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LEGAL

Privacy Policy

Version 1.0, effective as of 28 de maio de 2026.

1. Data controller

NURSY CONSULTING, LLC, a limited liability company (LLC) organized under the laws of the State of Wyoming, United States, with its address at 7345 W Sand Lake Rd, Ste 210, Office 8214, Orlando, FL 32819, United States acts as the controller of the personal data processed on the Lumerly platform.

2. Operation in Brazil and the LGPD

Lumerly offers its services to people located in Brazil on a permanent basis. For this reason, the Brazilian General Data Protection Law (LGPD) applies to the processing of personal data of users in Brazil.

3. Data protection officer

The data protection officer and general contact for privacy matters is [email protected]. Use this channel to exercise your rights, ask questions, or submit requests about personal data.

4. Data we collect

We collect registration data, platform usage, answers to questions, performance, preferences, IP address, browser, device, security logs, and communications sent through forms.

5. Purposes and legal bases

We use data to perform the contract, deliver the study experience, process payments, personalize practice, maintain security, send consented communications, comply with legal obligations, and improve the platform.

6. Stack processors

We may share data with providers required for payment, email, hosting, storage, AI, TTS, analytics, and security. Examples include the payment provider, Resend, Cloudflare, Anthropic, OpenAI, and infrastructure providers.

7. Permanent international transfer

Because the operator is based in the United States, there is a permanent international transfer of data. Personal data may be processed in the United States and in other countries by contracted processors, always with measures compatible with the LGPD.

8. What we do not do

We do not sell personal data, we do not share data with advertisers, and we do not use personal data to train third-party AI models.

9. Retention

We keep data for as long as necessary to provide the service, comply with legal obligations, resolve disputes, prevent fraud, and protect the platform. After that, data may be deleted or anonymized.

10. Your rights

You can request access, correction, deletion, portability, information about sharing, review of automated decisions where applicable, and withdrawal of consent by emailing [email protected].

11. Security

We use strong password hashing, encryption in transit, access control, administrative logs, and permission reviews. No system is entirely immune to risk, but we adopt reasonable measures to protect data.

12. Minors

The platform is not directed to anyone under 18 years of age.

13. Changes to this policy

This policy may be updated when there are material changes to the service, to providers, to legal requirements, or to data processing practices.

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