Privacy Policy

Effective: June 22, 2026

This Privacy Policy describes how Lumina Markets Inc. collects, uses, shares, and protects information about visitors to its website during the period before Lumina commences operations as an introducing broker. Lumina is not yet offering brokerage services. This Policy will be replaced by an updated privacy policy at the time Lumina launches its services, and we will notify users of the updated policy at that time.

1. Introduction

Lumina Markets Inc. ("Lumina," "we," "our," or "us") is a Delaware corporation that has applied for registration with the U.S. Commodity Futures Trading Commission (the "CFTC") as an introducing broker and is in the process of seeking membership in the National Futures Association (the "NFA"). At this time, Lumina is not yet offering brokerage services. We are preparing to launch a prediction market platform for U.S. residents, subject to obtaining all necessary regulatory approvals.

This Privacy Policy (the "Policy") applies to information we collect through our website at luminamarkets.com (the "Site"), including in connection with our pre-launch waiting list. By accessing or using the Site, you acknowledge that you have read and understood this Policy.

When Lumina launches its services, we will replace this Policy with an updated privacy policy that reflects the additional categories of information we will then collect (such as customer identification, brokerage account, and transaction information). We will notify users of the updated policy by email or by posting a notice on the Site, and the updated policy will supersede this Policy from the date of launch.

2. Scope of This Policy

This Policy applies to information we collect: (i) when you visit, use, or interact with the Site; (ii) when you submit your email address to our pre-launch waiting list; and (iii) when you communicate with us by email or otherwise.

This Policy does not apply to: (a) any future brokerage services offered by Lumina once it has obtained the necessary regulatory approvals (which will be governed by the updated privacy policy described in Section 1); or (b) the practices of any third party whose website or service is linked from the Site.

3. Information We Collect

Because Lumina is not yet operational, we collect a deliberately limited set of information through the Site.

Information You Provide to Us

  • Email address, when you sign up for our pre-launch waiting list to be notified at launch.
  • Name and other contact information, if you choose to provide it (for example, when you contact us by email or submit an inquiry through the Site).
  • Communications, including the content of emails and other messages you send to us, and your contact preferences.

Information We Collect Automatically

  • Device and connection data, including your IP address, device type, operating system, browser type and version, time zone, and similar technical attributes. We do not collect mobile advertising identifiers through the Site.
  • Usage and event data, including the pages you view on the Site, the features you use, the actions you take (such as signing up for the waiting list), and the dates and times of your visits.
  • Approximate location derived from your IP address.
  • Cookies and similar technologies, including software development kits, tags, and pixels used for analytics, measurement, and advertising, as described in Section 6.
  • Log data and crash reports, including diagnostic information collected when an error occurs on the Site.

Information We Do Not Collect

Because Lumina is not yet offering brokerage services, we do not collect Social Security numbers, government identification documents, financial-account information, suitability information, or other categories of information typically associated with opening a brokerage account. We will collect such information only after we have launched our services and you have chosen to apply for an account, and that collection will be governed by our updated privacy policy at that time.

4. How We Use Information

We use the information described in Section 3 for the following purposes:

  • To operate and improve the Site, including by analyzing aggregated usage patterns, debugging, and developing new features.
  • To manage the pre-launch waiting list, including by sending you updates about Lumina, notifying you when our services launch, and responding to your inquiries.
  • To respond to your communications and provide you with information about Lumina.
  • For marketing and advertising, including to measure the effectiveness of our marketing campaigns, deliver advertising for Lumina on third-party platforms, and reach audiences who may be interested in Lumina at launch. This use involves sharing certain information with third-party advertising platforms as described in Section 5.
  • To comply with our legal obligations and respond to lawful requests from regulators, self-regulatory organizations, and other authorities.
  • To detect and prevent fraud, abuse, and security incidents affecting the Site.
  • In aggregated or de-identified form, for analytical, research, and business-reporting purposes. We maintain and use de-identified information in de-identified form and do not attempt to re-identify it except as permitted by law.

5. How We Share Information

Lumina does not sell personal information in exchange for monetary consideration. We share certain personal information with third-party advertising platforms for cross-context behavioral advertising and measurement, as described below. You may opt out of this sharing at any time, as described in Section 9. Other than as described in this Section 5, we share information only as permitted or required by law.

Third-Party Advertising Platforms

Lumina uses pixels, software development kits, server-side integrations (sometimes referred to as Conversions APIs or equivalent), and similar technologies to share information with third-party advertising platforms for the purposes of (i) measuring the effectiveness of our marketing, (ii) reaching potential users with advertising about Lumina, and (iii) building and refining audiences for future advertising campaigns. This activity constitutes "sharing" of personal information for cross-context behavioral advertising under the California Consumer Privacy Act and analogous concepts in other U.S. state privacy laws.

The categories of information shared with third-party advertising platforms include hashed identifiers (such as a one-way hash of your email address or telephone number, where you have provided one), pseudonymous user identifiers assigned by us, device and connection data, and event data describing your interactions with the Site (such as page visits, form submissions, and waiting-list sign-ups). We do not share government identifiers, financial-account numbers, or unhashed contact information with advertising platforms.

Where you opt out of this sharing or send us an opt-out preference signal (see Section 9), we apply each advertising platform's Limited Data Use or equivalent mechanism on a per-platform basis. Under Limited Data Use, the advertising platforms may continue to use information they have already received for aggregate measurement and modeling purposes but will not use that information to target advertising to you or to include you in custom or lookalike audiences.

Service Providers

We share information with third-party service providers that perform services on our behalf and under contractual obligations of confidentiality and limited use. The categories of service providers we use during the pre-launch period include website hosting and infrastructure providers, email-delivery and waiting-list management providers, customer-relationship and lifecycle-management providers, analytics and crash-reporting providers, customer-support providers, and professional advisers (auditors, accountants, and outside legal counsel).

Affiliates

We share information with affiliates that support technical operations on our behalf, subject to the same confidentiality and security standards that apply to Lumina personnel.

Regulators and Law Enforcement

We may share information with the CFTC, NFA, and other governmental and self-regulatory bodies, in response to subpoenas, examinations, regulatory reporting obligations, and other lawful requests. We may also share information with law enforcement and other parties as required by law or to protect the rights, property, or safety of Lumina or others.

Corporate Transactions

If Lumina is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, information about you may be transferred to the counterparty or successor entity, subject to confidentiality protections.

With Your Direction or Consent

We share information with other parties when you direct us to do so or when you otherwise consent to the sharing.

6. Cookies and Similar Technologies

We and our service providers use cookies, software development kits, pixels, tags, and similar technologies (collectively, "Cookies") to operate the Site and to support analytics, measurement, and advertising. Cookies allow us to recognize you across sessions, maintain your preferences, secure the Site, conduct first-party analytics, and (subject to your choices) share information with third-party advertising platforms as described in Section 5. You can control browser-based Cookies through your browser settings, and you can control sharing for advertising purposes through the choices described in Section 9. If you disable strictly necessary Cookies, parts of the Site may not function correctly.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected. Approximate retention periods for the categories of data we hold during the pre-launch period are as follows:

  • Waiting-list email addresses and contact information: retained until you unsubscribe or until a reasonable period after launch, whichever occurs first.
  • Analytics event data in third-party analytics tools (such as Google Analytics): retained for approximately 14 months, after which the data is automatically deleted by the analytics provider.
  • Marketing and event data in our internal data warehouse: retained for approximately 25 months, after which the data is deleted or de-identified.
  • Information shared with third-party advertising platforms: retained by each advertising platform in accordance with that platform's own retention policies, which Lumina does not control.

At launch, the data we hold about you will be subject to the retention practices set forth in our updated privacy policy, which will reflect the books-and-records and other retention obligations applicable to introducing brokers. When we no longer have a business or legal need to retain personal information, we will delete or de-identify it.

8. Information Security

Lumina maintains administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of personal information, including encryption of data in transit, access controls, and security monitoring. No method of transmission or electronic storage is completely secure, and we cannot guarantee that information about you will not be accessed by unauthorized persons despite our efforts. If you believe your information has been compromised, please contact us at security@luminamarkets.com.

9. Your Choices

Unsubscribing from the Waiting List

You may unsubscribe from our pre-launch waiting list at any time by following the unsubscribe instructions in any email we send you or by emailing privacy@luminamarkets.com.

Opting Out of Sharing for Cross-Context Behavioral Advertising

You may opt out of our sharing of personal information with third-party advertising platforms for cross-context behavioral advertising by:

  • Selecting "Do Not Sell or Share My Personal Information" on the Site;
  • Submitting an opt-out preference signal recognized under applicable law, including the Global Privacy Control ("GPC"), through your browser or browser extension; or
  • Emailing privacy@luminamarkets.com.

Cookies and Tracking Choices

You may control browser-based Cookies through your browser settings. If you disable strictly necessary Cookies, parts of the Site may not function correctly.

Data Deletion

You may request that we delete the personal information we hold about you, including your waiting-list email address and any communications you have sent to us, by emailing privacy@luminamarkets.com. Upon receipt of a deletion request, we will delete the personal information we hold and will instruct our service providers and third-party advertising platforms to delete, or to stop using, the information they hold about you, subject to their respective technical capabilities. Personal information that has already been used by advertising platforms for aggregate measurement, modeling, or similar purposes may not be fully reversible at the platform level. We may retain limited information as required by applicable law (for example, records relating to fraud prevention or legal obligations).

Access and Correction

You may request access to, or correction of, the personal information we hold about you by emailing privacy@luminamarkets.com. We will respond to your request within the timeframes required by applicable law.

10. Children's Privacy

The Site is intended for individuals who are at least 18 years of age. The Site is not directed to children under 13 within the meaning of the Children's Online Privacy Protection Act ("COPPA"), and we do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a child under 18, we will delete that information promptly. If you believe a child has provided personal information to us, please contact privacy@luminamarkets.com.

11. U.S. State Privacy Rights

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states with comparable consumer privacy laws as they take effect may have certain rights under applicable state law, including:

  • The right to know what personal information we have collected;
  • The right to request access to or a copy of that information;
  • The right to request correction or deletion of that information;
  • The right to opt out of the sale or sharing of personal information and the use of personal information for targeted advertising; and
  • The right not to be discriminated against for exercising any of the foregoing rights.

As described in Section 5, Lumina shares personal information with third-party advertising platforms for cross-context behavioral advertising. Lumina does not sell personal information in exchange for monetary consideration. You may exercise your right to opt out of this sharing using any of the methods described in Section 9, including by selecting "Do Not Sell or Share My Personal Information" on the Site, by sending an opt-out preference signal such as the Global Privacy Control, or by emailing privacy@luminamarkets.com.

To exercise your other rights, please email privacy@luminamarkets.com. We will verify your identity before responding and may require you to provide additional information for verification purposes. We will respond within the timeframes required by applicable law (typically 45 days, with one extension permitted in certain circumstances). You may designate an authorized agent to make a request on your behalf, in which case the agent will be required to provide proof of authorization. If we deny your request, we will provide instructions for submitting an appeal in our response, where appeal rights apply under your state's law.

Lumina does not collect "consumer health data" within the meaning of the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, or comparable laws.

12. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by posting an updated version of this Policy on the Site, by email, or through other reasonable means, and we will update the "Effective" date at the top of this Policy. As described in Section 1, we will replace this Policy with an updated privacy policy at the time Lumina launches its services, and we will notify users of the updated policy at that time.

13. How to Contact Us

If you have questions, comments, or complaints about this Policy or our information practices, please contact us:

Lumina Markets Inc. Attention: Privacy Officer 895 Broadway, 5th Floor New York, NY 10003 Email: privacy@luminamarkets.com Website: luminamarkets.com

If you need this Policy in an alternative format for accessibility purposes, please contact privacy@luminamarkets.com.

Do Not Sell or Share My Personal Information

Use this control to opt out of the sharing of your personal information with third-party advertising platforms for cross-context behavioral advertising, as described in Sections 5 and 9. Your choice is saved on this browser.

Do not sell or share my personal information