Lumee-O Privacy Policy

This Privacy Policy describes how Marilyn Smith Ltd ("Lumee-O", "we", "us") collects, uses, stores, shares and protects information when people use our website, application and related services (the "Service"). It applies to individuals who register for and use Lumee-O, including members of organisation accounts.

We are committed to handling personal and commercially sensitive information responsibly and in line with the Nigeria Data Protection Act 2023 and applicable guidance of the Nigeria Data Protection Commission. This policy is a draft for professional legal review and is not a statement of completed certification or registration.

The data controller responsible for your information is Marilyn Smith Ltd, company registration number RC 1708331, with registered address at 10, Inwelle Close, Lagos. For data-protection enquiries, contact us at [DATA PROTECTION CONTACT].

Where the details above have not yet been verified, the bracketed placeholders will be replaced with confirmed information before public launch.

We may collect and process the following categories of information:

• Registration information — name, email address and authentication details used to create your account.
• Individual and organisation profile information — your role, organisation name and workspace settings.
• Project information — project name, location, typology, unit mix and programme details.
• Development and financial assumptions — costs, selling prices, financing terms and stress-test parameters you enter.
• Documents and files — drawings, estimates and other files you upload to a project.
• Team-member and invitation information — names and emails of colleagues invited to your organisation workspace.
• Communications and support requests — messages, support tickets and deletion requests you submit.
• Device, browser and technical information — IP address, browser type and similar technical data.
• Usage and analytics information — limited information about how you use the Service, where collected.
• Payment information — only where payment functionality is available; we do not store full card details.
• Cookies and similar technologies — only where used, as described in the Cookies section.

Property-development inputs may contain commercially sensitive information. You should enter only information you are authorised to share and that is necessary for your assessment.

We collect information through:

• Information you enter directly when registering, building projects or submitting requests.
• Information generated through your use of the platform, such as scores, reports and stress-test results.
• Information received from organisation administrators who invite you to a workspace.
• Information received through integrations, only where you connect a third-party service.
• Technical and analytics information collected automatically as you use the Service.

We use the information we collect for the following purposes:

• Creating and managing your account and organisation workspace.
• Providing development-viability assessments.
• Generating viability scores, stress tests and reports.
• Operating organisation workspaces and team access.
• Providing technical support and responding to requests.
• Protecting the security and integrity of the platform.
• Improving product performance and features.
• Meeting legal and regulatory obligations.
• Sending service communications about your account.
• Sending marketing communications only where legally permitted and where you have given appropriate consent.

We process personal information only where we have a valid legal basis. The grounds that may apply include:

• Performance of a contract — to provide the Service you registered for.
• Consent — where you have given clear consent, for example for optional marketing.
• Legitimate interests — where necessary for our legitimate operational interests, balanced against your rights.
• Compliance with legal obligations — where processing is required by law.

This section is marked for legal confirmation. Not every ground will apply to every processing activity; the applicable basis will be confirmed during legal review.

Lumee-O uses the assumptions you provide to generate viability scores, projections, stress tests and recommendations. The results depend on the quality and accuracy of the information you enter.

The platform provides decision support. Results should not be treated as guaranteed project outcomes. You should obtain appropriate professional advice before acting on any output. Lumee-O does not make legally binding automated decisions about you.

We may share information with the following categories of recipients where applicable:

• Hosting and infrastructure providers that support the Service.
• Authentication providers that manage sign-in.
• Analytics providers, where used.
• Payment processors, only where payment functionality is available.
• Customer-support providers that help us respond to requests.
• Professional advisers such as legal and accounting advisers.
• Regulators or public authorities where required by law.
• Organisation administrators and authorised team members within your workspace.

Named providers will be listed only where their use has been verified. We do not sell your personal information. This statement should be confirmed as accurate during legal review.

Organisation administrators may invite and manage team members. Authorised members may access projects within their workspace based on assigned permissions. You should understand your organisation's internal policies on who can view and edit shared information.

Lumee-O is designed so that one organisation's information is not exposed to another organisation. Access is scoped to the relevant organisation workspace.

We take reasonable measures to protect your information. Measures that may apply include:

• Secure authentication.
• Encrypted data transmission.
• Role-based access controls.
• Access restrictions scoped to your organisation.
• Logging and monitoring of platform activity.
• Backup and recovery measures.

No system can be guaranteed to be completely secure. We do not claim certifications, audit standards or specific encryption strengths unless they have been verified and appropriately described.

Some service providers may process information in countries other than Nigeria. Where this occurs, we aim to use appropriate safeguards as required by law. The specifics of any international transfer mechanism are subject to legal review.

We retain your information only for as long as necessary for legitimate operational, contractual and legal purposes. The approved retention period is [DATA RETENTION PERIOD].

Inactive accounts, deleted projects, backups and support records are handled in line with our retention and recovery practices, subject to verification during legal review.

Subject to legal review, the following rights may apply to you:

• Access to your personal information.
• Correction of inaccurate information.
• Deletion of your personal information.
• Restriction of processing.
• Objection to processing.
• Withdrawal of consent at any time.
• Data portability where applicable.
• The right to complain to the appropriate regulator.

To exercise these rights, submit a request through the Account and Data Deletion page or contact us at marilynsmithltd@gmail.com.

Lumee-O is intended for adults and business users and is not designed for children. We do not knowingly collect information from children. A specific minimum age will be confirmed during legal review.

We use only the following categories of cookies and similar technologies:

• Essential cookies — required for the Service to function.
• Authentication/session cookies — keep you signed in securely.
• Preference cookies — remember choices such as dismissed banners.

We do not currently use non-essential analytics or marketing cookies. If this changes, we will update this notice and obtain consent where required.

You can request deletion of your account or personal data through the Account and Data Deletion Request page. Submitting a request creates a review task only; it does not immediately delete your data. We will verify your identity before taking action.

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by other appropriate means. The "Last updated" date above indicates when the policy was last revised.

For privacy questions, contact us at marilynsmithltd@gmail.com. For data-protection matters, contact [DATA PROTECTION CONTACT]. For general support, see the Contact Support page.