Privacy Notice — WORKING DRAFT v1

Last updated: July 6, 2026

This notice explains what Santosha Digital US Ltd. ("Lucrum," "we") collects when you use the Lucrum app, dashboard, and website, why, and the choices you have.

What we collect

• Account information: name, email, phone, business name and details you provide.
• Verification data: where identity or business verification is required, our verification providers collect government ID, business registration, and related information on our behalf.
• Transaction metadata: records of payments, invoices, transfers, and swaps you create in the Services — amounts, timestamps, counterparty labels you enter, and status. Note: transactions you broadcast to public blockchains are public by design; wallet addresses and on-chain activity are visible to anyone and are not controlled by Lucrum.
• Device and usage data: device type, app version, IP address, and product analytics (we use Google Analytics 4 on the website) — see the Cookie Notice.
• Support communications: messages you send us.

What we do not collect: your wallet's private keys or recovery phrases. They never leave your control, and no Lucrum employee will ever ask for them.

Why we use it

To provide and improve the Services; to enable partner services you activate (card processing, banking rails); to meet verification, anti-fraud, and legal obligations; to communicate with you about the Services; and, with your consent, to send product news.

Who we share it with

• Service partners you activate: Stripe (card processing), Bridge (banking rails), and our identity-verification provider — each processes your data under its own privacy terms.
• Service providers that host, secure, and support our infrastructure and analytics.
• Authorities, where required by law.

We do not sell your personal information.

Your rights

Depending on where you live (including under GDPR, Brazil's LGPD, and applicable US state laws), you may have rights to access, correct, delete, or port your personal information, and to object to or restrict certain processing. Contact privacy@lucrum.cash to exercise them. You may also opt out of marketing at any time via the unsubscribe link or in-app settings.

Retention and security

We keep personal information for as long as your account is active and as required for legal, accounting, and anti-fraud purposes, then delete or anonymize it. We protect data with encryption in transit, access controls, and least-privilege practices. No system is perfectly secure; protect your device and credentials.

Children

The Services are for users 18+. We do not knowingly collect data from children.

Changes and contact

We'll post updates here and note the effective date above.

Questions: privacy@lucrum.cash