PRIVACY POLICY

Effective: Jan 1 2026

1. INTRODUCTION Lumispark Technologies ("we," "us," or "our") respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes how we collect, use, and share information when you access or use our cloud-based software platforms, applications, websites, and related services (collectively, the "Services"), including but not limited to Aries Construction Manager and Macabeo Tenant Management Suite.

2. IMPORTANT: OUR ROLE AS A DATA PROCESSOR It is critical to understand the distinction between the data we collect about you (our Customer) and the data you upload to our Services:

Account Information: We are the Data Controller for the information you provide to create your account (e.g., your name, billing address, email).
Customer Data: For the operational data, files, financial records, and third-party information you upload to the Services ("Customer Data"), we act strictly as a Data Processor. You, the Customer, are the Data Controller. You are responsible for ensuring you have the legal right to collect and input this data into our Services.

3. INFORMATION WE COLLECT

3.1 Information You Provide to Us

Account Registration: Name, email address, phone number, company name, and job title of Authorized Users.
Billing Information: Credit card details and billing addresses (processed securely by our third-party payment processors; we do not store raw credit card numbers).
Support Data: Information you provide when contacting our support team.

3.2 Information We Collect Automatically

Usage Logs: Details of your visits to our Services, including traffic data, location data, logs, and other communication data.
Device Information: Information about your computer and internet connection, including your IP address, operating system, and browser type.

3.3 Customer Data (Application-Specific Information) We process data regarding your business operations depending on the specific Service you utilize ("Customer Data"). This includes, but is not limited to:

Construction project schedules, blueprints, cost estimates, change orders, and vendor lists.
Tenant information, lease details, and property management records. You verify that you have the legal right to input this operational and financial data into the Services.

3.4 Sensitive Financial Data & Payment Processing (a) Third-Party Processing: We do not store your credit card or bank account information on our servers for subscription payments. All such billing information is tokenized and processed by our secure third-party payment gateway (e.g., Stripe, PayPal). (b) Banking Data Storage: If you use the Services to store banking details for your vendors, subcontractors, or tenants (e.g., for ACH transfers or direct deposit), you acknowledge that you are the Data Controller for this sensitive financial information. You agree not to store unencrypted bank account numbers or routing numbers in free-text fields (such as "Notes" or "Comments") within the Services where they are not protected by our specific encryption standards for financial fields.

4. HOW WE USE YOUR INFORMATION We use the information we collect to:

Provide, operate, and maintain the Services.
Process transactions and send related information, including confirmations and invoices.
Send you technical notices, updates, security alerts, and support and administrative messages.
Monitor and analyze trends, usage, and activities in connection with our Services to improve our infrastructure (e.g., determining the need for High Availability resources).
Detect, prevent, and address technical issues and security breaches.

5. DISCLOSURE OF YOUR INFORMATION We do not sell your personal information. We may disclose aggregated information about our users (which does not identify any individual) without restriction. We may disclose personal information that we collect or you provide:

To Service Providers: To contractors, service providers (such as Microsoft Azure for hosting), and other third parties we use to support our business.
Legal Requirements: If required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (including those of the State of Georgia).
Business Transfers: To a buyer or other successor in the event of a merger, divestiture, restructuring, or sale of Lumispark Technologies' assets.

6. DATA SECURITY We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls (hosted on Microsoft Azure).

Your Responsibility: The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential.

7. DATA RETENTION We retain your Account Information for as long as your account is active or as needed to provide you services. We retain Customer Data for the duration of the Subscription Term and for a period of 30 days thereafter to allow for data export, after which it may be deleted from our systems, subject to our backup retention policies.

8. CHANGES TO OUR PRIVACY POLICY It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account.

9. CONTACT INFORMATION To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Lumispark Technologies LLC

PO Box 2482, Alpharetta GA 30023

legal@lumisparktech.com

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