Privacy Policy
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1. Introduction

Lumini dApps ("we", "us", or "our") is committed to protecting the privacy and personal data of all users, clients, and visitors of our website and decentralized application services. This Privacy Policy describes the types of data we collect, how we process and protect such data, and the rights granted to data subjects under the Brazilian General Data Protection Law (LGPD – Lei nº 13.709/2018). This policy applies to all interactions with our platform, including browsing our website (https://luminidapps.com/), using our smart contract deployment services, creating tokens and NFTs, and any related communications.


2. Data Collection

We collect the following categories of personal data:
Personal Identification Data: Full name, email address, and telephone number (when voluntarily provided through contact forms or service requests).

Browsing Data: IP address, browser type, operating system, pages visited, time and date of access, referring URLs (collected automatically via cookies and similar technologies).

Wallet Addresses: Public blockchain wallet addresses (e.g., Ethereum, BSC, Polygon addresses) provided by users for deploying smart contracts, minting tokens or NFTs, and receiving payments.

Payment Data: Cryptocurrency transaction hashes (TxID) and, when applicable, fiat currency payment records (such as credit card receipts). We do not store full credit card numbers; these are handled by PCI-DSS compliant third-party payment processors.

Communication Data: Records of correspondence (emails, support tickets) when you contact our support team.


3. Purposes of Processing

Your data is processed for the following legitimate purposes based on LGPD legal bases:

Service Delivery & Execution: To develop, deploy, and manage smart contracts, tokens, and NFTs on your selected blockchain networks. Wallet addresses are necessary to execute on-chain functions (Art. 7, V).

Communication & Support: To respond to inquiries, provide technical assistance, and send service-related notifications (Art. 7, V).

Billing & Payment Processing: To process payments, issue invoices, and reconcile cryptocurrency transactions (Art. 7, V).

Security & Fraud Prevention: To monitor and prevent abusive, fraudulent, or unauthorized use of our services (Art. 7, IX - Legitimate Interest).

Legal Compliance: To fulfill obligations under applicable laws, including tax regulations and anti-money laundering (AML) requirements (Art. 7, II).

Service Improvement & Analytics: To analyze anonymized browsing patterns to optimize website performance (Art. 7, IX).


4. Data Storage and Security

We implement industry-standard technical and organizational measures (such as TLS 1.3 encryption in transit, AES-256 encryption at rest, and multi-factor authentication) to protect your personal data.

However, we establish a strict distinction between off-chain and on-chain data:

Off-chain data: Personal identification data, browsing data, and payment logs are stored in secure, encrypted databases hosted on third-party cloud infrastructure providers who comply with LGPD security standards.

On-chain data: Wallet addresses, transaction hashes, smart contract code, and token/NFT metadata deployed on public blockchains are immutable and public. Once recorded on a decentralized ledger, such data cannot be deleted, altered, or anonymized by Lumini dApps. Users assume full responsibility for any personal data they choose to embed in on-chain content.


5. Data Sharing

We may share your personal data with third parties only under these conditions:

Service Providers: Trusted partners who assist in operating our platform (hosting, payment gateways, support desks, analytical software) under strict LGPD compliance contracts.

Legal Authorities: When required by a court order, subpoena, or applicable tax and financial regulatory frameworks.

Corporate Transactions: In the event of a merger, acquisition, or asset sale, subject to continued protection under this policy.

We do not sell, rent, or trade your personal data with third parties for marketing purposes.


6. User Rights (LGPD Compliance)

In accordance with Article 18 of the LGPD, you have the following rights regarding your personal data:

Confirmation of processing: The right to verify whether we process your data.

Access: The right to obtain a copy of the personal data we hold about you.

Correction: The right to request the rectification of incomplete or outdated data.

Deletion or Anonymization: The right to request the deletion or anonymization of unnecessary or excessive data.

Portability: The right to request the transfer of your data to another service provider.

Revocation of Consent: The right to withdraw your consent at any time.

Critical Limitation Regarding Blockchain Data:

Rights related to deletion, anonymization, and portability cannot be applied to on-chain data that has been permanently recorded on a public blockchain. Due to the decentralized and immutable nature of blockchain technology, Lumini dApps is technically unable to alter or remove data once a transaction is successfully confirmed.


7. Changes to This Policy

We reserve the right to update this Privacy Policy from time to time. Material changes will be communicated through a notice on our website and, if you are a registered user, via the email address on file. The revised version will become effective on the date of publication.


8. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or your data subject rights, please contact our Data Protection Officer (DPO):

Data Protection Officer (DPO): Lumini dApps Compliance Team
Email: dpo@luminidapps.com
Address: 51 Ana Benvinda de Andrade Street - Office 11 – Alto de Santana, São Paulo – SP, 02403-030, Brazil