Privacy Policy

At LumaSoft, LLC (“SparkWallet”); we are committed to protecting your privacy. This Privacy Policy describes our policies and practices in relation to how we collect, handle, use and disclose your personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected. What personal information do we collect and hold? 'Personal information' means any details about you, from which your identity is apparent or can be uncovered. When you register with us we ask you for the information we need to provide you with our service and verify your identity. This can include your name, email address, and identity details (for example it could be your drivers' licence). Generally, we will not collect sensitive information about you unless we required to do so by law or unless you provide consent. Sensitive information includes information about your race or ethnicity, political opinions, religious beliefs, criminal record, sexual information, health or biometric information. How do we collect your personal information? Generally, we collect your personal information directly from you. We could do this in a number of ways, including when you register on our app or website or when you contact us.

We may collect personal information about you from other people or organisations where it is not reasonable or practicable for us to collect the information directly from you. Examples of how we may do this include collecting your personal information from: • Our own records; • Organisations who help us verify your identity (such as Plaid); • Other organisations, service providers or business partners who provide you with products or services along with us; • Anyone else who you refer to us or who refers you to us.

We may also collect and disclose personal information about job applicants from and to other people, including their recruiter, university, referees and other sources (for example LinkedIn). This information is commonly employment, qualification, education and criminal history information for the purpose of considering the application. What are the purposes for which we collect, hold, use and disclose your personal information? The main purpose for which we collect, hold, use and disclose personal information is to provide our services to you. Other purposes for which we do this include to: • Verify your identity; • Manage our ongoing relationship with you and improve our services; • Refer you to other organisations, service providers or business partners; • Comply with legal and regulatory requirements, prevent fraud or crime; • Help us improve our services, develop our products and conduct research; and • Promote services, send you news or other information that we believe will be of interest to you. You may opt out of this at any time by getting in contact with us. We may communicate with you electronically unless you tell us that you do not wish to receive electronic communications.

You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to SparkWallet or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud. See our Privacy Policy for how we treat your data.

Will we disclose the personal information we collect to anyone? In connection with our services, we may disclose your personal information to: • Organisations who help us verify your identity (such as Plaid); • Organisations, our agents and contractors who supply services to us (including our data storage provider, our marketing provider and the merchant who sends you rewards); • Other organisations, service providers or business partners whom we consider may provide services or products you would find useful, or who provide you with products or services along with us; • Other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event; • Regulatory bodies, government agencies or law enforcement bodies; and • Others, if we are permitted to or required to do so by law.

We do not sell, trade, or rent your personal information to others. Will we disclose your personal information overseas? We may disclose your personal information to our data storage provider in the United States of America. We will only do so if we believe they are regulated by laws that protect your information in a way that is similar to the Privacy Act. What if you don't provide some personal information to us? If you do not provide us with some or all of the personal information that we ask for, we may not be able to provide you with our services. How do we store and protect your personal information? We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. We hold the information we collect from you in physical and electronic records, which may be stored at our premises or those of our service providers (including Vix Verify), or in secure data centres or in the cloud. We strive to ensure that your information is safe by using a range of physical and electronic security measures to protect it from misuse, interference, loss, unauthorised access, modification or disclosure. What information does our service collect and display? Data - We collect information about the use of our website, for example when you browse our website our service provider logs your IP address, the date and time of your visit, the pages and links accessed and the type of browser used. We collect and store transaction information for bitcoin, lightning and USD transactions in order to provide the service. Cookies - In order to collect this data we use "cookies". Cookies are small pieces of information which are sent to your browser and stored on your computer's hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to not accept cookies or notify you when you receive a cookie so that you can decide if you want to accept it. They allow the website to recognise your computer when you return in the future. Analytics - Google analytics marketing features are active on this website. Cookies are used for marketing analysis purposes, so that Google can provide more relevant advertising through its channels. We will not identify users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through any Google advertising product or feature. You can opt-out of the Google Analytics Advertising Features we use, through Ads Settings, Ad Settings for mobile apps, or any other available means, including the "Google Analytics opt-out browser ad-on" which can be found here: Third party advertising - Third parties may advertise on our website or it may contain links to other sites not operated by us. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this Privacy Policy does not cover the information practices of these third parties. Statistics - Our website may publicly display statistics about the payments made using our service and we may change the categories of statistics displayed at any time. For example, we may display the amount of total payments made, the average transaction fee and the average payment amount. This information will not identify you to the public.

How can you check, update or change the personal information we are holding? You have a right to request access to your personal information and to ask us to correct it. If you wish to access or correct your personal information please write to us by email at Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete. We do not charge for receiving a request for access to personal information or for complying with a correction request. In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal. What happens if you want to complain? If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy, please write to us by email at We will try to respond with a decision within 30 days of you making the complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is. Updating this Privacy Policy We may update this Privacy Policy at any time by publishing it on our website. Tell us what you think We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact us by email at