and our users safe!

© 2024 Lumanu, Inc. All Rights Reserved.