Legal.

This policy describes how Lumina Financial Technologies Oy (“Lumina”) processes personal data when you use our services or visit our websites. We are the controller for data about our customers and site visitors, and a processor for the data our customers send through the API on behalf of their own users.

What we collect

Account data — name, work email, company details, and verification documents required by anti-money-laundering law. Transaction data — the payment objects you create through the API, including amounts, currencies, and counterparty identifiers. Technical data — API request logs, IP addresses, and device information, retained for security and debugging.

What we do not do

We do not sell personal data. We do not use your transaction data to build advertising profiles. We do not move EU customer data outside the EEA when residency pinning is enabled — which it is by default for EEA-incorporated customers.

Legal bases and retention

We process data to perform our contract with you, to comply with financial regulation (KYC/AML obligations require us to retain identity and transaction records for five years after the relationship ends), and on legitimate interest for security and service improvement. Where consent is the basis — for example, the changelog newsletter — withdrawing it is one click.

Your rights

You may request access, correction, export, or deletion of your personal data at privacy@lumina.dev. Deletion is honored except where regulation requires retention. You may lodge a complaint with the Finnish Data Protection Ombudsman or your local supervisory authority.

Subprocessors

We use a short list of subprocessors (cloud hosting in eu-central, email delivery, error monitoring), published and versioned at our trust page. We notify customers 30 days before adding one.

These terms govern your use of Lumina’s services. The short version: use the API lawfully, keep your keys secret, and we’ll move your money exactly as the documentation says we will.

The service

Lumina provides payment acceptance, payout, currency conversion, and account services through its API and dashboard. We target 99.99% API availability, measured monthly and published at our status page. Scheduled maintenance is announced 72 hours ahead and never touches the charge-authorization path.

Your obligations

Provide accurate onboarding information and keep it current. Use the services only for the business activities described in your application. Safeguard API keys — charges created with your keys are yours. Comply with applicable law, including sanctions regimes, in the jurisdictions where you operate.

Funds

Customer funds are safeguarded in segregated accounts at credit institutions, separate from Lumina’s own assets, as required by the EU Electronic Money Directive. Funds in your Lumina balance are not bank deposits and do not earn interest, but they are protected in the event of Lumina’s insolvency.

Fees and changes

Fees are those published on the pricing page or in your order form. We give 60 days’ notice before any fee increase. You may terminate at any time; we pay out your full balance within five business days of completing wind-down checks.

Liability

Each party’s aggregate liability is capped at the fees paid in the preceding 12 months, except for funds-safeguarding obligations, which are not capped, and willful misconduct. We are not liable for losses caused by card network or banking-system outages beyond our control, though we will always tell you what happened.

Governing law

Finnish law, with disputes resolved in the District Court of Helsinki. Enterprise agreements may specify otherwise. Questions about either document: legal@lumina.dev.