Lumina AI Privacy Policy

This Privacy Policy describes how MSA CORE LLC (“MSA CORE”, “we”, “our”) processes information in connection with the Lumina AI mobile application (the “App”).

Lumina AI is an informational and decision-support application. It is not a buy/sell, investment-advice or trading-instruction platform, and it does not connect to any broker, exchange or trading account.

1. Information We May Process

The App may process the following categories of information:

• Device account / local identifier — The App may operate with a private, device-based account or local identifier. Email address is collected only if you contact support, create an optional account, or use future cloud-based or account-linked features.
• Device information — operating system, device model, app version, language, time zone and similar technical attributes used to deliver and stabilise the service.
• Diagnostic data — crash reports, performance metrics and anonymised event logs used to detect and fix technical issues.
• App usage data — non-identifying interaction data (e.g. screens opened, feature usage frequency) used to improve product quality and inform behavioral personalization of decision-support surfaces.
• Market preferences — selected assets, watchlists, alert settings, language, plan state, and context preferences. These preferences are stored locally on your device unless you explicitly enable cloud sync.
• Push notification data — if you opt in to push alerts: push tokens, device ID, platform, app version, language and locale, alert preferences, and delivery status. We do not send unsolicited notifications.
• Subscription entitlement data — subscription status and entitlements are processed through Google Play or Apple App Store billing, managed via RevenueCat. We receive entitlement confirmation (active, expired, cancelled) only. We do not receive or store payment card or banking details. Subscription management and cancellation are handled directly through the app store from which you purchased. Purchase and restore are separate from app login.
• Questions you ask Ask Lumina — the question you type or select, the market and timeframe it concerns, and the Lumina market data needed to answer it. We process this only after you give permission in the App (see section 4A).
• Analytics on Android (Google Analytics for Firebase) — from app version 1.1.32, the Android App uses Google Analytics for Firebase, a Google service, to measure app use and subscription events. It collects a random app-instance identifier that is reset when you reinstall the App; automatically logged events such as first open, sessions, engagement time, app and operating-system updates, and in-app purchases with product and price; device information (model, operating-system version, app version and language); and an approximate location (country, region or city) that Google derives from your IP address. The App does not allow Google Analytics to collect your device’s advertising ID or Android ID, ad personalization is turned off, and Google signals are not used. We pass the app-instance identifier to RevenueCat so that subscription events (trial start, purchase, renewal, cancellation and expiration, with the amount and currency) are recorded in our Google Analytics property.
• Apple Ads attribution on iOS — from app version 1.1.32, if you install the iOS App after interacting with an Apple Ads advertisement on the App Store, the App obtains an attribution token from Apple’s AdServices framework and sends it to RevenueCat. RevenueCat exchanges the token with Apple for details of that advertisement, such as the campaign, ad group, keyword and country or region, and stores them with your subscription record. The App does not access the advertising identifier (IDFA) and does not ask for permission to track you.

2. Data We Do Not Collect

The App does not collect, access, or store:

• Brokerage credentials or trading account login details
• Exchange credentials or API keys
• Bank account, card, or payment details
• Government-issued identification documents
• Biometric data of any kind
• Order history, trading positions, or account balances
• Any data that would allow us or any third party to execute trades on your behalf

Lumina AI does not connect to any broker, exchange account, or trading account and cannot execute trades.

3. How Information May Be Used

• To operate, maintain and improve the App and its decision-support features.
• To detect and prevent abuse, fraud and security incidents.
• To diagnose technical issues and stability problems.
• To comply with applicable legal obligations.
• To answer the questions you ask Ask Lumina, with your permission.
• To measure how the App is used and which of our own advertising campaigns lead to installs and subscriptions.

We do not sell personal information. We do not use personal information to issue investment advice or buy/sell instructions.

4. AI and Behavioral Analysis

Lumina AI uses behavioral and contextual analysis features to surface decision-support information to the user (for example: behavioral risk awareness, decision pressure context, discipline awareness). These features are informational and educational. They are not price predictions, market directions, or execution-related recommendations of any kind.

Where models are used, inputs are processed to generate informational outputs only. The user remains fully responsible for any decision they take based on the information surfaced inside the App.

4A. Ask Lumina and our AI service provider (OpenAI)

Permission first. Ask Lumina uses OpenAI, L.L.C. (“OpenAI”) to write answers. Before your first question, the App explains what is sent and asks for your permission. Nothing is sent to OpenAI unless you choose “Accept and Continue”. If you choose “Cancel”, nothing is sent, and the rest of the App keeps working.

What is sent. Your question, the market and timeframe it concerns, and the Lumina market data needed to answer it. We do not send your name, email address, payment details, or your account or device identifiers. Please do not include personal information in your questions.

Why. To generate the answer you asked for. Our legal basis is your consent.

How OpenAI handles it. OpenAI processes this data as our service provider under its API terms. Under our API settings, it is not used to train OpenAI’s models. OpenAI may keep API data for up to 30 days to detect abuse and misuse, and may keep data longer where the law requires. OpenAI processes data in the United States and other countries.

What we keep. Our servers process your question to obtain the answer, but we do not store the text of your question. We keep the generated answer in a cache that contains no account or device identifier and no question text, so that an identical question about an unchanged market can be answered without another AI request. Cached answers expire after 15 minutes and are deleted automatically shortly after they expire. We also keep daily usage counts (number of AI requests, token counts and estimated cost) for your plan’s limits and for cost control; Ask Lumina’s per-account count is stored under a pseudonymous key. The conversation shown in the App is kept only in the App’s memory while you use it.

Withdrawing permission. You can withdraw your permission at any time in Profile › Settings › AI processing. After that, the App sends no further questions to OpenAI. Withdrawal does not affect data sent before it, which is handled as described above. Your permission is stored on your device, and the App asks again if this disclosure changes materially or if your account changes.

5. Data Sharing

We share limited information with service providers that act on our instructions and under appropriate confidentiality obligations: cloud hosting; Apple and Google (app distribution, in-app purchases and push notification delivery); RevenueCat (subscription status and, on iOS, Apple Ads attribution); Google (Google Analytics for Firebase on Android, as described in section 1); and OpenAI (Ask Lumina answers, only with your permission, as described in section 4A). Our Google Analytics property is linked to our Google Ads account so that we can count purchases that follow our own ads; personalized advertising is turned off for that link. We do not sell personal information, we do not share it with third parties for their own advertising, and we do not track you across other companies’ apps or websites. We may disclose information where required by law or to protect the rights, safety and integrity of MSA CORE, our users or third parties.

6. Data Retention

Device-based preferences and local identifiers are retained as long as the App is in use. Telemetry and crash logs are retained for up to 24 months, or a shorter period if configured. Support messages are retained only for as long as needed to resolve the request or as required by applicable law. Diagnostic and usage data may be retained in aggregated or anonymised form beyond these periods. Questions sent to OpenAI are handled under OpenAI’s retention described in section 4A. Ask Lumina usage counts are kept for as long as needed for plan limits, cost control and abuse prevention. Google Analytics keeps event-level data for 2 months and user-level data for up to 14 months; aggregated reports may be kept longer. Apple Ads attribution details are kept with your subscription record for as long as that record exists.

7. Security

We apply technical and organisational measures designed to protect information against unauthorised access, alteration, disclosure or destruction. No system can be guaranteed fully secure, and you use the App at your own risk.

8. Your Choices and Rights

Depending on your jurisdiction, you may have rights to access, correct, delete or restrict processing of your personal information. To exercise such rights, contact us at the address below. We may need to verify your identity before acting on a request. Where we rely on your consent, as with Ask Lumina, you can withdraw it at any time in the App without affecting the lawfulness of processing before the withdrawal. On Android, reinstalling the App resets the Google Analytics app-instance identifier.

9. Children

The App is not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If you believe a minor has provided us with personal information, please contact us so we can delete it.

10. International Transfers

Information may be processed in countries other than your country of residence. Where required, we apply appropriate safeguards for such transfers.

11. Changes to this Policy

We may update this Privacy Policy from time to time. The updated version takes effect when published on this page. Continued use of the App after a change constitutes acceptance of the updated Policy.

12. User Responsibility

Lumina AI provides informational and decision-support features only. The user remains solely responsible for any trading, financial or operational decision they take, regardless of any information surfaced inside the App.

13. Contact

MSA CORE LLC · Wyoming, USA · [email protected]