Privacy Policy

This Privacy Policy describes how MSA CORE LLC (“MSA CORE”, “we”, “us”) collects, uses and protects information when you use the Lumina AI mobile application, the Lumina Core platform, the MSA CORE website (msacore.net) and any related services (collectively, the “Services”).

1. Information We Collect

We collect only what is necessary to operate the Services:

• Account information: Lumina AI 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 & technical data: device model, OS version, app version, language, time zone, IP address, crash logs, performance telemetry.
• Usage data: screens viewed, features opened, app interactions, stability and crash data, and anonymous product telemetry.
• Market preferences: selected assets, watchlists, alert settings, language, plan state, and context preferences. These preferences stay 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 app store billing providers (Google Play, Apple App Store) and RevenueCat. We receive entitlement status only and do not store payment card or banking details.
• Support contact data: if you contact support, we keep the messages and your contact details for the duration needed to resolve the request.

We do not collect: brokerage credentials, trading account credentials, exchange credentials, API keys, bank account information, government IDs, biometric data, or any data that allows us to place trades. Lumina AI does not connect to any broker, exchange account, or trading account and cannot execute trades.

2. How We Use Information

• To operate, maintain and secure the Services.
• To deliver behavioral analytics and decision-support content inside the application.
• To diagnose crashes, fix bugs, and improve product quality.
• To communicate with you about updates, security alerts, and support requests.
• To comply with legal obligations and to enforce our Terms of Service.

3. Legal Bases (GDPR / KVKK)

Where the GDPR or Turkish KVKK applies, we process personal data on the bases of: (a) performance of a contract with you, (b) our legitimate interests in operating and improving the Services, (c) your consent where required, and (d) compliance with legal obligations.

4. Sharing of Information

We do not sell personal data. We share data only with:

• Infrastructure providers (hosting, database, crash reporting, analytics) that process data on our behalf under contract.
• App store billing providers and RevenueCat for subscription and entitlement processing. We receive entitlement status only and do not store payment card or banking details.
• Authorities when legally required by valid court order or applicable law.

5. 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. You can request deletion of your data at any time by contacting [email protected].

6. Your Rights

Subject to applicable law, you have the right to access, correct, delete, restrict or object to processing of your personal data, the right to data portability, and the right to withdraw consent at any time. To exercise these rights, email [email protected].

7. Children

The Services are not directed to individuals under 18. We do not knowingly collect data from children. If you believe a minor has provided us data, contact us and we will delete it.

8. Security

We use industry-standard safeguards (encryption in transit, access controls, audit logs). No system is perfectly secure; we cannot guarantee absolute security and you use the Services at your own risk.

9. International Transfers

Data may be processed in the United States, the European Union or other jurisdictions where our infrastructure providers operate. We rely on standard contractual clauses or equivalent safeguards where required.

10. Changes to this Policy

We may update this Privacy Policy from time to time. The “Effective” date at the top reflects the latest version. Material changes will be communicated in-app or by email.

11. Contact

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