Privacy Policy

This Privacy Policy explains how Lumie Holdings d/b/a Lumina Engine ("Lumina," "we," "us") collects, uses, and shares information when you use the Lumina Engine beta application at https://beta.luminaengine.ai and related services (the "Service").

This Policy is written for humans, not for whoever keeps inventing pop-up cookie banners.

1) Scope

This Policy applies to information processed by Lumina when you:

• use the beta App,
• sign up for beta access or communicate with us,
• contact support.

This Policy does not apply to third-party services you use alongside Lumina (e.g., Miden wallet extensions, browsers, device OS, third-party RPC providers, or other integrated services). Those are governed by their own policies.

2) What We Collect

A) Information you provide

Depending on what you do, we may collect:

• contact details (e.g., email) if you submit a form or contact support,
• messages you send us (support requests, bug reports),
• beta signup responses (which may include self-reported trading preferences, geography/country, and similar survey fields).

B) Wallet and account identifiers

When you use the Service, we may collect:

• public wallet addresses and account identifiers (e.g., Miden addresses),
• account labels you set (e.g., "Test wallet 1"),
• basic lifecycle events tied to those identifiers (created intent, updated, settled, transferred, etc.).

We do not ask for or intentionally collect your private keys or seed phrases. If you create a local wallet/account inside the App, key material is intended to remain on your device.

C) Transaction and intent metadata

Because the Service facilitates private intents and lifecycle tracking, we may process:

• intent lifecycle events (created, responded, partially consumed, settled),
• timestamps, status changes, and routing/transport events,
• limited execution settings you choose (e.g., slippage setting, expiry).

D) Device, network, and usage data

We may automatically collect:

• IP address, device type, browser type, and basic telemetry,
• log data (pages viewed, clicks, errors, crash reports),
• approximate location derived from IP (country/region level).

E) Cookies and similar technologies

We may use cookies/local storage to:

• maintain sessions,
• store preferences (e.g., UI settings),
• support security and abuse prevention,
• run basic analytics (if enabled).

You can restrict cookies in your browser settings, but the Service may degrade.

3) How We Use Information

We use information to:

• provide and operate the Service (wallet connectivity, intent creation, transfers),
• support private note exchange via the transport layer,
• maintain an activity log and user experience,
• troubleshoot, debug, and improve product performance,
• prevent abuse, fraud, and security incidents,
• comply with legal obligations (when applicable),
• communicate with you (support, important notices).

4) Operator Visibility (Important for This Beta)

Lumina's Milestone 1 beta includes internal monitoring tools (including an operator dashboard) intended to support reliability and debugging.

This means authorized Lumina personnel may be able to view certain trading/transfer lifecycle data associated with your activity (especially in beta), including metadata and status information, and potentially additional details necessary to diagnose issues or prevent abuse.

We limit internal access to a need-to-know basis and use access controls, but this is not a "trustless black box" in its current beta form.

5) How We Share Information

We may share information:

• With service providers who help run the Service (hosting, monitoring, analytics, support tooling), under confidentiality obligations.
• With counterparties, when needed to complete a flow (e.g., responding to an RFQ-style intent or completing a private transfer), consistent with the Service design.
• For legal reasons, if we reasonably believe disclosure is required by law, court order, or to protect rights, safety, or security.
• In aggregated/de-identified form, for reporting or research (e.g., aggregated beta insights that exclude personal identifiers).

We do not sell your personal information.

6) Blockchain Reality Check: Privacy and Immutability

The Service operates on the Miden testnet and related infrastructure. Even privacy-preserving systems have constraints:

• Some information may be observable on network infrastructure (RPC requests, timing, non-private accounts, etc.).
• Blockchain systems can be immutable. If something is recorded on-chain, it may be difficult or impossible to delete.
• "Privacy mode" does not equal "invisibility." Threat models vary by flow and by counterparty.

If you make a transfer to a recipient outside Miden/Lumina accounts, privacy may be partial (e.g., one side may lose full privacy protections).

7) Data Retention

We retain information for as long as needed to:

• provide the Service,
• comply with legal obligations,
• resolve disputes,
• maintain security and prevent abuse.

Because this is a beta, we may also periodically delete or reset data (including activity logs and testnet-facing records), subject to technical constraints.

8) Security

We implement reasonable administrative, technical, and organizational safeguards to protect information. However, no system is perfectly secure, especially in experimental crypto infrastructure.

You are responsible for securing your devices, wallet(s), and backups.

9) International Transfers

If you access the Service from outside the country where Lumina operates, your information may be processed in other countries. We take reasonable steps to protect information in transit and at rest, but cross-border processing may occur.

10) Your Rights and Choices

Depending on your location, you may have rights to:

• request access to personal information,
• request correction or deletion (where feasible),
• object to or restrict certain processing,
• opt out of marketing communications.

Note: We may not be able to delete information that is stored on-chain or required for security/legal reasons.

To make a request, contact: info@luminaengine.ai

11) Children

The Service is not intended for children and we do not knowingly collect personal data from minors.

12) Changes

We may update this Policy from time to time. We'll update the "Last Updated" date above.

13) Contact

Privacy questions:

• Email: info@luminaengine.ai