Privacy Policy

Lumos Fund SPC and its affiliates (“Lumos Fund SPC”, and all references, as the context
requires, to “we”, “us” or “our”) scope is to provide various financial solution in the financial markets (the “Services”). In doing so, we are committed to protecting personal data and information that we gather from our customers, potential customers,
prospects, and other end users of our online site and services, and all mobile device applications, if any (the “Website”).
Please read the following carefully to understand our views and practices regarding your personal
information and how we will collect, store, process, disclose and use such personal information in
respect of any use of the Website and the Services. This Privacy Policy applies to all of the software,
services, information, tools, features and functionality offered by us in our Website and Services.
Should we ask you to provide certain personal information when using our Services, you can be assured
that it will only be used in accordance with this Privacy Policy. 

IMPORTANT: BY USING THE SERVICES AND/OR THE WEBSITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL INFORMATION THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE WEBSITE OR THE SERVICES MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN AND TO OUR TERMS OF USE (“TERMS”), PLEASE DO NOT USE THE WEBSITE OR THE SERVICES.

1 General

1. Our users entrust us with information of a personal and confidential nature, and this
   Privacy Policy is to inform you about our practices with respect to collection, storage and
   processing of personal information that may be used, alone or in combination with other
   information, in connection with the provision of our Services and the Website.
   Accordingly, we process your personal information only for specific and limited purposes. We
   ask only for personal information that is adequate, relevant and not excessive for those
   purposes and internally to help us improve our Website and Services and to help resolve any
   problems.
   
   
2. We will not collect or use personal information for purposes other than those described in
   this Privacy Policy, our Terms, and/or in any other legal instrument in effect between us.
   You can decline to submit personal information, in which case we may not be able to provide
   you with part or all of the Services.
   
   
3. Unless stated otherwise in this Privacy Policy, we will not share, sell, auction off or give
   away your personal information to any third-party or other organization without first
   obtaining your prior written consent.
   
   
4. This Privacy Policy forms a part of the Terms, and is incorporated thereto by reference,
   along with other policies which you may be notified of by us from time to time.
   
   

2 What data we collect?

1. Information you give us. You may give us information about you, including personal
   information, when you register and/or use our Website or by corresponding with us by phone,
   e-mail or post. You may also provide such information when you subscribe to
   our Services; and when you report a problem with our Website or Services. The information
   you give us may include your name, address, e-mail address and phone number and other
   personal information. By entering the Website and providing information in any or all of
   the alternatives as specified above, you expressly consent to the terms of this Privacy
   Policy, and to the collection, use and disclosure of your information, including personal
   information, in accordance with the terms of the Privacy Policy.
   
   
2. Information we collect about you. When you visit or use our Website, we may automatically
   receive and record information from your device and browser, including your cookie
   information, your country, regional and language settings, device model, operating system,
   mobile carrier and software and hardware attributes.
   In addition, we may automatically collect and store the following information for
   statistical purposes: technical information, including the Internet protocol (IP) address
   used to connect your computer to the Internet, your login information, browser type and
   version, time zone setting, browser plug-in types and versions, operating system and
   platform; information about your visit, including the full Uniform Resource Locators (URL)
   clickstream to, through and from our Website (including date and time); page response
   times, download errors, length of visits to certain pages, page interaction information
   (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the
   Website.

   The aforesaid information does not identify you personally, it simply enables us to compile
   statistics about our visitors and their use of the Website. When you use the Website, our
   servers record information (“Log Data”), including information
   that your browser automatically sends whenever you visit a website. Log Data includes your
   Internet Protocol address, the address of and activity on websites you visit that
   incorporate service features, searches, browser type and settings, the date and time of your
   request, how you used the websites, cookie data and device data.
   Furthermore, the Website contains hyperlinks to other pages and features on the Website. We
   may use technology to track how often these links are used and which pages and features of
   the Website our visitors choose to view. This technology does not identify you personally
   it simply enables us to compile statistics about the use of these hyperlinks.

3. Information we receive from other sources. We may receive information about you if you use
   any of the other websites we operate or the other services we provide. We are also working
   closely with third parties (including, for example, business partners, sub-contractors in
   technical, payment and delivery services, advertising networks, analytics providers, search
   information providers, lead generation agencies) and may receive information about you from
   them.
   
   
4. Cookies. We use cookies on the Website. We use them for the following main purposes:
   • to associate each of the pages that you visit on our Website with each other and
     thereby allows us to present the correct information to you;
   • to keep you signed in to our Website and ensures the content you are viewing is
     secure;
   • to maintain your personal preferences.
     
     
5. Additionally, we use some cookies from Google. These helps facilitate and measure the
   effectiveness of advertisements and web searches. We may also use web beacons via the
   Services to collect information. Web beacons or “gifs”, are electronic images that may be
   used in our Services or in our emails. We may use web beacons to deliver cookies, count
   visits and to tell if an email has been opened and acted upon.
   By using our Website and/or Services, you agree to us placing these sorts of cookies on
   your device and accessing them when you visit the Website in future. If you prefer, it is
   possible to block some or all cookies, or even to delete cookies that have already been set;
   but you need to be aware that you might lose some functions of that Websites and/or
   Services.
   Please be aware of our Cookie Policy, which sets out information about the cookies on the
   Website.
   
   
6. User communications. When you send email or other communication to us, we may retain those
   communications in order to process your inquiries, respond to your requests and improve our
   Website and/or Services. We may send you push notifications to offer you special updates in
   respect of the Services. You should be able to opt-out of these notifications at the device
   level. We may also send you newsletters and promotional communications if you joined our
   mailing list, you may opt-out of this service at any time by clicking UNSUBSCRIBE at the
   bottom of each email or by submitting a request to: roey.k@fingenom-capital.com.
   Providing any means of contact with you (including by telephone) constitutes your consent
   for us to contact you by such way for the purposes outlined in this Privacy Policy.
   
   

3 Information Security

1. The security of your personal information is important to us. We follow generally accepted
   industry standards to protect the personal information submitted to us, including against
   unauthorized access to or unauthorized alteration, disclosure or destruction of personal
   information. However, no method of transmission over the Internet, or method of electronic
   storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to
   protect your personal information, we cannot guarantee its absolute security.
   
   
2. We limit access to personal information about you to employees, contractors and service
   provider who we believe reasonably need to come into contact with that personal information.
   These individuals are bound by confidentiality obligations.
   
   
3. Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration
   or destruction of data, we try to prevent such unfortunate occurrences, including by
   implementing corporate procedures in this regard.
   
   

4 Third Party Sites and Services

1. To improve our ability to provide you with the Services, we may combine your personal
   information with aggregated data about groups of people in similar circumstances.
   Furthermore, we sometimes supplement the information that you provide with information that
   is received from third parties.
   
   
2. We may use a reputable third party to present or serve advertisements that you may see on
   the Website. These third-party ad servers may use cookies, clear gifs or similar
   technologies to help present such advertisements, and to help track, measure and research
   the advertisements’ performance and effectiveness. Furthermore, we may enable trusted data
   partners to collect non-personal information, by deploying certain collection technologies
   within the Website, including, but not limited to, for purposes such as statistics
   aggregation, to improve the Website or to improve the Services. The use of these
   technologies by these third-party ad servers is subject to their own privacy policies and is
   not covered by our Privacy Policy.
   
   
3. This Privacy Policy does not apply to the practices of companies that we do not own or
   control, or to individuals whom we do not employ or manage, including any of the third
   parties to which we may disclose information as set forth in this Privacy Policy. The
   Website may also enable you to interact (whether directly or through link) with third party
   websites, social media, widgets, mobile software applications and services that are not
   owned or controlled by us (each a “Third-Party Service”). We are
   not responsible for the privacy practices or the content of these Third-Party Services.
   Please be aware that the Third-Party Services may collect personal information from you.
   Accordingly, we encourage you to read the terms and conditions and privacy policy of each
   Third-Party Service that you choose to use or interact with.
   
   
4. By providing any personal information to us pursuant to this Privacy Policy, all users,
   fully understand and unambiguously consent to this Privacy Policy and to the collection and
   processing of such personal information in Cyprus and abroad. The server on which the
   Website and the Services are hosted and/or through which the Website and the Services are
   processed may be outside the country from which you access them and may be outside your
   country of residence. Some of the uses and disclosures mentioned in this Privacy Policy may
   involve the transfer of your personal information to various countries around the world that
   may have different levels of privacy protection than your country.
   
   

5 Non-Personal Information

1. We may use or share non-personal information (such as information which does not enable
   identification of an individual user or aggregated information) in any of the above
   circumstances, as well as for the purpose of providing and improving the Website and/or the
   Services, aggregate statistics and conduct business and marketing analysis, and enhance your
   experience with the Website and/or the Services. If we combine personal information with
   non-personal information, the combined information will be treated as personal information for
   as long as it remains combined.
   
   

6 Minor

1. We care about the safety of children. Therefore, the Website and/or the Services are not
   directed towards children who have not reached the age of legal majority in their jurisdiction.
   Specifically, that is the age at which an individual is recognize by the applicable law to be an
   adult and responsible for any legal obligations created by his or her actions. We do not
   knowingly contact or engage with children without said parental consent (or consent from their
   legal guardian). By using the Website and/or the Services, you affirm that you have reached the
   age of legal majority in your jurisdiction.
   
   

7 Enforcement

1. We regularly review our compliance with this Privacy Policy. Please feel free to direct any
   questions or concerns regarding this Privacy Policy or our treatment of personal information by
   contacting in accordance with the “Contacting Us” section below. When we receive formal written
   complaints, it is our policy to contact the complaining user regarding his or her concerns.
   
   

8 Updates to this Privacy Policy

1. We may update this Privacy Policy from time to time without prior notice, by posting amended
   Privacy Policy on the Website. We encourage you to periodically review this Privacy Policy for
   the latest information about our privacy practices. Any changes to this Privacy Policy will
   become effective on the next business day following posting the revised Privacy Policy on the
   Website. Your use of the Website and/or Services following these changes means that you accept
   the revised Privacy Policy.
   
   

9 Contact us

1. If you have any questions about this Privacy Policy, please feel free to contact us at

   roey.k@fingenom-capital.com