General Provisions of Lumina Capital

Lumina Capital LLC ("we", "us", "Company", or "Lumina Capital") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at luminacapital.com or engage with our financial planning services. By accessing or using our services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with the terms, please discontinue use of our website and services. This policy applies to all users, including visitors, registered clients, and prospective clients who interact with our platform in any capacity.

What Data We Collect

We collect personal information that you voluntarily provide when requesting a consultation, submitting forms, or communicating with our team. This includes your full name, email address, phone number, approximate investment balance, and financial goals. We may also collect technical information automatically, such as your IP address, browser type, operating system, referring URLs, and pages visited on our site. This technical data helps us improve platform performance and user experience. When you connect your investment accounts through our Fidelity-integrated portal, we receive only read-level portfolio data required to deliver our advisory service — we never have access to withdrawal or transfer functionality. All financial data you share with us is treated with the highest level of confidentiality in accordance with applicable securities regulations.

How We Use Your Data

The information we collect is used solely to provide, personalize, and improve our financial advisory services. Specifically, we use your data to schedule and conduct initial consultations, analyze your current investment structure, prepare a personalized tax-advantaged strategy using accounts such as 401(k), IRA, or HSA, and communicate relevant updates or recommendations. We may also use anonymized, aggregated data for internal research and service improvement purposes. We do not sell, rent, or share your personal information with third-party marketers. Data may be shared with regulated service partners — such as Fidelity Investments — solely to the extent necessary to deliver our services and always under strict confidentiality agreements. You may opt out of non-essential communications at any time by contacting us at [email protected].

Data Storage and Protection

Lumina Capital employs industry-standard security measures to protect your personal and financial data. All information transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Access to client data is restricted to authorized personnel on a need-to-know basis, and all staff handling personal data are subject to confidentiality obligations. Your data is stored on secure servers located within the United States and is not transferred internationally. We retain your personal information only for as long as necessary to fulfill the purposes described in this policy or as required by applicable law. In the event of a data breach that may compromise your personal information, we will notify you and relevant authorities within 72 hours in accordance with applicable regulations.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to analyze site traffic, remember your preferences, and enhance your browsing experience. Cookies are small text files stored on your device that help us understand how visitors interact with our content. We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device for a set period. We may also use third-party analytics tools such as Google Analytics to gather aggregated, anonymized usage data. You can control or disable cookies through your browser settings at any time; however, doing so may affect the availability or functionality of certain features on our website. By continuing to use our site without changing your cookie settings, you consent to our use of cookies as described in this policy.

Your Rights and Choices

You have the right to access, correct, or delete the personal information we hold about you at any time. You may also request that we restrict or cease processing your data, or ask us to provide you with a portable copy of your information in a commonly used format. To exercise any of these rights, please contact us at [email protected] or by mail at 1560 Broadway, New York, NY 10036. We will respond to your request within 5 business days. Please note that withdrawing consent to data processing may limit our ability to provide certain services. Where required by law, we will verify your identity before processing any access or deletion request. Lumina Capital does not make automated decisions that produce legal or similarly significant effects on individuals without human review.

Policy Changes and Contact

Lumina Capital reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings. The revised policy will take effect immediately upon posting to our website, and the "Last Updated" date at the top of this page will be updated accordingly. We encourage you to review this policy periodically to stay informed about how we protect your information. For any questions, concerns, or requests related to this Privacy Policy, please contact our Privacy Team at [email protected], call us at +1 (800) 123-4567, or write to us at Lumina Capital LLC, 1560 Broadway, New York, NY 10036. Business hours: Monday through Friday, 9:00 AM to 6:00 PM (EST).