PRIVACY POLICY - PRIVACY, CONTROL, AND TRANSPARENCY

1. Who We Are and Data Control

Lumnix (available at www.lumnixapp.com) is a platform of interactive experiences and personalized journeys focused on inclusion and human development. For the purposes of Brazil's General Data Protection Law (LGPD - Law No. 13.709/2018), the data controller is Lumnix. Privacy questions or requests to exercise your rights can be sent via WhatsApp.

This policy transparently describes which data Lumnix processes, for what purposes, under which legal basis, and how you can exercise your rights.

2. Overview of Data Processing

Lumnix is designed so that the platform works without registration and keeps most data on your own device. In summary:

• Local data: preferences, progress, sessions, and reports are stored only in your browser (localStorage) and are not sent to Lumnix servers.
• Sensitive and children's data: in Professional mode, a guardian may register the name, age, and diagnosis (e.g., autism, cerebral palsy, Down syndrome, ADHD, dyslexia) of children and teenagers. This data is considered sensitive under the LGPD and is stored only on the device being used.
• Donations: Lumnix may receive voluntary donations via PIX to maintain the platform. Donations do not unlock features, and Lumnix does not request or store payment details.
• Navigation and advertising data: we use Google Analytics and Adsterra, which may collect data through cookies.

3. Data Stored on Your Device

Journey usage data - preferences, settings, progress, session history, and reports - is saved exclusively in your device browser (localStorage). Its sole purpose is to personalize your experience, save preferences, and let you resume your journey where you left off. You can delete this data at any time by clearing the site's browsing data.

4. Sensitive Health Data and Children's Data

In Professional mode, student profiles may contain health information, such as a diagnosis (autism, cerebral palsy, Down syndrome, ADHD, dyslexia, among others). The LGPD classifies this as sensitive personal data (Art. 5, II) and imposes specific rules for children's and teenagers' data (Art. 14).

Lumnix stores this data only on the local device and does not send it to Lumnix servers. By registering a profile for a child or teenager with health information, the legal guardian declares they have the authority to do so and grants free, informed, and unambiguous consent for the processing strictly necessary to personalize the experience.

5. Data Processed by Third Parties

For some features, Lumnix uses third-party services that act as processors:

• Google Analytics: collects usage data in an aggregated and anonymous way through cookies, to help us understand how the site is used and improve the experience. Legal basis: legitimate interest (Art. 7, IX).
• Adsterra: displays ads on the site and may use advertising cookies, in accordance with Adsterra's policies.

Lumnix does not sell, rent, or share personal data with third parties for marketing purposes. The providers above act only as processors, within the purposes described.

6. Cookies and Similar Technologies

Cookies are small files stored in your browser. Lumnix and its partners use:

• Strictly necessary cookies: essential for the platform to work, such as remembering preferences and access mode.
• Analytics cookies: used by Google Analytics to measure site usage.
• Advertising cookies: used by Adsterra to display and measure ads.

You can manage or block cookies in your browser settings. Some features may not work properly without necessary cookies.

7. Accounts and Authentication

Using Lumnix does not require registration, email, or login. Lumnix maintains an authentication infrastructure (Supabase) that may be used in the future for new features, such as accounts and synchronization. If account features are enabled, this policy will be updated before any new collection. Until then, the platform does not ask for any registration.

8. Legal Bases for Processing

Lumnix processes data based on the following LGPD bases:

• Consent (Art. 7, I and Art. 11, I): for sensitive health data and children's data registered in Professional mode.
• Legitimate interest (Art. 7, IX): to improve the platform based on aggregated usage data.
• Legal or regulatory obligation (Art. 7, II): where applicable, to comply with tax and legal obligations.

9. Retention and Security

Data stored on your device remains until you delete it or clear your browsing data. Data processed by third parties follows the retention policies of the respective providers (Google). Lumnix adopts appropriate technical and organizational measures, including encrypted connections (HTTPS), access controls, and data minimization.

10. Your Rights as a Data Subject (Art. 18)

The LGPD guarantees you the right to:

• Confirm whether your data is processed and access it;
• Correct incomplete, inaccurate, or outdated data;
• Anonymize, block, or delete unnecessary or excessive data;
• Obtain data portability;
• Delete personal data processed on the basis of consent;
• Revoke consent at any time;
• Be informed about sharing with third parties.

To exercise your rights, contact us via WhatsApp. For local device data, you can also delete it directly by clearing the site's browsing data in your browser.

11. International Data Transfers

Services such as Google Analytics and Adsterra may process data outside Brazil. Lumnix adopts, where applicable, the safeguards set out in Art. 33 of the LGPD for international transfers, including contracts with appropriate protection clauses with the providers.

12. LGPD and ANPD

Lumnix operates in compliance with Brazil's General Data Protection Law (Law No. 13.709/2018). The Brazilian National Data Protection Authority (ANPD) is the body responsible for enforcing the LGPD. You may file complaints with the ANPD, without prejudice to contacting us first.

13. Changes to This Policy

This policy may be updated to reflect changes to the platform or to the law. The date of the last update appears at the top of this page. Continued use of Lumnix after changes means you agree to the new version.

14. Contact and Data Protection Officer

For privacy questions, to exercise your rights, or any other matter related to personal data, contact us via WhatsApp. We offer human, accessible support for everyone.