Privacy Policy

This Privacy Policy describes how Lumin Finanças collects, uses, stores, protects, and disposes of personal and financial information.

We process data in strict alignment with the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018), the EU General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) where applicable to individuals in the EEA or UK, and relevant US state privacy statutes (such as the California Consumer Privacy Act / CPRA).

• Operating Brand: Lumin Interactive
• Data Controller (Natural Person in Brazil): Luiz Fernando dos S. Lima. In accordance with legal accuracy, the operation does not hold a corporate registry (CNPJ) at this stage. If a corporate entity is established in the future, this document will be updated with corporate registry details without diminishing any of your legal rights.
• Data Protection Officer / Privacy Inquiries: privacidade@lumininteractive.com.br
• Customer Support: suporte@lumininteractive.com.br
• Rights Request Portal: privacy.lumininteractive.com.br/requests

We only collect data that is strictly necessary for our personal finance services:

• Account Data: Name, email address, unique user ID (Firebase UID), profile photo (optional), and user preferences (language, dark/light theme, subscription plan).
• Financial Records: User-entered incomes, expenses, categories, transaction dates, bank accounts/wallets, credit card aliases, limits, statement closing dates, budgets, financial goals, and recurring subscription reminders.

NOTE: Lumin Finanças NEVER collects or stores full credit card numbers (PAN), CVV security codes, or banking passwords.

• Documents & Receipts: Invoices, receipts, and images voluntarily attached to entries. Initial text recognition runs locally via Google ML Kit on-device; attachments are stored privately in Cloudflare R2 using SHA-256 hashed keys.
• AI Interactions: Prompts sent to Lumin AI and contextual financial aggregates sent strictly on-demand.
• Device Data: Operating system version, device model, push token (FCM), and transient edge networking logs.

Lumin Finanças offers optional biometric app locking (fingerprint or face unlock).

STRICT AUDITED DECLARATION:

Biometric verification is executed exclusively by your device's operating system (Android BiometricPrompt / iOS LocalAuthentication via Secure Enclave).

• Lumin Finanças NEVER receives, processes, or stores your biometric samples, facial geometry, or fingerprints.
• The operating system only returns a true/false authorization result to the app.

When you query Lumin AI:

• Requests are processed through Google Cloud Platform (Vertex AI) in region us-central1.
• ZERO FOUNDATION MODEL TRAINING: Under our Google Cloud Vertex AI enterprise terms, your customer prompts, contextual financial summaries, and uploaded receipts are NEVER used to train, retrain, or improve Google's Gemini foundation models.
• Lumin AI answers are strictly informational suggestions and do not constitute certified financial or investment advice.

You maintain full rights to access, rectify, export, and delete your personal information:

• Export / Portability: Export your records anytime into OFX, CSV, or Excel formats.
• Account Deletion: Delete your entire account and synchronized records directly inside the app (Profile > Security & Privacy > Delete Account) or online at privacy.lumininteractive.com.br/requests. Data is expunged from primary databases within 30 days.
• We Do Not Sell Personal Information: We do not monetize or sell your data.
• Contact: Reach our privacy team at privacidade@lumininteractive.com.br.