Lumina Privacy Policy

Last Updated: 9 September 2025

Lumina values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share information when you use our eSIM products and services (“Services”).By using Lumina’s Services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect the following categories of personal information:

  1. Identification Data - such as your name, email address, billing address, telephone number.
  2. Account Data - username, password, account preferences, communication history.
  3. Payment Data - payment method, transaction history, currency of purchase.
  4. Device and Technical Data - device identifiers, eSIM activation codes, operating system, IP address, browser type, mobile carrier.
  5. Usage Data - data usage volumes, network performance statistics, logs of service activation/deactivation.
  6. Location Data - approximate geolocation based on IP address or network information (to enable network selection and regulatory compliance).
  7. Communications Data - when you contact our support teams or interact with us through email, chat, or phone.

2. How We Use Your Information

We process personal data for the following purposes:

  1. To provide, activate, and maintain our eSIM and connectivity Services.
  2. To process payments and prevent fraud.
  3. To improve and personalize your user experience.
  4. To comply with telecom regulations, tax obligations, or legal requirements.
  5. To provide customer support and communicate service updates.
  6. For internal analytics and performance monitoring.
  7. For marketing purposes, only where consent has been obtained (where required by law).

3. Your Privacy Rights and Controls

  1. GDPR: You may exercise your rights as outlined in Section 4.
  2. CCPA: California residents may exercise rights outlined in Section 5.
  3. Malaysia (PDPA): Malaysian residents may exercise rights outlined in Section 6.
  4. Philippines (Data Privacy Act): Philippine residents may exercise rights outlined in Section 7.
  5. South Africa (POPIA): South African residents may exercise rights outlined in Section 8.
  6. Kingdom of Saudi Arabia (PDPL): Residents of Saudi Arabia may exercise rights outlined in Section 9.
  7. Colombia (Ley 1581): Colombian residents may exercise rights outlined in Section 10.
  8. Requests: Requests can be made by contacting us (see Section 17). We will verify your identity before processing any request to protect your data.

4. Legal Bases for Processing (GDPR)

Under GDPR, we process your personal data based on one or more of the following legal grounds:

  1. Contractual Necessity - where processing is required to provide you with the Services you purchase.
  2. Legal Obligation - where processing is necessary for compliance with applicable law.
  3. Consent - where we rely on your specific permission (e.g., for marketing communications).
  4. Legitimate Interests - for service improvements, fraud prevention, or internal administration, provided your rights are not overridden.

5. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under CCPA/CPRA:

  1. Right to Know - to request disclosure of categories of data collected, purposes, and third parties your data is shared with.
  2. Right to Access - to request access to the specific personal information we hold about you.
  3. Right to Delete - to request deletion of your personal data, subject to legal retention requirements.
  4. Right to Correct - to request correction of inaccurate personal data.
  5. Right to Opt-Out of Sale/Sharing - Lumina does not “sell” personal data within the meaning of CCPA. If data is ever shared for advertising or marketing, you can opt out.
  6. Right to Limit Use of Sensitive Data - where applicable, limit processing of sensitive categories of data.
  7. Non-Discrimination - you will not be treated differently if you exercise your privacy rights.

6. Malaysia Privacy Rights (PDPA)

If you are a resident of Malaysia, you have the following rights under the Personal Data Protection Act (PDPA):

  1. Right to Access - to request access to the personal data we hold about you.
  2. Right to Correct - to request correction of inaccurate or outdated personal data.
  3. Right to Withdraw Consent - to withdraw your consent to the processing of your personal data at any time.
  4. Right to Prevent Direct Marketing - to object to the use of your data for direct marketing purposes.
  5. Right to Be Informed - to be informed about how your personal data is processed.
  6. Non-Discrimination - you will not be treated differently for exercising your privacy rights.

7. Philippines Privacy Rights (Data Privacy Act)

If you are a resident of the Philippines, you have the following rights under the Data Privacy Act of 2012:

  1. Right to Access - to request access to the personal information we hold about you.
  2. Right to Rectification - to request correction of any inaccurate or incomplete personal data.
  3. Right to Erasure or Blocking - to request deletion or blocking of your data when necessary and allowed by law.
  4. Right to Object - to object to the processing of your personal data, including for marketing.
  5. Right to Data Portability - to obtain a copy or transfer your data to another provider.
  6. Right to Damages - to claim compensation if you suffer damage due to privacy violations.
  7. Right to Lodge Complaints - to file complaints with the National Privacy Commission.
  8. Non-Discrimination - you will not be treated differently for exercising your privacy rights.

8. South Africa Privacy Rights (POPIA)

If you are a resident of South Africa, you have the following rights under the Protection of Personal Information Act (POPIA):

  1. Right to Access - to request confirmation and a copy of your personal information held by us.
  2. Right to Correction or Deletion - to request correction or deletion of inaccurate or unnecessary personal information.
  3. Right to Object - to object to the processing of your personal information under certain circumstances.
  4. Right to Complain - to submit a complaint to the Information Regulator.
  5. Right to Withdraw Consent - to withdraw your consent for data processing at any time.
  6. Non-Discrimination - you will not be treated differently for exercising your privacy rights.

9. Saudi Arabia Privacy Rights (PDPL)

If you are a resident of the Kingdom of Saudi Arabia, you have the following rights under the Personal Data Protection Law (PDPL):

  1. Right to Be Informed - to be informed about the collection and use of your personal data.
  2. Right to Access - to request access to your personal data.
  3. Right to Correction - to request correction or updating of your data.
  4. Right to Deletion - to request deletion of your data as permitted by law.
  5. Right to Object - to object to processing under certain situations.
  6. Right to Limit Data Transfers - to request restrictions on cross-border transfers of your data.
  7. Right to Complain - to file a complaint with the Saudi Data & Artificial Intelligence Authority (SDAIA).
  8. Non-Discrimination - you will not be treated differently for exercising your privacy rights.

10. Colombia Privacy Rights (Ley 1581 de 2012)

If you are a resident of Colombia, you have the following rights under Ley 1581 de 2012:

  1. Right to Know - to request information about the processing of your personal data.
  2. Right to Access - to obtain access to your personal data held by us.
  3. Right to Update or Rectify - to request correction or updating of your data.
  4. Right to Delete - to request deletion of your data when it is excessive, not necessary, or not being processed according to law.
  5. Right to Revoke Consent - to revoke your consent for processing at any time.
  6. Right to Complain - to file complaints with the Superintendence of Industry and Commerce.
  7. Non-Discrimination - you will not be treated differently for exercising your privacy rights.

11. Data Sharing and Transfers

  1. Service Providers: We may share information with trusted vendors and partners (e.g., payment processors, telecom carriers, analytics providers) that assist in delivering our Services.
  2. Legal and Regulatory Authorities: We may disclose data where legally required (e.g., anti-fraud measures, telecom obligations).
  3. International Transfers Personal data may be transferred outside the EEA/UK or California to jurisdictions where our partners (e.g., global network operators) operate. Transfers will be safeguarded by Standard Contractual Clauses or equivalent protections.

12. Data Retention

  1. We retain personal data only as long as necessary for the purpose collected, including contractual, legal, and compliance requirements.
  2. Usage and transaction data may be retained for billing disputes, fraud prevention, or regulatory compliance.
  3. When personal data is no longer required, it will be securely deleted or anonymized.

13. Security of Your Information

  1. We apply organizational, technical, and administrative safeguards designed to protect your data.
  2. However, no internet or telecommunications transmission is 100% secure; we cannot guarantee absolute security.

14. Cookies and Tracking

  1. Lumina may use cookies, web beacons, and similar technologies to improve service performance and analytics.
  2. You can manage cookie preferences through your browser settings.
  3. Where required by law, consent for cookies will be obtained.

15. Children’s Privacy

  1. Lumina Services are not directed toward children under 16 (GDPR) or 13 (CCPA).
  2. We do not knowingly collect personal data from children. If you become aware that a person under the age of 13 has submitted personal data to us, please contact us promptly at legal@Luminasim.com.

16. Changes to this Privacy Policy

  1. Lumina reserves the right to update or modify this Privacy Policy.
  2. If we make material changes, we will notify you by posting the revised policy on our website or contacting you by email (where required by law).

17. Contact Information

To exercise your privacy rights or ask questions about this policy, please contact us:

Lumina Privacy Office

Email: Privacy@Luminasim.com

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