COOKIE POLICY

Lux Capital LLC

Effective Date: June 1, 2026 | Version 1.0
FinCEN MSB Registration No. 31000283507084

1. Introduction

This Cookie Policy explains how Lux Capital LLC (“Lux Capital,” “we,” “us,” or “our”), a financial technology company incorporated in the United States of America and registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN), uses cookies and similar tracking technologies on its website and digital platforms (collectively, the “Platform”).

This Policy applies to all users of the Platform, including individuals located in Brazil, the United States, and the European Union, and is intended to comply with the requirements of the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados — LGPD, Law No. 13,709/2018), the European Union General Data Protection Regulation (EU GDPR, Regulation 2016/679), and applicable U.S. privacy laws.

The Platform includes lux.capital and app.lux.capital and all associated subdomains and digital services operated by Lux Capital.

By continuing to use the Platform after being presented with this Policy, you acknowledge that you have read and understood our use of cookies as described herein.

2. What Are Cookies

Cookies are small text files placed on your device (computer, tablet, or mobile phone) when you visit a website. They allow the website to recognize your device and store certain information about your preferences or actions over time.

In addition to cookies, we may also use similar technologies such as web beacons, pixel tags, local storage objects (LSOs), and session replay scripts. For the purposes of this Policy, all such technologies are collectively referred to as “cookies.”

3. Categories of Cookies We Use

We use the following categories of cookies on the Platform:

3.1. Strictly Necessary Cookies
These cookies are essential for the Platform to function properly. They enable core functionalities such as security, session management, fraud prevention, and access to restricted areas. Without these cookies, the services you have requested cannot be provided. These cookies do not require your consent under applicable law, but we are required to inform you of their use.

3.2. Functional Cookies
These cookies allow the Platform to remember choices you make (such as your language preference, currency, or login information) and provide enhanced, personalized features. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites. Functional cookies require your prior consent where mandated by applicable law.

3.3. Analytical and Performance Cookies
These cookies collect information about how visitors use the Platform, including which pages are visited most often and whether users receive error messages. This information is used exclusively to improve the functioning of the Platform. The data collected is aggregated and anonymized where technically feasible. Use of these cookies requires your prior consent.

3.4. Marketing and Targeting Cookies
These cookies are used to deliver advertisements more relevant to you and your interests. They remember that you have visited the Platform and may share this information with third-party advertisers. Use of these cookies requires your prior consent under LGPD and EU GDPR.

4. Legal Basis for Processing

The legal bases for our processing of personal data through cookies vary by jurisdiction:

Under the LGPD (Brazil): strictly necessary cookies are processed on the basis of Article 7(II) (legal and regulatory obligations), Article 7(V) (contract performance), and Article 7(IX) (legitimate interest). All other cookies are processed on the basis of Article 7(I) (consent).

Under the EU GDPR: strictly necessary cookies are based on Article 6(1)(b) (performance of a contract) and Article 6(1)(f) (legitimate interests). All other cookies require explicit consent pursuant to Article 6(1)(a) and Recital 32.

Under U.S. law: we comply with applicable state privacy laws including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and respect opt-out rights regarding the sale or sharing of personal information.

5. Cookie Consent Management

When you first access the Platform, you will be presented with a cookie consent banner that allows you to accept or reject non-essential cookies by category. You may update your preferences at any time by accessing the Cookie Preferences Center, available via the link in the footer of the Platform.

Your consent is voluntary. Refusing non-essential cookies will not prevent you from accessing core services, although certain personalization features may be unavailable.

For users in Brazil and the European Union, withdrawal of consent is as easy as the original grant. To withdraw consent, access the Cookie Preferences Center and deselect the relevant categories. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6. Third-Party Cookies

Certain cookies on the Platform are set by third-party service providers. These third parties may include analytics providers, security monitoring services, and fraud prevention tools. We require all third-party providers to process data in compliance with applicable data protection law and to maintain appropriate data processing agreements with Lux Capital.

Third parties who set cookies on our Platform are independently responsible for compliance with their own privacy obligations. We encourage you to review their respective privacy policies for further information.

7. Data Retention

Session cookies are deleted automatically when you close your browser. Persistent cookies remain on your device for the duration specified in Section 3 above, or until you delete them manually. You may delete cookies at any time through your browser settings.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding personal data collected through cookies:

  • Right to access: obtain confirmation of whether and how your data is being processed.
  • Right to rectification: request correction of inaccurate data.
  • Right to erasure / deletion: request deletion of your personal data.
  • Right to restriction: request that processing be limited.
  • Right to data portability: receive your data in a structured, machine-readable format.
  • Right to object: object to processing based on legitimate interests.
  • Right to opt out of sale or sharing (CCPA/CPRA): if applicable under California law.

To exercise any of these rights, please contact our Data Protection Officer at the contact details provided in Section 10.

9. International Data Transfers

As Lux Capital operates across multiple jurisdictions, data collected through cookies may be transferred to and processed in the United States. Where data of EU residents is transferred outside the European Economic Area, such transfers are governed by appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46 of the EU GDPR. Transfers of data relating to Brazilian data subjects comply with Chapter V of the LGPD and applicable resolutions of the National Data Protection Authority (ANPD).

10. Contact and Complaints

If you have questions about this Cookie Policy or wish to exercise your data protection rights, please contact:

Data Protection Officer — Lux Capital LLC
Email: privacy@lux.capital
Registered Address: 1603 Capitol Avenue, Ste 219, Cheyenne, WY 82001, United States

Residents of Brazil may also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd. Residents of the European Union may lodge a complaint with their local supervisory authority.

11. Updates to This Policy

We may update this Cookie Policy from time to time to reflect changes in technology, regulation, or our business practices. Material changes will be communicated through a prominent notice on the Platform prior to the change becoming effective. We encourage you to review this Policy periodically. The date of the most recent revision is indicated at the top of this document.

Version 1.0 — 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