PRIVACY POLICY
Last updated: September 22, 2026

This Privacy Policy explains how Luma Strategy LLC, operating the Luma Strategy website and brand (“Luma Strategy,” “Luma,” “we,” “our,” or “us”), collects, uses, discloses, retains, and protects personal information when you visit lumastr.com (the “Site”), contact us, purchase a digital product, or use our Services.

1. Information We Collect
We may collect information you provide directly, including your name, email address, telephone number, country of residence, company and business information, billing and contact information, appointment information, and the contents of messages you send us. When you engage us for an administrative or business-support service, we may also collect information reasonably necessary to perform that service, such as company ownership and management information, addresses, identification information, information required for EIN, state filing, bank, fintech, marketplace, or payment-platform applications, documents you provide, and our communications with you.

Payments are processed by third-party payment processors. We may receive transaction information such as your name, payment amount, transaction status, and limited payment-card information, but we do not store full payment-card numbers.

We may automatically receive technical information such as IP address, browser and device information, pages viewed, referral source, and similar usage information through cookies or comparable technologies actually enabled on the Site.

2. Sensitive Information
Please do not submit Social Security numbers, taxpayer identification numbers, passport or visa numbers, government identification numbers, bank-account credentials, passwords, medical records, or other sensitive information through a general contact form, ordinary email, or messaging application. If sensitive information is reasonably necessary for an accepted engagement, we may designate a more appropriate transmission method. We collect sensitive information only when reasonably necessary for the Service requested or where required by law.

3. How We Use Information
We may use personal information to respond to inquiries; determine whether we can accept a requested engagement; provide, administer, and improve Services; prepare or coordinate administrative filings and applications at your direction; schedule consultations; process and document transactions; communicate about purchases, appointments, and engagements; maintain business records; verify information where reasonably necessary; protect the Site and our business against fraud, misuse, and security threats; comply with applicable law; establish or defend legal claims; and send marketing communications where permitted by law. Marketing emails will include an unsubscribe method where required.

4. How We Disclose Information
We may disclose personal information to service providers that help us operate our business, such as website hosting, cloud storage, email, scheduling, customer-relationship management, video conferencing, e-signature, payment processing, security, analytics, or advertising providers, but only to the extent relevant to services we actually use. We may also disclose information to government agencies or third-party providers when you have asked us to coordinate a filing or application; to independent attorneys, accountants, or other professionals with your authorization; when required by law or legal process; to protect rights, property, or security; in connection with a merger, acquisition, financing, reorganization, or sale of business assets; or with your consent. Third-party services process information under their own terms and privacy practices.

5. Cookies and Online Technologies
We may use cookies and similar technologies that are necessary for Site functionality and, if enabled, for preferences, analytics, advertising, campaign measurement, or retargeting. We will not identify a particular analytics, advertising, or tracking provider in this Policy unless that technology is actually used on the Site. Please see our Cookie Policy for additional information and available controls.

6. Sale or Sharing of Personal Information
We do not sell personal information for money. If our use of advertising or other technologies becomes subject to a law that treats a particular disclosure as a “sale,” “sharing,” targeted advertising, or similar regulated activity, we will provide any notice and consumer choice required by applicable law.

7. Data Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of personal information, taking into account the size and complexity of our business, the nature and scope of our activities, and the sensitivity of the information we maintain. Measures may include access controls, secure account practices, appropriate service-provider controls, secure transmission or storage methods where appropriate, and reasonable disposal practices. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and for legitimate business and legal needs, including providing Services, maintaining transaction and business records, resolving disputes, enforcing agreements, preventing fraud, and complying with legal obligations. Retention periods may vary depending on the type of information, the Service provided, and applicable requirements. When information is no longer reasonably needed, we may delete, anonymize, or securely dispose of it as appropriate.

9. Security Incidents
If a security incident involving personal information occurs, we will evaluate and respond to it in accordance with applicable law, including any legally required notifications to affected individuals or government authorities.

10. Your Requests and Choices
You may contact us to request access to, correction of, or deletion of personal information you have provided, or to unsubscribe from marketing communications. Whether a request can or must be honored depends on applicable law and legitimate recordkeeping, fraud-prevention, contractual, and legal obligations. We may verify your identity before acting on a request.

11. Children
The Site and Services are intended for persons 18 years of age or older and are not directed to children. We do not knowingly solicit personal information from children through the Site. If we learn that we have collected personal information from a child in circumstances requiring deletion under applicable law, we will take appropriate steps.

12. International Processing
Luma is based in the United States. Our service providers may process or store information in the United States or other jurisdictions depending on their infrastructure. Privacy and data-protection laws may differ between jurisdictions. We will address any additional transfer or privacy requirements that apply to our activities where required by law.

13. Third-Party Sites and Services
The Site may contain links to third-party websites, platforms, or services. We do not control their privacy or security practices, and this Privacy Policy does not govern information processed independently by those third parties.

14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our Services, technology, business practices, or legal obligations. The current version will be posted on the Site with an updated “Last updated” date. Where required by law, we will provide additional notice.

15. Contact
Luma Strategy
New York, New York, USA
Email: lumateam@lumastr.com