Privacy Policy

Luminary Club LLC is a technology studio in Phoenix, Arizona. We are an Arizona limited liability company (Arizona Corporation Commission file number 23823322) with our principal place of business at 1345 E Chandler Blvd, Suite 117, Phoenix, AZ 85048, United States. Founded 2025 in Arizona.

We build custom software and platform integrations, and we build and operate an AI customer support agent that answers inbound customer questions over SMS and web chat.

This policy applies to:

• Our website at https://luminaryclubllc.com and the pages, forms, and demonstrations hosted on it
• The Luminary Club LLC SMS Program — the text messages we send from our own registered 10DLC number, (480) 761-3456, to people who opted in with us directly
• Our email and phone conversations with visitors, prospective clients, clients, and partners, and any web chat we offer on this site in future
• The products, integrations, and services we operate for our own account

This policy does not apply to:

• Messaging programs a client business operates using technology we build or host. Those are separate programs, registered to that client with The Campaign Registry under the client's own brand, campaign, and phone number. The client is the sender of record, and the client's own privacy policy governs those messages.
• Personal information we handle strictly on behalf of a client business as its service provider. See Our Role When We Build and Operate Systems for Clients.
• Third-party websites, apps, or platforms we link to or integrate with, which have their own privacy policies.

This policy is a notice of our practices, not a contract. Browsing our website does not sign you up for anything and does not waive any right you have under privacy law. Your use of the site and our services is governed by our Terms & Conditions. Consent to receive text messages is given only through the three opt-in paths described in SMS and Mobile Information Sharing. If something here concerns you, contact us. Details are in How to Contact Us.

Much of what we do is performed on behalf of a client business. This distinction decides who is responsible for your information and who you should contact about it.

When we are the controller (or "business"). For information collected through our own website, our own marketing, our own sales conversations, and our own SMS Program, Luminary Club LLC decides why and how the information is used. This policy governs that information, and you can exercise your rights directly with us.

When we are a processor (or "service provider"). When we build, host, or operate a system for a client, for example running our AI customer support agent so a restaurant, clinic, or retailer can answer questions from its own patrons, the client business is the controller. We handle that information only:

• On the client's documented instructions, under a written agreement
• For the limited purpose of providing the service to that client: routing, answering, and logging support conversations, and maintaining the reliability and security of that client's service
• Without selling it, without sharing it for cross-context behavioral advertising, and without using it for our own independent marketing
• Without cross-client reuse. We do not use one client's data to build or improve services we offer to other businesses.

Client messaging programs belong to the client. The Luminary Club LLC Program covers only messages we send from our own registered number to people who opted in with us directly. Messaging programs we build, host, or operate for a client business are separate programs, registered to that client with The Campaign Registry under the client's own brand, campaign, and number. The client is the sender of record for those messages and its own policies govern them. Luminary Club never routes client traffic through its own brand or number. The client obtains consent, controls the content, and honors opt-outs. If you messaged a business and our AI agent replied, that business holds your information. Requests to access, correct, or delete it are best directed to the business you contacted. If you contact us instead, we will forward your request to the client and support them in responding, as our agreement with them requires.

About the AI agent itself. Our AI customer support agent generates replies to inbound inquiries. The content of your message is transmitted to an AI model provider so a reply can be generated, and the conversation is logged so the business has a record of what was asked and answered and so we can troubleshoot errors. Automated replies can be inaccurate or incomplete, and a conversation may be escalated to a person at the business. Please do not send sensitive information, such as Social Security numbers, full payment card numbers, or detailed health information, through SMS or chat.

We disclose our own bot. When you interact with our own agent, on our number, in our web chat, or in a demonstration, it identifies itself as an automated assistant at the start of the conversation, as California Business and Professions Code section 17941 and similar laws require. The automated first reply comes at any hour; a person picks up during business hours, and you can reach one at (480) 712-9936 or info@luminaryclubllc.com. Conversations are logged and may be read by authorized Luminary Club LLC personnel to troubleshoot errors, review quality, and investigate abuse.

Information you give us directly. When you fill out a form, request a demonstration, subscribe to updates, opt in to text messages, chat with us, email us, or call us, you may provide:

• Name and job title or company name
• Email address
• Phone number, including your mobile number when you opt in to SMS
• The content of your message: what you write in a form field, a text message, a chat window, or an email
• Project details you choose to share, such as your business goals, budget range, timelines, or the systems you want integrated

Information collected automatically. When you visit our website, our servers and analytics tools may record:

• Log data: IP address, date and time of your request, pages viewed, referring URL, and error information
• Device and browser data: browser type and version, operating system, screen size, language, and general device type
• Usage data: which pages you visited, how long you stayed, links clicked, and how you navigated the site
• Approximate location derived from IP address, at the city or region level. We do not collect precise GPS location from our website.
• Cookies and similar technologies. See Cookies, Analytics, and Your Choices.

Consent records. When you opt in to our SMS Program, we record the details listed under What we record when you opt in in SMS and Mobile Information Sharing, including the IP address of the submission and the exact disclosure text shown to you. Messaging rules require us to be able to prove consent on demand.

Messaging metadata. When you exchange text messages with our Program, our messaging provider records the sending and receiving phone numbers, timestamps, message content, delivery status, and opt-in and opt-out status. This is necessary to deliver messages and to honor opt-outs.

Information from clients and partners. A client may provide us with information as part of an engagement: records they want integrated into a system we are building, a contact list they are authorized to message under their own program, or credentials to their own platform accounts. Credentials are treated as sensitive, used only for the work the client hired us to do, and revoked at the end of the engagement or on request. We handle all of it under our agreement with the client, as described in Our Role When We Build and Operate Systems for Clients.

Information from third-party sources. We may receive limited business contact information from partners, referral sources, publicly available sources, or business directories, and delivery and engagement data from the email and messaging providers we use.

Information we do not seek. Through our website and our own messaging programs, we do not intentionally collect Social Security numbers, government ID numbers, full payment card numbers, biometric data, precise geolocation, or health information. Please do not send it. The narrow circumstances in which sensitive information reaches us anyway are described in California Privacy Rights.

This section describes how Luminary Club LLC handles mobile phone numbers and text messaging consent for its own messaging program — the only program this Privacy Policy covers. The Luminary Club LLC Program covers only messages we send from our own registered number to people who opted in with us directly. Messaging programs we build, host, or operate for a client business are separate programs, registered to that client with The Campaign Registry under the client's own brand, campaign, and number. The client is the sender of record for those messages and its own policies govern them. Luminary Club never routes client traffic through its own brand or number.

Our Program sends from our own registered 10DLC number, (480) 761-3456. (480) 712-9936 is our voice line. It is the number to call for support and the contact we give in HELP replies; it is not the number our text messages are sent from. The public program page is at /sms, and the opt-in form is at /sms-signup.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Text messaging originator opt-in data and consent are never sold, rented, licensed, or traded, and are never shared with any third party or affiliate for marketing or promotional purposes. They are used only to deliver the messages you asked for and to prove that you asked for them.

What we use your phone number for.

• Send the customer support replies and service notifications you opted in to receive, including replies generated by our automated AI assistant
• Keep records of consent, opt-outs, and message delivery, as messaging regulations require

Consent and opt-in are required. There are exactly three ways to join the Program:

• the opt-in form at https://luminaryclubllc.com/sms-signup;
• the SMS consent block on the contact form at https://luminaryclubllc.com/contact; or
• texting our program number first to start a conversation.

Both web forms use a consent checkbox that is unchecked by default and optional. The SMS consent box stands on its own. It is separate from accepting our Terms & Conditions, separate from acknowledging this Privacy Policy, and separate from any consent to email or phone calls, and leaving it unchecked does not stop you from submitting the form. We do not accept verbal opt-ins, written opt-ins taken offline, or opt-ins collected by any third party. Consent to receive text messages is not a condition of purchasing any goods or services. Consent you give to Luminary Club LLC applies only to Luminary Club LLC's messaging program; it is not transferable or assignable to any other brand, campaign, client, or affiliate. We do not buy, rent, sell, or use purchased, rented, or shared phone lists for messaging.

What we record when you opt in. For every opt-in submitted through one of our web forms we record the date and time of consent, the acquisition medium, the URL of the form used, which form it was, the exact disclosure text displayed at that moment, the IP address and browser user agent of the submission, the mobile number, and the name and email address of the consenting individual. Where someone opts in by texting our program number first, the record is the message thread itself, which shows the number, the time, and what was sent. We retain that record for at least four years after the consent or opt-out, and we retain opt-out records indefinitely on a suppression list so an opted-out number is not messaged again unless the person opts in again.

Confirmation. After you opt in, we send one confirmation message that identifies Luminary Club LLC, describes the Program, and states message frequency, that message and data rates may apply, and how to get help or stop. If more than 30 days pass between your opt-in and our first message to you, we re-confirm your consent by text before sending anything else, and you must reply YES to continue.

You must be 18. The Program is available only to people who are at least 18 years old and who are the account holder for, or authorized to enroll, the mobile number provided.

How to opt out — reply STOP. You can cancel at any time by replying STOP to any message from the Program. We also honor END, CANCEL, UNSUBSCRIBE, and QUIT. We honor these keywords regardless of capitalization, punctuation, or any other words in the same message. After an opt-out we send exactly one confirmation message, and nothing after it. We also honor a request to revoke consent made by any reasonable means — including a reply in your own words, a phone call to (480) 712-9936, or an email to info@luminaryclubllc.com. We act on a texted keyword immediately, and on a request made through any other channel no later than ten (10) business days after we receive it, consistent with the FCC's revocation rule. To rejoin, reply START from the same number, or submit the opt-in form at https://luminaryclubllc.com/sms-signup again. Your number stays suppressed until you opt in again.

How to get help — reply HELP. Reply HELP or INFO to any message for assistance, or contact us at info@luminaryclubllc.com or (480) 712-9936.

Message and data rates may apply. Message and data rates may apply to any message we send you and to any message you send us. Rates are set by your mobile carrier, not by us.

Message frequency. Message frequency varies. This is a conversational program rather than a broadcast schedule, so how many messages you receive depends on the conversation. We do not commit to a fixed number of messages per week or month.

Supported carriers and delivery. Our messages are delivered through licensed messaging providers and mobile carriers. Carriers are not liable for delayed or undelivered messages. Delivery is not guaranteed and may be affected by carrier filtering, network conditions, or your device settings.

Who touches your mobile number. To send and receive messages, your number is processed by our messaging infrastructure provider — currently Telnyx — and by the mobile carriers required to deliver the message. Where a reply is generated by our AI customer support agent, the content of your message is also transmitted to the AI model provider that generates the reply. We select AI model providers whose terms do not permit training general-purpose models on customer content, and we configure the available controls to that effect. Our hosting provider stores the conversation log, and authorized Luminary Club LLC personnel may read it to troubleshoot errors, review quality, and investigate abuse. These providers act on our instructions to transmit, generate, and support the messages, under terms that do not permit them to use the information for their own purposes. That is a delivery function, not marketing sharing. Again: No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

We use the information described above to:

• Provide and operate our services, including our website, web chat, demonstrations, and the AI customer support agent
• Send and receive the text messages you opted in to receive, and respond to your questions
• Respond to inquiries submitted through forms, email, chat, or phone, and follow up on sales conversations
• Deliver client projects: design, build, integrate, test, host, and support the systems a client hires us to create
• Maintain and improve our services, including debugging errors, measuring performance, and testing changes. Where we act as a service provider to a client, we use that client's data only to provide, secure, and improve the service we deliver to that client, never to build or improve services we offer to other businesses, and only as our agreement with that client permits. Any cross-client improvement uses de-identified or aggregated data only, and we do not attempt to re-identify it.
• Protect security and prevent abuse, including detecting fraud, spam, message abuse, and unauthorized access
• Keep business records, including invoicing, accounting, and records of consent and opt-out
• Comply with law, including messaging regulations, tax obligations, and lawful requests
• Send limited marketing about our own services to business contacts who have asked to hear from us or who we reasonably believe have a business interest, with an easy way to unsubscribe. Commercial email we send identifies us, includes our valid physical postal address, and contains a working unsubscribe link. We honor unsubscribe requests within ten (10) business days, at no charge, and without requiring you to give us any information beyond your email address, as CAN-SPAM requires.

We do not use your information to build advertising profiles, and we do not disclose personal information to third parties for cross-context behavioral advertising.

Luminary Club LLC is a United States company serving primarily U.S. clients, so most of our processing is governed by U.S. federal and state law. Where a legal basis framework applies to a given interaction, we rely on the following:

• Consent — for text messages, for non-essential cookies, and for marketing email where consent is required. You may withdraw consent at any time (reply STOP, use the unsubscribe link, or contact us).
• Performance of a contract — to deliver services you or your company have engaged us for, and to communicate about an active project or account.
• Legitimate interests — to run, secure, and improve our business and our website, to respond to inquiries, and to conduct limited business-to-business outreach, balanced against your rights and interests.
• Legal obligation — to keep the records regulations require, to respond to lawful requests, and to meet tax and accounting duties.
• Client instructions — where we act as a service provider or processor, we process personal information only as our client's written instructions direct.

We use the information we collect only for the purposes described in this policy or for a compatible purpose that would be reasonably expected in the context in which you provided it.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or third-party marketing. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

We disclose information only in these limited categories:

1. Service providers and subprocessors. We use a small set of vendors to run our business. They act only on our documented instructions, are bound by contract to protect the information, and may not use it for their own purposes. They include:

• Messaging providers — to transmit SMS text messages (currently Telnyx) and the mobile carriers required for delivery, and our hosting and application providers to transmit web chat messages
• Email providers — to send transactional and requested email
• Hosting and cloud infrastructure providers — to host our website, applications, and databases
• Analytics providers — to measure website traffic and performance
• AI model and inference providers — to generate replies in our AI customer support agent. We select providers whose terms do not permit training general-purpose models on customer content, and we configure the available controls to that effect.
• Business tools — customer relationship management, support ticketing, accounting, and payment processing

2. Client-operated programs. Where a client business operates its own messaging or support program using technology we build, that client is the sender of record under its own registered brand and campaign, and its own privacy policy governs. Luminary Club LLC does not share opt-in data or message content from its own SMS Program with any client or other business.

3. Legal compliance and protection. We may disclose information when we reasonably believe it is necessary to comply with a law, regulation, subpoena, court order, or lawful government request; to enforce our agreements; to investigate suspected fraud, security incidents, or abuse; or to protect the rights, property, or safety of Luminary Club LLC, our clients, our users, or the public.

4. Business transfers. If Luminary Club LLC is involved in a merger, acquisition, financing, reorganization, or sale of all or part of its assets, information may be transferred as part of that transaction. Text messaging originator opt-in data and consent are excluded from any such transaction and will not be transferred. We will require any successor to honor the commitments in this policy for information transferred, or to give you notice and a meaningful choice before applying materially different practices. We will provide notice of any material change in how information is handled.

5. With your direction. We share information with anyone else only when you ask us to or otherwise clearly consent.

Aggregated and de-identified data. We may create and use aggregated or de-identified information, for example the total number of support conversations handled in a month or how often conversations were escalated to a person, that cannot reasonably be used to identify you. We will not attempt to re-identify it.

Excluded from all of the above: text messaging originator opt-in data and consent will not be shared with any third parties. This information is not sold, rented, licensed, traded, or transferred, and it is excluded from every sharing category listed in this section, including any business transfer. The messaging vendors and mobile carriers that carry our messages act on our instructions as an extension of our own service, solely to deliver the messages you asked for; that is a delivery function, not sharing.

This site sets no cookies and runs no analytics. There is no advertising pixel, no tag manager, no visitor-tracking script, and no third-party embed that could set one. We did not remove a tracker to write this paragraph; we never added one.

The only thing we store in your browser is a single entry in local storage, named lc-theme, which remembers whether you chose the light or dark version of the site. It holds one word. It is not a cookie, it is never sent to our servers, it is not used to identify you, and clearing your browser data removes it.

Because we set nothing that requires consent, there is no cookie banner to accept or dismiss.

What we do record. Our hosting provider keeps ordinary server logs of requests to the site, described under Information We Collect. Those logs exist to keep the site running and secure, not to build a profile of you.

Do Not Track and Global Privacy Control. Browsers may send a Do Not Track (DNT) signal, which has no agreed standard, and a Global Privacy Control (GPC) signal, which acts as an opt-out of the sale or sharing of personal information. We do not currently detect either signal, because there is nothing on this site for them to switch off: we set no cookies, run no analytics, and do not sell or share personal information as those terms are defined in state privacy law. If we ever add analytics or any technology that GPC would govern, we will honor the signal and update this policy before turning it on.

We keep personal information only as long as we need it for the purposes described in this policy, and then we delete it or de-identify it. In general:

• Inquiry and form submissions — up to 24 months after the last contact, unless you become a client
• Client and project records — for the duration of the engagement and up to 7 years afterward, for contract, tax, and accounting purposes
• SMS consent and opt-out records — the full consent record described in SMS and Mobile Information Sharing, kept for at least 4 years after the consent or opt-out, because messaging regulations require us to be able to prove consent and honor opt-outs; opt-out records are kept indefinitely on a suppression list so we do not message you again unless you opt in again
• Message content and conversation logs — typically 12 to 24 months, or the shorter period our client instructs when we act as their service provider
• Website log and analytics data — typically 14 months or less
• Marketing email lists — until you unsubscribe, plus a suppression record so we do not re-add you

Sensitive information that reaches us in the narrow circumstances described in California Privacy Rights is kept no longer than is reasonably necessary for the permitted purpose it was received for. Client platform credentials are revoked and deleted at the end of the engagement or on request.

We may keep information longer where a legal hold, dispute, investigation, or regulatory requirement makes it necessary. When we act as a service provider, retention follows the client's instructions and our contract with them.

We maintain a security program appropriate to the size of our business and the sensitivity of the information we handle. What follows is a description of the controls we use, not a guarantee of a result:

• Encryption in transit (TLS/HTTPS) for our website, APIs, and messaging integrations, and encryption at rest for stored data where our infrastructure providers support it
• Access controls — least-privilege access, unique accounts, and multi-factor authentication on the systems we use to store or access personal information
• Vendor diligence — we seek written data protection terms with the providers that process personal information on our behalf
• Monitoring and logging intended to surface unauthorized access, abuse, or unusual activity
• Secure development practices, including code review and dependency management

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. SMS is not an encrypted channel. Please do not send Social Security numbers, full payment card numbers, passwords, or detailed health information by text message.

If we become aware of a security incident affecting your personal information, we will notify you and any applicable authorities as required by law. When we act as a service provider, we notify the affected client without undue delay so they can meet their own notification obligations.

Wherever you live, you can exercise the following choices with us:

• Text messages — reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any message to opt out, or HELP or INFO for assistance. You can also revoke consent by any other reasonable means, including a reply in your own words, a phone call to (480) 712-9936, or an email to info@luminaryclubllc.com.
• Marketing email — click the unsubscribe link in any marketing email, or email info@luminaryclubllc.com. We will still send transactional messages about an active project or account.
• Access, correction, and deletion — you may ask us for a copy of the personal information we hold about you, ask us to correct it if it is wrong, or ask us to delete it.
• Cookies and analytics — use the controls described in Cookies, Analytics, and Your Choices.

How to make a request. Email info@luminaryclubllc.com with the subject line "Privacy Request," or write or call us using the details in How to Contact Us. Tell us what you are asking for and give us enough information to find your records, for example the email address or phone number you used.

How we verify you. To protect your information, we will ask you to confirm details that match what we already have on file, such as the email address or phone number associated with the records. We may ask for additional confirmation for sensitive requests. We do not use verification information for any other purpose.

Timing. We confirm receipt of your request within ten (10) business days and tell you how we will process it. We respond substantively within 45 days. If we need more time, we will tell you why within that 45-day period and may take up to an additional 45 days, for a maximum of 90 days from receipt.

Authorized agents. You may use an authorized agent to submit a request. We will ask for written proof of authorization and may ask you to verify your identity directly.

No retaliation. We will not deny you goods or services, charge you a different price, or provide a different level of service because you exercised a privacy right.

Requests about a client's data. If your information is held by us on behalf of a client business, we will forward your request to that business and help them respond, as our agreement requires.

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act gives you specific rights.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. We have not sold or shared personal information in the preceding 12 months, including the personal information of consumers we know to be under 16.

Categories of personal information we collect (as defined by the statute):

• Identifiers — name, email address, phone number, IP address
• Customer records information — name, phone number, and other contact details you provide
• Commercial information — services you inquired about or purchased
• Internet or network activity — browsing and interaction data on our website
• Geolocation data — approximate city or region derived from IP address only
• Audio, electronic, or similar information — the content of your messages, chats, emails, and, where a call is recorded with notice, call recordings
• Professional or employment-related information — company name and job title, where you provide it
• Inferences — limited inferences drawn from the above, such as which of our services likely fits your business need

We collect these from you directly, automatically through our website, and from clients and partners as described in Information We Collect. We use them for the business purposes listed in How We Use Information.

Categories disclosed for a business purpose in the preceding 12 months. We disclosed identifiers; customer records information; commercial information; internet or network activity; approximate geolocation; and audio, electronic, or similar information (message and chat content) to the categories of recipients listed in How We Share Information: our messaging, email, hosting, analytics, AI model, and business-tool service providers; the client business you contacted; and, where required, legal and governmental recipients. We disclosed no category of personal information to any third party for that third party's own purposes, and we sold or shared none.

Retention. We retain each category for the periods stated in Data Retention, and we retain sensitive personal information no longer than is reasonably necessary for the permitted purpose for which it was collected.

Sensitive personal information. In the ordinary course we do not seek sensitive personal information from consumers. In limited circumstances we do receive it: account credentials a client provides so we can build or operate a system on its behalf, and the contents of messages and chats where we are not the intended recipient because we transmit them to a client business on that client's instructions. We use and disclose that information only for the purposes permitted by Civil Code section 1798.121(a) — performing the services requested, security and integrity, and short-term transitory use — and never to infer characteristics about you. Because our use is limited to those permitted purposes, the right to limit the use and disclosure of sensitive personal information does not apply, but you may still ask us about it at info@luminaryclubllc.com.

Your California rights:

• Right to know — request the categories and specific pieces of personal information we collected, the sources, the business purpose, and the categories of third parties to whom we disclosed it
• Right to delete — request that we delete personal information we collected from you, subject to legal exceptions
• Right to correct — request that we correct inaccurate personal information
• Right to opt out of sale or sharing — we do not sell or share personal information, so there is nothing to opt out of; we honor the Global Privacy Control signal regardless
• Right to limit the use of sensitive personal information — see above
• Automated decisionmaking and profiling — we do not use automated decisionmaking technology to make a significant decision about you, and we do not profile you for behavioral advertising. Our AI customer support agent generates conversational replies only; it does not make decisions that produce legal or similarly significant effects, and a person at the business you contacted is available on request.
• Right to non-discrimination — we will not treat you differently for exercising these rights

How to exercise them. Email info@luminaryclubllc.com with the subject line "California Privacy Request," or call (480) 712-9936. See Your Rights and Choices for verification, timing, and authorized agents.

Shine the Light. California Civil Code section 1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not make such disclosures.

Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island, among others as their laws take effect, generally have the right to:

• Confirm whether we process their personal data and access it
• Obtain a portable copy of data they provided to us
• Correct inaccuracies
• Request deletion
• Opt out of targeted advertising, the sale of personal data, and profiling with legal or similarly significant effects

We do not sell personal data, do not engage in targeted advertising, and do not conduct profiling that produces legal or similarly significant effects. We do not process personal data for those purposes, so those opt-outs have no effect on how we handle your information, but we honor opt-out preference signals such as the Global Privacy Control where required.

We also do not knowingly process sensitive data, such as precise geolocation, health, or biometric data, without consent, and we do not use personal data for automated decisions that produce legal effects about you.

Consumer health data (Washington, Nevada, Connecticut). We do not seek consumer health data, and we ask that you not send health information by text or chat. If you message a healthcare client through a system we operate, that client is the controller of any health-related information in the conversation and is responsible for obtaining any consent or authorization required by Washington's My Health My Data Act, Nevada SB 370, or similar law; we handle it only as that client's service provider, on its instructions, and we never sell it. Washington and Nevada residents may email info@luminaryclubllc.com with the subject line "Health Data Request" to ask what consumer health data, if any, we hold and to request its deletion.

How to exercise these rights. Email info@luminaryclubllc.com with the subject line "Privacy Request," or call (480) 712-9936. We will verify and respond within the timelines your state's law requires, generally 45 days, extendable once.

Appeals. If we decline your request, you may appeal by replying to our decision with the subject line "Privacy Appeal." We will respond in writing within 45 days, or the period your state's law requires, explaining our decision. If your appeal is denied, you may contact your state attorney general's office to submit a complaint.

Nevada residents. Nevada law lets residents opt out of the sale of certain covered information. We do not sell covered information, but you may submit a verified request to info@luminaryclubllc.com.

Our website, products, and messaging programs are intended for businesses and for adults. They are not directed to children, and we do not knowingly collect personal information from anyone under 18. We do not knowingly collect personal information from children under 13 in violation of the Children's Online Privacy Protection Act (COPPA), and we do not knowingly sell or share the personal information of consumers under 16 — and, as stated above, we do not sell or share personal information at all.

Our text messaging program is available only to people who are at least 18 years old and who are the account holder for, or are authorized to enroll, the mobile number provided. Do not opt in a mobile number belonging to a minor.

If you believe someone under 18 has provided us with personal information, contact us at info@luminaryclubllc.com or (480) 712-9936 and we will delete it promptly.

Our website and messages may link to third-party websites, tools, documentation, or platforms we integrate with. We also build integrations that connect our clients' systems to third-party platforms.

Those third parties operate independently. We do not control them, and this policy does not cover their practices. When you follow a link or use a third-party platform, that provider's privacy policy and terms apply. We encourage you to read them before providing personal information.

Including a link or an integration does not mean we endorse the third party or its privacy practices.

Luminary Club LLC is based in the United States. We and the service providers we use store and process personal information in the United States.

Our services are intended for users and businesses in the United States. We do not target our website or messaging programs to individuals in the European Economic Area, the United Kingdom, or other jurisdictions with data transfer restrictions.

If you access our services from outside the United States, understand that your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your country. By using our services or sending us information, you consent to that transfer and processing.

We may update this Privacy Policy from time to time to reflect changes in our services, our technology, or the law.

When we do, we will:

• Update the effective date and last updated date at the top of this page
• Post the revised policy at https://luminaryclubllc.com/privacy
• Provide additional notice, by email, by a notice on our website, or by text message where appropriate, if the changes are material, such as a change in how we use or disclose personal information

Material changes take effect no sooner than the date we post them, unless a shorter period is required by law. We recommend reviewing this page periodically. This policy is a notice rather than a contract, so continuing to use the site does not sign you up for anything; your agreement with us is set out in our Terms & Conditions.

This Privacy Policy is governed by the laws of the State of Arizona, without regard to its conflict-of-laws rules. Any dispute relating to this policy is subject to the informal-resolution requirement, the exclusive venue in the state or federal courts located in Maricopa County, Arizona, and the other terms of the Governing Law, Venue, and Dispute Resolution section of our Terms & Conditions, which are incorporated here by reference.

Nothing in this section limits any right you have under applicable state or federal privacy law, your ability to contact a regulator, or any right that cannot be waived by agreement.

Questions, requests, or complaints about this policy or your personal information? Reach us any of these ways. A person, not an autoresponder, handles privacy requests.

Luminary Club LLC, an Arizona limited liability company 1345 E Chandler Blvd, Suite 117 Phoenix, AZ 85048 United States

• Phone (voice line, and our support and HELP contact): (480) 712-9936
• Email: info@luminaryclubllc.com
• Website: https://luminaryclubllc.com

Our phone and email are answered by a person during business hours. Our automated assistant can reply at any hour, and the site and text messaging program are not monitored around the clock by people.

For privacy requests, use the subject line "Privacy Request" so we can route it quickly. For questions about text messaging, opt-in, or opt-out, use "SMS Request."

We confirm receipt of a privacy request within ten (10) business days and respond within 45 days. We act on a texted opt-out keyword immediately, and on a revocation request made through any other channel no later than ten (10) business days after we receive it. You can opt out of text messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or QUIT, or get help by replying HELP or INFO.