Luminaris Securities & Capital Ltd Online Privacy Policy

Your privacy matters to us.
This Online Privacy Policy explains how Luminaris Securities & Capital Ltd, together with its affiliated entities (collectively referred to as “Luminaris”, “we”, or “the company”), collects, uses, shares and protects your personal information when you access or use any online service that links to or references this policy.

Depending on how you engage with us, the type of financial products or services you make use of, and the legal requirements of your jurisdiction, additional privacy terms may also apply.

We take your privacy seriously

We place great importance on the confidentiality and protection of your personal information.
We use physical, electronic and procedural safeguards that meet applicable legal and industry standards to protect your information from unauthorised access, misuse, accidental or unlawful alteration, destruction or any other unlawful form of processing.

All Luminaris staff members are required to follow the company’s privacy, confidentiality and data-protection policies without exception.

What information we collect and why

When you use our online services, we may collect personal information such as:

• Your name, email address, postal address and phone number
• Account numbers
• Limited location data
• Your username and password
• Where you choose to provide it, and only when required for business purposes, we may also collect:
• Payment card details
• Identification documents such as an ID or passport
• Social security/tax identification numbers (or the equivalent in your jurisdiction)
• Gender, nationality or race (only where permitted by law)
• Biometric details used strictly for identity verification

In some cases, we may generate information about you based on your account activity or interactions with us.
We do not intentionally collect or process sensitive personal information unless required or permitted by law, needed for crime prevention, necessary for legal claims, or provided with your explicit consent.

Information we may collect from other sources

We may collect information about you from publicly available social-media platforms if you choose to make such information public.
We may also obtain information from commercial third parties, such as credit bureaus, and combine it with the data we collect under this policy.

In jurisdictions where a legal basis is required for processing your personal information, we may rely on:

• Your explicit consent
• Our legitimate business interests, provided they do not override your rights or freedoms
• Compliance with legal obligations
• Performance of a contract with you
• Protection of vital interests

How we use your information

We use your information to:

• Provide, improve and maintain our online services
• Manage, assess and optimise our business, including product development, analytics, research and communication
• Conduct risk management
• Share information about our products and services with you
• Comply with laws, regulations, contracts and internal policies
• We may also use anonymised or aggregated data — which cannot identify you — for lawful business purposes.

We only keep what is necessary

We take reasonable steps to ensure that the personal information we process is:

• Limited to what is needed for the purposes outlined in this policy
• Accurate and kept up to date when required
• Corrected or deleted when inaccuracies are identified
• Some online services allow you to update your account details directly through your Client Centre. If an update cannot be made online, you may contact Luminaris Client Services for assistance.

We retain identifiable information only for as long as necessary to meet the purposes described in this policy, unless a longer retention period is required by law — including retention needed for the establishment, exercise or defence of legal claims.

Your privacy on mobile devices

For your convenience, Luminaris provides mobile applications and mobile-optimised websites.
When you interact with us using a mobile device, we may collect information such as:

• Device identifiers
• Screen resolution and device settings
• Location data
• Usage and interaction analytics

If precise location data is required, we will request your permission beforehand.

When we share information with affiliates and third parties

We may share your information across the Luminaris group to improve service quality.
In situations such as mergers, acquisitions or asset transfers, your personal information may be transferred accordingly.

We may also disclose information:

• To regulators or law-enforcement authorities where required by law
• To prevent fraud, verify compliance with terms or protect our legal rights
• To carefully selected third-party service providers who assist in delivering our services

All service providers are contractually required to protect your information and may only use it for the purposes specified by Luminaris.

We may also share your information with other individuals or entities if you give us explicit consent.

Cross-border data transfers

As a global financial-services provider, we may transfer your personal information to our headquarters, operational centres or service providers located outside your country or region. This is done to ensure you receive the high-quality financial products and services you expect.

Data-protection laws may differ in those locations, and some may offer lower levels of protection.
However, Luminaris will take appropriate steps to ensure your information is handled in line with this policy.

Your rights regarding your personal information

Depending on your jurisdiction, you may have one or more of the following rights:

• Access to your personal information or a copy thereof
• Correction of inaccurate or outdated details
• Request deletion or restriction of processing
• Object to certain types of processing
• Request data portability to another provider
• Withdraw consent where processing is based on consent
• Lodge a complaint with a data-protection authority
• You may exercise these rights using the contact information provided in this policy.

Based on your relationship with Luminaris, we may also offer additional privacy choices or disclosures.

Your choices for online advertising and data collection

Luminaris does not allow unrelated third parties to collect your personal information while you are using our online services.
We also do not use information from non-affiliated websites to deliver behaviour-based advertising to you.

If this changes in future, we will provide clear notice and an option to opt out.

Updates to this Privacy Policy

If we make significant changes to this policy or to our privacy practices, we will notify you through appropriate channels.