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PRIVACY POLICY

Lux Capital LLC

Version 2.0 | Effective Date: June 1, 2026
FinCEN MSB Registration No. 31000283507084

Let’s get to know the guidelines regarding how we collect information and data from our USERS and visitors and how we protect them. The purpose of this document is to help you make informed decisions about sharing information with us and using the platform.

LUX CAPITAL, LLC is a limited liability company organized under the laws of the State of Wyoming, United States of America (Registered Address: 1603 Capitol Avenue, Ste 219, Cheyenne, WY 82001), registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000283507084. This Privacy Policy applies to all services provided through the Platform at lux.capital and app.lux.capital.

By accepting this PRIVACY POLICY, the USER agrees that it may be subject to changes over time, and it is their sole responsibility to periodically check it, especially before using the SERVICES. If LUX CAPITAL, LLC makes material changes to this PRIVACY POLICY, it will provide written notice to the USER through the email address registered on the Platform at least 15 (fifteen) days prior to the changes taking effect, except where immediate implementation is required by applicable law or regulatory authority.

The concepts and expressions used in the Privacy Policy are the same as in the Terms and Conditions of Use.

The processing of personal data by LUX CAPITAL, LLC is governed internally by its Privacy and Data Protection Policy, which details the technical, organizational, and legal framework applicable to all data processing activities. This site-facing Privacy Policy reflects and is consistent with that internal framework.

ACCEPTANCE

By expressing “Acceptance” to the Terms of Use, of which this Privacy Policy is an integral part, the USER expressly declares that they have read and understood all the rights and obligations specified herein, and agrees and is subject to all the provisions of this instrument.

This Privacy Policy covers the treatment given by LUX CAPITAL, LLC to information capable of identifying USERS, as well as their data when they visit and register with the Platform. Personal data will be retained in accordance with the retention periods set out in Section IV of this Policy, which vary according to the category of data and applicable legal obligations. As a general rule, data will be retained for a minimum of 5 (five) years from the end of the business relationship, with certain categories subject to longer retention as required by law.

This Privacy Policy is designed to comply with, and shall be interpreted in accordance with:

  • Brazilian Law No. 13.709/2018 (Lei Geral de Proteção de Dados Pessoais — LGPD) and applicable resolutions of the Autoridade Nacional de Proteção de Dados (ANPD), for USERS with tax domicile in Brazil;
  • EU Regulation 2016/679 (General Data Protection Regulation — GDPR) and applicable national implementing laws, for USERS located in the European Union;
  • Applicable U.S. federal and state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA);
  • The U.S. Bank Secrecy Act (BSA) and FinCEN regulations regarding recordkeeping and reporting obligations.

Furthermore, LUX CAPITAL, LLC grants USERS the following rights with respect to their personal data:

  1. Right of access – the right to be informed and request access to the personal data that we process about the USER;
  2. Right to rectification – the right to request that LUX CAPITAL, LLC change or update the USER’s personal data whenever they are incorrect and/or incomplete;
  3. Right to deletion of information – the right to ask us to delete your personal data, subject to applicable legal retention obligations (including AML/CFT recordkeeping requirements under the BSA and Brazilian law);
  4. Right to restrictions – the right to request that we temporarily or permanently stop processing all or some of your personal data;
  5. Right to object – the right to object at any time to the processing of your personal data for reasons relating to your particular situation; and the right to object to your personal data being processed for direct marketing purposes;
  6. Right to data portability – the right to request a copy of your personal data in electronic format;
  7. Right not to be subject to automated decisions – the right not to be subject to a decision based solely on automated processing, including profiling, where the decision may have a legal effect on you or produce an equally significant effect, subject to the exceptions permitted under applicable law for AML/CFT compliance purposes.

To exercise any of the above rights, the USER may contact the Data Protection Officer (DPO) of LUX CAPITAL, LLC at compliance@lux.capital. Requests will be responded to within the timeframes required by applicable law.

INFORMATION COLLECTED

Our platform collects personal information from USERS:

  1. Registration: When registering on the PLATFORM, processing the following data that may be provided by USERS: full name, birth date, country of tax domicile, email, telephone, full address (including city, state, country), identification document numbers (e.g., CPF, passport, government-issued ID). In the case of legal entities, all data contained in the company’s articles of association, including beneficial ownership information as required by applicable AML/CFT regulations.
  2. Contact Forms: When filling out any contact form, all data entered by USERS will be processed.
  3. Email Communication: When voluntarily sending information by email, data that is also limited to this information.
  4. Platform Usage & Cookies: When accessing the LUX CAPITAL, LLC platform, through cookies and other technologies: URL data, the USER’s IP address, data from their visit, screens visited on the LUX CAPITAL, LLC page, interaction patterns (such as screen actions, clicks, touches), even as a way of confirming the USER’s own choices and actions. See our Cookie Policy for further details.
  5. User Feedback: LUX CAPITAL, LLC may request registered users of the PLATFORM to submit videos and/or comments regarding their experience as customers, at which point their personal image may be collected.
  6. AML/CFT Compliance: For AML/CFT compliance and transaction monitoring purposes: virtual asset wallet addresses, transaction hashes, blockchain transaction data, and risk scores generated by automated blockchain analytics tools (including Chainalysis KYT). This processing is mandatory and constitutes a legal obligation under applicable AML/CFT law.

PURPOSE OF DATA PROCESSED

The USER agrees and authorizes the use of the data processed for the following purposes:

  1. Identity Verification & Access: The data described in item “1” above — for mandatory customer identity verification and due diligence (KYC/CDD/EDD) pursuant to applicable AML/CFT obligations, and to enable access to the services made available on the platform. Legal basis: compliance with legal obligation (LGPD Art. 7(II); GDPR Art. 6(1)(c); BSA).
  2. Communications: The data described in items “1” and “2” above — for sending newsletters and informational communications. Legal basis: consent (LGPD Art. 7(I); GDPR Art. 6(1)(a)). The USER may withdraw consent at any time.
  3. User Requests: The data described in item “3” above — to respond to user requests. Legal basis: legitimate interest (LGPD Art. 7(IX); GDPR Art. 6(1)(f)).
  4. Security & Improvement: The data described in items “1” and “4” above — for research and analysis, to improve our technology, to record access, improve security tools, and to identify the USER and services. Legal basis: legitimate interest (LGPD Art. 7(IX); GDPR Art. 6(1)(f)).
  5. Marketing & Media: The data described in items “1” and “5” above — for analysis, research, commercial and marketing purposes, improvement, inclusion on the website, creation and distribution of advertisements, campaigns, landing pages, audiovisual productions, promotions, among others. Such use shall not entitle USERS to any payment or compensation of any kind. The voluntary submission of the requested material constitutes express authorization for the use and processing of the data in accordance with the stated purpose. Legal basis: consent (LGPD Art. 7(I); GDPR Art. 6(1)(a)).
  6. AML/CFT Compliance: The data described in item “6” above — for AML/CFT transaction monitoring, sanctions screening (OFAC, UN, EU, COAF), and compliance with reporting obligations to FinCEN and COAF. Legal basis: compliance with legal obligation (LGPD Art. 7(II); GDPR Art. 6(1)(c); BSA; Lei 9.613/1998).

I — PERSONAL DATA COLLECTED

1.1. By accessing the Platform through a computer, mobile device, tablet or any other access, the User consents to the personal data below being collected, stored, used and processed by LUX CAPITAL, LLC, under the terms of this Privacy Policy.

1.2. LUX CAPITAL, LLC may collect the IP address and information from the Access Device, namely: identifier, name and type of device, operating system, location, mobile and Wi-Fi network information and standard web log information, browser used, traffic to/from the Platform and the pages accessed within the Platform.

1.3. Additionally, information on all activities carried out on the Platform by the User will also be collected, including transaction data and blockchain-related information for AML/CFT compliance purposes.

1.4. The User authorizes LUX CAPITAL, LLC to share the data collected and processed under the terms of this Privacy Policy with the following categories of recipients:

  • Identity verification service providers: including Sumsub, which processes identity documents and biometric data (iris, fingerprints, facial image, voice) for KYC/AML onboarding verification;
  • Blockchain analytics and transaction monitoring providers: including Chainalysis, which processes virtual asset wallet addresses and transaction data for AML/KYT compliance;
  • Other service providers contracted by LUX CAPITAL, LLC: (cloud infrastructure, IT security, legal, compliance);
  • Financial institutions: that are partners of LUX CAPITAL, LLC;
  • Potential investors: of LUX CAPITAL, LLC, subject to applicable confidentiality obligations;
  • Government authorities, regulatory bodies: (including FinCEN, and law enforcement agencies), upon legal request or as required by applicable law.

All third-party data processors are required to enter into Data Processing Agreements (DPAs) with LUX CAPITAL, LLC, binding them to process data only in accordance with documented instructions and to implement appropriate technical and organizational security measures.

1.5. Except in the case of a legal or regulatory request, the data protected by this Privacy Policy shall only be shared after the execution of a data processing agreement or confidentiality agreement requiring third parties who have access to the User’s data to act with the same degree of diligence and protection as LUX CAPITAL, LLC itself.

1.6. In the event of suspension, termination of use of the Platform and its Services or termination of the Terms and Conditions of Use, whether by the User or by LUX CAPITAL, LLC, the User is aware that his/her registration will be cancelled. Personal data will be retained by LUX CAPITAL, LLC in accordance with the retention schedule in Section IV below. After the applicable retention period has elapsed, all of the User’s data shall be securely and permanently deleted or anonymized.

II — FORM OF DATA COLLECTION AND USE OF COOKIES OR SIMILAR TOOLS

2.1. The User is aware and agrees that the aforementioned data will be collected upon completion of registration on the LUX CAPITAL, LLC Platform, the User’s access to the Platform, and the use of cookies or other similar technologies to collect data about the User.

2.2. Cookies are small text files sent to the User’s computer or other Access Device in order to allow LUX CAPITAL, LLC to personalize the experience on the Platform.

2.3. Most web browsers are configured to accept cookies. The User may, at any time, block, delete or disable the use of cookies if their browser allows it, but should be aware that this choice may interfere with the use and functionality of the Platform and its Services. For further information on the types of cookies used and how to manage them, please refer to our Cookie Policy, available on the Platform.

2.4. The User may encounter cookies or other similar mechanisms on third-party platforms, applications or advertisements that are not controlled by LUX CAPITAL, LLC and are not subject to this Privacy Policy.

III — USE OF COLLECTED DATA

The data collected by LUX CAPITAL, LLC may be used to:

(i) prevent and investigate potentially prohibited or illegal activities and/or violations of the Platform’s Terms and Conditions of Use;

(ii) identify possible account violations by unauthorized third parties, such as hackers and fraudsters in general, by malicious software or activity that may financially or otherwise harm Users;

(iii) provide better Service and support to the User;

(iv) process transactions and send notifications about User Transactions;

(v) resolve disputes and troubleshoot problems;

(vi) customize, measure and improve the Platform and its Services, as well as the content and layout of the platform and application, always for the benefit of the User;

(vii) provide notices of Service updates and promotional offers;

(viii) verify the User’s identity when requesting to open an account and carry out transactions through the Platform, comparing the data collected by LUX CAPITAL, LLC in all User interactions in order to verify possible attempts at unauthorized use of the User’s account;

(ix) comply with AML/CFT legal and regulatory obligations imposed on the Platform, including customer due diligence, transaction monitoring, suspicious activity reporting to FinCEN and compliance with sanctions screening requirements (OFAC, UN, EU, COAF lists); and

(x) comply with other legal and regulatory obligations imposed on the Platform.

IV — DATA RETENTION

LUX CAPITAL, LLC retains personal data only for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal, regulatory, and contractual obligations. The following minimum retention periods apply:

Category of Data Minimum Retention Period
KYC/AML identity and due diligence records 5 years from end of business relationship (BSA; LGPD Art. 16; COAF Res. 36/2021)
Transaction and LCContract records 10 years (Brazilian Civil Code Art. 205; U.S. BSA)
Sanctions and compliance screening records 5 years from date of screening
General registration and contact data 5 years from end of business relationship
Consent records Until consent is withdrawn plus 5 years

After the applicable retention period, personal data will be securely deleted or anonymized. Retention obligations under AML/CFT law take precedence over deletion requests.

V — INTERNATIONAL DATA TRANSFERS

As LUX CAPITAL, LLC is incorporated in the United States and serves users located in Brazil and other countries, cross-border transfers of personal data will occur. The following safeguards are implemented:

  • Transfers of personal data of Brazilian data subjects to the United States: governed by LGPD Chapter V. Where an ANPD adequacy decision is not available, transfers are conducted pursuant to standard contractual clauses or another applicable legal basis under LGPD Art. 33.
  • Transfers of personal data of EU data subjects to the United States: conducted pursuant to Standard Contractual Clauses (SCCs) adopted by the European Commission under GDPR Art. 46(2)(c), or the EU-U.S. Data Privacy Framework where applicable.
  • All transfers to third-party processors (including Sumsub and Chainalysis): are governed by Data Processing Agreements that include appropriate transfer safeguards.

VI — PROTECTION AND STORAGE OF USER DATA

6.1. All data provided by the User or collected through their access to the Platform will be protected under the terms of this Privacy Policy as long as they are capable of being associated with and identified as an individual. This Privacy Policy does not apply to anonymized data, since such data does not identify the User.

6.2. The User’s account on the Platform will be protected by a personal and non-transferable password, in order to guarantee their security and privacy. The password must be chosen by the User appropriately, and it is the User’s responsibility to (i) prevent third parties from accessing their computer or other devices while using the Platform; and (ii) disconnect from the Platform when access is terminated, in addition to the prohibitions/responsibilities stipulated in the terms of use.

6.3. LUX CAPITAL, LLC will never request the User’s password to access the Platform by any means other than the Platform itself. In case of suspicion of unauthorized access by third parties to your personal account on the Platform, improper use of your access email, password, or any unrecognized activity, the User must immediately (i) request a change of your password on the Platform; and (ii) notify LUX CAPITAL, LLC, through the service channels available on the platform, so that LUX CAPITAL, LLC can take the necessary measures.

6.4. The transmission of information over the internet may not be completely secure given the possibility of unauthorized access or use, hardware or software failure, and other factors that may compromise the security of the User’s information at any time. To prevent unauthorized access to User data, LUX CAPITAL, LLC uses security solutions to monitor and prevent invasions of LUX CAPITAL, LLC’s servers, including encryption of data in transit (TLS 1.2+) and at rest (AES-256), multi-factor authentication, and role-based access controls. Furthermore, all communication through the Platform is encrypted and sensitive data is stored in databases protected by the most current protection technologies.

6.5. The User acknowledges being solely responsible for the transmission of his/her personal information on the Platform. LUX CAPITAL, LLC is not responsible for security breaches that occur due to the Access Device used by the User to access the Platform, as well as for damages or problems resulting from delays, interruptions or blocking of data transmissions due to fluctuations in the User’s internet connection.

6.6. The User’s data collected when accessing or using the Platform and/or contracting the Services will be stored on the servers of LUX CAPITAL, LLC or its contracted cloud infrastructure providers, subject to appropriate data processing agreements.

6.7. By accessing and using the Platform and sending us their personal data, the User agrees to the transfer, storage, processing and use of their data in the format set out in this Privacy Policy.

6.8. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, LUX CAPITAL, LLC will notify the relevant supervisory authority (ANPD for Brazil; competent EU data protection authority for EU residents) within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay where required, in accordance with LGPD Art. 48 and GDPR Art. 33-34.

VII — CONTACT AND DATA PROTECTION OFFICER

For any questions, requests, or complaints regarding this Privacy Policy or the processing of your personal data, please contact:

Email: privacy@lux.capital
Address: 1603 Capitol Avenue, Ste 219, Cheyenne, WY 82001, United States

Users with tax domicile in Brazil may also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd.

Users located in the European Union may lodge a complaint with their local data protection supervisory authority.

Version 2.0 — Last updated: June 1, 2026

LUX CAPITAL, LLC | 1603 Capitol Avenue, Ste 219, Cheyenne, WY 82001 | FinCEN No. 31000283507084

compliance@lux.capital  |  privacy@lux.capital  |  lux.capital