Terms of Use

These Terms of Use (hereinafter "Terms") define the terms and conditions for using the Lumy service (hereinafter "the Service"), accessible at lumy.finance. Lumy is a personal wealth tracking tool that allows users to track their assets, loans, and net worth. Using the Service implies full acceptance of these Terms. If you do not accept these conditions, you must not use the Service.

The Service is published by: - Publisher: Robin Le Corre - Legal status: Auto-Entrepreneur (sole proprietor) - SIRET: 84364247100034 - EU VAT number: Not applicable (Article 293 B CGI) - Contact: support@lumy.finance - Hosting: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855 Luxembourg (data hosted in France, eu-west-3 Paris region) Consumer mediator: CM2C, 49 rue de Ponthieu, 75008 Paris

In these Terms, the following terms have the indicated meaning: - User: any individual accessing the Service and holding an Account. - Account: the User's personal space created during registration. - Data: information entered by the User (assets, loans, etc.). - Encrypted Data: Data protected by end-to-end encryption. - Recovery Key: a 24-word phrase allowing recovery of Account access.

The Service is intended exclusively for users residing in France. By using the Service, the User represents that they reside in France. Access to the Service is reserved for individuals aged at least 18 years with full legal capacity. To use the Service, the User must create an Account by providing a valid email address and password. The User is solely responsible for the confidentiality of their login credentials. Any use of the Service from their Account is deemed to have been made by them. The Service offers a 14-day free trial, followed by a paid subscription to continue accessing features.

Lumy allows the User to: - Record and track assets (bank accounts, real estate, investments, etc.) - Record and track loans - View net worth and its evolution - Export data The Service uses end-to-end encryption (E2EE) to protect the User's financial data. The Publisher has no technical access to encrypted data. AI-Powered Analysis: The Service offers an optional AI-powered analysis feature. Regarding this feature: - Data is anonymized before being sent to the AI - No data is ever sent to the AI without explicit User action - AI responses are not stored by default. The User may choose to save these responses, which will then be encrypted end-to-end like other data

The Service uses end-to-end encryption to protect the User's financial data (assets, loans, and related information). Technical specifications: - Algorithm: AES-256-GCM - Key derivation: PBKDF2 (600,000 iterations) - Salt size: 256 bits (32 bytes) - Initialization vector size: 96 bits (12 bytes) During registration, a 24-word recovery key is generated. This key is the ONLY way to recover Account access if the password is lost. IMPORTANT: The Publisher cannot under any circumstances recover data for a User who has lost both their password AND recovery key. The User is solely responsible for securely storing their recovery key.

The User agrees to: - Provide accurate information during registration - Maintain the confidentiality of their credentials and recovery key - Not use the Service for illegal purposes or contrary to these Terms - Not attempt to circumvent the Service's security measures - Comply with applicable laws and regulations, including tax laws The Service is a personal tracking tool and does not constitute financial, tax, or wealth management advice. The User remains solely responsible for their financial decisions.

The Publisher commits to using all reasonable means to ensure the availability and security of the Service (best efforts obligation). Calculations and Projections: The calculations, simulations, and projections displayed in the Service (net worth, projected growth, loan amortization, estimated returns, etc.) are provided for informational and indicative purposes only. They are based on simplified assumptions (constant return rates, fixed inflation, absence of exceptional events) and do not constitute any guarantee of future performance. The Publisher cannot be held liable for: - Any difference between displayed projections and actual performance of the User's assets - The accuracy of calculations, which depend on data entered by the User and the projection assumptions used - Investment, divestment, or any other financial decisions made based on displayed information - Data loss resulting from loss of password and recovery key - Temporary Service interruptions for maintenance or updates - Direct or indirect damages resulting from use or inability to use the Service - Accuracy of displayed market prices (cryptocurrencies, precious metals), which come from third-party sources The User acknowledges that financial markets are inherently unpredictable and that past performance is not indicative of future results. It is recommended to consult a professional financial advisor before making any investment decision. The above limitations of liability do not apply in cases of gross negligence, fraud, or breach of essential obligations by the Publisher.

Source Code: Lumy's source code is published under the Apache 2.0 license, available on GitLab. This license permits use, modification, and redistribution of the code, subject to compliance with the license terms (including attribution and preservation of copyright notices). Trademark and Visual Identity: The name "Lumy", the logo, and associated visual identity are the exclusive property of the Publisher and are protected by intellectual property laws. The Apache 2.0 license does not grant any rights to use these trademark elements. Hosted Service: Access to the Service hosted at lumy.finance is subject to these Terms and requires a subscription, regardless of the source code availability. User Data: Data entered by the User remains their exclusive property.

In accordance with the General Data Protection Regulation (GDPR), the User has the following rights regarding their personal data: - Right of access - Right of rectification - Right to erasure ("right to be forgotten") - Right to data portability - Right to object Data collected: - Email address (for authentication) - First and last name - Encrypted financial data (unreadable by the Publisher) Data is hosted on AWS servers located in France (eu-west-3 region, Paris). To exercise your rights, contact: rgpd@lumy.finance

The User may request Account deletion at any time from their profile settings. Deletion results in immediate and permanent erasure of all data associated with the Account. If the User has an active subscription, they must first cancel it before deleting their Account.

The Publisher reserves the right to modify these Terms at any time. In case of substantial modification, the User will be notified by email or via a notification in the Service at least 30 days before the new Terms take effect. Continued use of the Service after the modifications take effect constitutes acceptance of the new Terms.

The User may terminate their use of the Service at any time by deleting their Account. The Publisher may suspend or terminate a User's access in case of violation of these Terms, after formal notice sent by email to the address associated with the Account remaining without effect for 15 days, except in cases of serious violation justifying immediate suspension.

These Terms are governed by French law. In accordance with European regulations, in case of dispute, the User may use a consumer mediator free of charge. The list of mediators is available at: https://ec.europa.eu/consumers/odr Failing amicable resolution, French courts shall have jurisdiction over any dispute relating to the interpretation or execution of these Terms.

If any provision of these Terms is declared null or unenforceable, the other provisions shall remain in force. The Publisher's failure to exercise a right under these Terms does not constitute a waiver of that right. These Terms constitute the entire agreement between the User and the Publisher regarding the use of the Service.