User Privacy Policy

Last updated: February 2026 Effective as of: February 2026

Introduction

We are committed to respecting and protecting each individual's privacy rights. This Privacy Policy explains how the website and its wholly-owned subsidiaries and holding subsidiaries (collectively, the "Company," "we," "our," or "us," meaning Lumenary Codex Inc and its affiliates; where "holding" refers to direct or indirect ownership of 50% or more) collect, use, disclose, or share end-user information ("you" or "your") through our advertising platform (the "Advertising Service"), our website (the "Website"), our mobile applications (the "App"), and any other products or services we provide (collectively, the "Services"). This Policy applies whether you access the Services directly or through a third party.

Except as specifically described below, this Privacy Policy does not apply to information collected by third parties—for example, other companies, websites, or mobile applications—even if they are linked to or accessible through our Services.

Scope—We collect information when users: (i) visit our Website; (ii) view ads served by our Advertising Service; (iii) interact with our Advertising Service; or (iv) interact with platforms, applications, websites, or other products or services provided by our business partners (e.g., app publishers, advertisers).

When you use the Services, and where applicable under relevant laws, you consent to our collection, use, and disclosure of information as described in this Privacy Policy. Under other legal frameworks, we may collect, use, or disclose your information based on appropriate legal bases. Please review this Privacy Policy before using the Services. We may amend it from time to time; any updates will be posted on our Website. Please check regularly for the most recent version. Where permitted by applicable law, your continued use of the Services after the effective date constitutes your acknowledgment and acceptance of the revised Privacy Policy.

1. What Information We Collect and How

We may collect, transmit, store, and otherwise process information about you in connection with your use of the Services, including information you send to or through the Services. We use this information to provide and improve the Services, fulfill requests, conduct analysis, personalize experiences, track usage, display relevant advertising, assist our partners, provide customer support, back up our systems, ensure security, and comply with legal obligations. Even when information is not retained, it must be transmitted to our servers and temporarily stored for processing.

Information you provide may include: name, gender, date of birth, personal ID numbers, address, phone number, email address, occupation, education, work experience, and other information you choose to provide.

Passively collected information includes: browser information (user agent), browser type, IP address, device type, Identifier for Advertising (IDFA), Google Advertising ID (GAID), interaction with ads (views, clicks, engagement), device identifiers, domain name, pages visited, session duration, and log data collected via IP, cookies, tags, SDKs, or similar technologies.

Cookies: We use cookies to collect device and network information such as access time and date, device characteristics, and domain access data. This information is used internally to analyze and optimize performance; cookie-based data does not personally identify you.

Information from third-party partners: companies providing services to us, publishers, advertisers, analytics or attribution partners.

2. How We Use Your Information

We use personal and non-personal information to: provide, operate, maintain, and improve our Services; carry out internal business operations; assist customers or partners in improving their offerings; compile aggregate analytics for internal/external use; prevent illegal or fraudulent activities; handle customer service requests and user accounts; comply with legal and regulatory requirements; and enforce our Terms and Conditions.

We may also use device-level information to: display advertisements, including interest-based ads; conduct real-time ad bidding; measure ad effectiveness across devices; provide advertisers with reporting and analytics; and build custom audience segments.

Legal Basis for Processing: 2.1 Legitimate Interests: For example, tracking and reducing fraudulent traffic, verifying ad performance, preventing and detecting crime, analyzing device data to optimize ad performance, conducting ongoing business analysis, and optimizing our in-house Apps. We conduct a balancing test to ensure our legitimate interests are not overridden by your rights and freedoms. 2.2 Compliance with Legal Obligations: We may process personal information where required to comply with applicable laws.

3. Intellectual Property & Content Ownership

3.1 Platform IP: All intellectual property rights in the Services—including software, algorithms, models, interfaces, trademarks, logos, and documentation—belong to the Company (Lumenary Codex Inc) or its licensors. You may not copy, reverse-engineer, redistribute, or commercially exploit them without written authorization. 3.2 User-Generated Content (UGC): You retain ownership of materials you upload (e.g., images, audio, video, text). You warrant that you hold all necessary rights or licenses and that such content does not infringe any third party's copyright, likeness, privacy, or other rights. You are solely liable for infringement arising from your uploaded content. 3.3 AI-Generated Content: Provided you use the Services lawfully and comply with this Policy and our Terms, we assign to you—to the extent permitted by applicable law—such rights as we can claim in the output for your lawful use. You understand that generated content may lack originality or copyright protection, and that copyrightability of AI-generated content varies across jurisdictions. 3.4 License Grant: To provide, operate, moderate, secure, and improve the Services, you grant us a worldwide, non-exclusive, royalty-free license to store, process, reproduce, and display your uploaded and generated content. This license terminates within a reasonable technical period after you delete the content or account, except where retention is legally required or irreversible backups have been generated.

4. Prohibition of Content Abuse

When using the Services (especially AI image/audio/video generation, editing, or face-swap features), you are strictly prohibited from: 4.1 Deepfake / Face-Swap Abuse: Using another person's likeness, face, or voice for face-swapping or deepfakes without their explicit consent, or creating misleading synthetic media. 4.2 Pornographic & Sexualized Content: Generating, uploading, or distributing pornographic or obscene material, or any sexualized content involving minors (strict zero tolerance). 4.3 Infringement & Personality Rights: Violating others' likeness, reputation, privacy, or intellectual property rights. 4.4 Illegal & Harmful Content: Using the Services for fraud, defamation, intimidation, harassment, hate speech, violence or terrorism, misinformation, or any purpose that violates applicable law. 4.5 Enforcement: Upon detection, we may remove the content, restrict or terminate your account without prior notice, preserve evidence, and report to competent authorities where legally required or permitted. Sexualized content involving minors will be reported to law enforcement (including the U.S. National Center for Missing & Exploited Children, NCMEC) as required by law.

5. Computing Resources Usage

5.1 Quota & Rate Limits: AI generation features rely on finite computing resources. We may set limits on request frequency, concurrency, generation duration, or quota per unit of time, and may adjust these based on plan tier, risk controls, or system load. 5.2 Resource Abuse: You may not abuse computing resources via scripts, crawlers, automated bulk requests, multi-account quota circumvention, or abnormally high-frequency calls. Such conduct may result in throttling, suspension, or termination of service. 5.3 Metering & Logging: For billing, abuse prevention, and capacity planning, we log your resource usage (e.g., call counts, generation duration, quota consumed). Such data forms part of the passive information described in Section 1. 5.4 Availability: Under high load, maintenance, or force majeure, generation tasks may be queued, degraded, or delayed. We are not liable for resulting waits beyond what applicable law requires.

6. Protection of Minors

6.1 Age Threshold: The Services are intended for adults. You must be at least 18 years old (or the age of majority in your jurisdiction, whichever is higher) to use the Services. 6.2 Guardian Consent: Where applicable law permits use by minors with consent, the explicit consent of a parent or legal guardian must be obtained, and use must be supervised by the guardian. 6.3 No Knowing Collection: We do not knowingly collect personal information from children under 13 (in accordance with the U.S. Children's Online Privacy Protection Act, COPPA). 6.4 Deletion Upon Discovery: If we learn that we have collected such a child's personal information without guardian consent, we will delete it and terminate the related account within a reasonable period. 6.5 Reporting: If you believe we may hold a minor's information, please contact us using the details below; we will promptly investigate and address it.

7. Governing Law, Jurisdiction & Cross-Border Transfers

7.1 Governing Law: This Privacy Policy and any dispute arising out of or relating to it are governed by and construed in accordance with the laws of the State of Colorado, United States and applicable U.S. federal law, without regard to its conflict-of-laws rules. 7.2 Jurisdiction: Disputes shall be subject to the exclusive jurisdiction of the state or federal courts located in El Paso County (Colorado Springs), Colorado; where permitted by applicable law and mutually agreed, disputes may be submitted to arbitration administered by the American Arbitration Association (AAA) under its rules, seated in Colorado. 7.3 Data Location & Cross-Border Transfers: Your information may be transferred to the United States and to other countries/regions where our servers or service providers are located, for storage and processing. When data is transferred from the EEA, the UK, or other regions with cross-border restrictions to the U.S., we implement appropriate safeguards required by applicable law (e.g., Standard Contractual Clauses). 7.4 Regional Law Notices:

• Colorado users: Protected under the Colorado Privacy Act (CPA), with rights to access, correct, delete, port data, and opt out of targeted advertising and the "sale" of personal data.

• California (US) users: Within the scope of the CCPA/CPRA, you have rights to know, delete, correct, and opt out of the "sale/sharing" of personal information.

• EU/EEA & UK users: Within the scope of the GDPR / UK GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, and objection.

• Other regions: We process your information in accordance with the data protection laws applicable in your jurisdiction.

8. Retention, Security & Your Rights

8.1 Retention: We retain information only as long as necessary for the purposes in this Policy, or longer where required by applicable law; thereafter it is deleted or anonymized. 8.2 Security: We apply reasonable technical and organizational measures (e.g., encryption in transit, access controls), though no method of transmission or storage is completely secure. 8.3 Your Rights: Within the limits of applicable law, you may access, correct, or delete your personal information, withdraw consent, object to or restrict processing, and exercise data portability. Submit requests via the contact details below; we will respond within the statutory period.

9. Contact Us

If you have any questions or concerns about our information practices, please contact us.

• Legal entity: Lumenary Codex Inc

• Registered address: 1755 Telstar Dr #340, Colorado Springs, CO 80920, USA

• Phone: +1 815-650-1239