PRIVACY NOTICE

Last updated February 24, 2022

This privacy notice for Luma Global Trading LLC ("Company," "we," "us," or "our"), describes how
and why we might collect, store, use, and/or share ("process") your information when you use our
services ("Services"), such as when you:

 Visit our website at https://www.lumavitamins.com, or any website of ours that links to this
privacy notice

 Engage with us in other related ways ― including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights
and choices. If you do not agree with our policies and practices, please do not use our Services. If
you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details
about any of these topics from table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with Luma Global Trading
LLC and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal

information.

Do you receive any information from third parties? We do not receive any information from third
parties.

How do you process my information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We process
your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission over
the internet or information storage technology can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be
able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy
law may mean you have certain rights regarding your personal information.
Want to learn more about what Luma Global Trading LLC does with any information we collect?
Review the Privacy Policy in full.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services, when
you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:

 names

 phone numbers

 email addresses

 mailing addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases,
such as your payment instrument number (such as a credit card number), and the security code
associated with your payment instrument. All payment data is stored by PayPal, Credit
Cards and Apple Pay. You may find their privacy notice link(s)
here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full, https://www.mastercard.us/en-us/
vision/corp-responsibility/commitment-to-privacy/privacy.html and https://support.apple.com/en-us/
HT203027#:~:text=dynamic%20security%20code.-,Neither%20Apple%20nor%20your%20device
%20sends%20your%20actual%20payment%20card,whether%20the%20transaction%20completed
%20successfully..

All personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device characteristics,
operating system, language preferences, referring URLs, device name, country, location, information
about how and when you use our Services, and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our internal analytics
and reporting purposes.

The information we collect includes:

 Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you interact with us, this log
data may include your IP address, device information, browser type, and settings and
information about your activity in the Services (such as the date/time stamps associated with
your usage, pages and files viewed, searches, and other actions you take such as which
features you use), device event information (such as system activity, error reports
(sometimes called "crash dumps"), and hardware settings).

 Device Data. We collect device data such as information about your computer, phone, tablet,
or other device you use to access the Services. Depending on the device used, this device
data may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model, Internet service
provider and/or mobile carrier, operating system, and system configuration information.

 Location Data. We collect location data such as information about your device's location,
which can be either precise or imprecise. How much information we collect depends on the
type and settings of the device you use to access the Services. For example, we may use
GPS and other technologies to collect geolocation data that tells us your current location
(based on your IP address). You can opt out of allowing us to collect this information either
by refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of the
Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:

 To facilitate account creation and authentication and otherwise manage user

accounts. We may process your information so you can create and log in to your account,
as well as keep your account in working order.

 To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.

 To respond to user inquiries/offer support to users. We may process your information to

respond to your inquiries and solve any potential issues you might have with the requested
service.

 To fulfill and manage your orders. We may process your information to fulfill and
manage your orders, payments, returns, and exchanges made through the Services.

 To save or protect an individual's vital interest. We may process your information

when necessary to save or protect an individual’s vital interest, such as to prevent
harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR

INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have
a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply
with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect
your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you otherwise you can ignore it.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal information. As such, we may rely on the
following legal bases to process your personal information:

 Consent. We may process your information if you have given us permission (i.e., consent) to
use your personal information for a specific purpose. You can withdraw your consent at any
time.

 Performance of a Contract. We may process your personal information when we

believe it is necessary to fulfill our contractual obligations to you, including providing
our Services or at your request prior to entering into a contract with you.
  Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend our legal rights, or
disclose your information as evidence in litigation in which we are involved.

 Vital Interests. We may process your information where we believe it is necessary to

protect your vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you otherwise you can ignore it.

We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw your consent at any
time.

In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:

 If collection is clearly in the interests of an individual and consent cannot be obtained

in a timely way

 For investigations and fraud detection and prevention

 For business transactions provided certain conditions are met

 If it is contained in a witness statement and the collection is necessary to assess,

process, or settle an insurance claim

 For identifying injured, ill, or deceased persons and communicating with next of kin

 If we have reasonable grounds to believe an individual has been, is, or may be victim
of financial abuse

 If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province

 If disclosure is required to comply with a subpoena, warrant, court order, or rules of

the court relating to the production of records

 If it was produced by an individual in the course of their employment, business, or profession

and the collection is consistent with the purposes for which the information was produced

 If the collection is solely for journalistic, artistic, or literary purposes

  If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the
following third parties.

We may need to share your personal information in the following situations:

 Business Transfers. We may share or transfer your information in connection with, or

during negotiations of, any merger, sale of company assets, financing, or acquisition of all or
a portion of our business to another company.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will require us keeping your
personal information for longer than thirty six (36) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and
technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat
our security and improperly collect, access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the
Services, you represent that you are at least 18 or that you are the parent or guardian of such a
minor and consent to such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will deactivate the account
and take reasonable measures to promptly delete such data from our records. If you become aware
of any data we may have collected from children under age 18, please contact us
at [email protected].

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and
Canada, you have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data
protection laws. These may include the right
(i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal
information. You can make such a request by contacting us by using the contact details.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory authority.
You can find their contact details
here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .

If you are located in Switzerland, the contact details for the data protection authorities are available
here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time by
contacting us.

However, please note that this will not affect the lawfulness of the processing before its withdrawal,
nor when applicable law allows, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in the
emails that we send, or by contacting us. You will then be removed from the marketing lists —
however, we may still communicate with you, for example to send you service-related messages that
are necessary for the administration and use of your account, to respond to service requests, or for
other non-marketing purposes.

Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:

 Log in to your account settings and update your user account.

 Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us
at [email protected].

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-
Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that we must follow
in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to
your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users
who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California resident and would
like to make such a request, please submit your request in writing to us using the contact information
provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services,
you have the right to request removal of unwanted data that you publicly post on the Services. To
request removal of such data, please contact us using the contact information provided below and
include the email address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our systems (e.g.,
backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose
and
(2) every individual who is domiciled in the State of California who is outside the State of California
for a temporary or transitory purpose

All other individuals are defined as "non-residents."

Category Examples Collected
Contact details, such as real name, alias, postal
address, telephone or mobile contact number,
A. Identifiers unique personal identifier, online identifier, Internet NO
Protocol address, email address, and account
name
B. Personal information Name, contact information, education,
categories listed in the California employment, employment history, and financial YES
Customer Records statute information
C. Protected classification
characteristics under California or Gender and date of birth NO
federal law

Transaction information, purchase history, financial

D. Commercial information NO
details, and payment information

E. Biometric information Fingerprints and voiceprints NO

Browsing history, search history, online behavior,

F. Internet or other similar interest data, and interactions with our and other
NO
network activity websites, applications, systems, and
advertisements

G. Geolocation data Device location NO

H. Audio, electronic, visual,

Images and audio, video or call recordings created
thermal, olfactory, or similar NO
in connection with our business activities
information
Business contact details in order to provide you our
I. Professional or employment- services at a business level or job title, work
NO
related information history, and professional qualifications if you apply
for a job with us
J. Education Information Student records and directory information
NO
 Inferences drawn from any of the collected
K. Inferences drawn from other personal information listed above to create a profile
NO
personal information or summary about, for example, an individual’s
preferences and characteristics

If this definition of "resident" applies to you, we must adhere to certain rights and obligations
regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories instances where you
interact with us in person, online, or by phone or mail in the context of:

 Receiving help through our customer support channels;

 Participation in customer surveys or contests; and

 Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at [email protected], by

visiting https://lumavitamins.com/contact-us/, or by referring to the contact details at the bottom of
this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit entity that processes the
information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
"selling" of your personal information.

Luma Global Trading LLC has not disclosed or sold any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. Luma Global Trading LLC will
not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information, subject to certain
exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or
her right to free speech, our compliance requirements resulting from a legal obligation, or any
processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

 whether we collect and use your personal information;

 the categories of personal information that we collect;

 the purposes for which the collected personal information is used;

 whether we sell your personal information to third parties;

 the categories of personal information that we sold or disclosed for a business purpose;

 the categories of third parties to whom the personal information was sold or disclosed for a
business purpose; and

 the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify individual data to verify a
consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification efforts require us to
ask you to provide information so that we can match it with information you have previously provided
us. For instance, depending on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the information we already have
on file, or we may contact you through a communication method (e.g., phone or email) that you have
previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to
make the request. To the extent possible, we will avoid requesting additional information from you
for the purposes of verification. However, if we cannot verify your identity from the information
already maintained by us, we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes. We will delete such additionally
provided information as soon as we finish verifying you.

Other privacy rights

  You may object to the processing of your personal information.

 You may request correction of your personal data if it is incorrect or no longer relevant, or
ask to restrict the processing of the information.

 You can designate an authorized agent to make a request under the CCPA on your behalf.
We may deny a request from an authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance with the CCPA.

 You may request to opt out from future selling of your personal information to third parties.
Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible,
but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at [email protected], by

visiting https://lumavitamins.com/contact-us/, or by referring to the contact details at the bottom of
this document. If you have a complaint about how we handle your data, we would like to hear from
you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an
updated "Revised" date and the updated version will be effective as soon as it is accessible. If we
make material changes to this privacy notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us
at [email protected] or by post to:

Luma Global Trading LLC

6032 Wilshire Dr, Tampa, FL 33615, USA
Tampa, FL 33615
United States

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the
personal information we collect from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your personal information,
please visit: https://lumavitamins.com/my-account/.