Explicit Consent Annex for Personal Data Processing

Last updated: May 17, 2026 · Version 1.0

Notice: This annex covers consent for processing data from receipts and communications sent via WhatsApp, email, the mobile app, and official LÜM channels. It supplements the Privacy Policy, Terms of Service, and Cookie Policy (website cookies only). Requires Panamanian legal review before sole reliance in regulatory proceedings.

1. Purpose and scope

This Annex governs your explicit consent when you provide personal data to LÜM by:

Website cookies are managed separately via the Cookie Policy banner.

By affirmatively consenting (e.g. replying «I ACCEPT», checking a box, or continuing after notice with link to this Annex), you authorize processing under Panama Law 81 of 2019.

2. Data controller

LÜM, Republic of Panama.

3. Data covered and purposes

With your explicit consent, LÜM processes data to:

  1. Read and process receipts, images and purchase emails (including OCR and AI);
  2. Extract amounts, merchants, dates, products and tax identifiers;
  3. Credit and manage Lümis and loyalty benefits;
  4. Provide spending analytics (Lümiscope);
  5. Personalize offers and alerts (you may object to marketing);
  6. Validate redemptions with partner merchants;
  7. Prevent fraud and comply with law;
  8. Improve the service using aggregated/anonymized data where possible.

4. Full consent text (for records)

CONSENT FOR PERSONAL DATA PROCESSING — LÜM I, the data subject, aged 18 or older, freely, informed, specifically and unambiguously: 1. Authorize LÜM to process my personal data, including receipt contents, purchase emails, WhatsApp/Telegram messages and app usage data, for LÜM loyalty program purposes described at lumapp.org/privacy-policy.html and this annex (lumapp.org/data-consent.html). 2. Understand processing may use automated systems and AI, which may contain errors; I will review derived information. 3. Declare I am entitled to share submitted documents and do not include third-party data without authorization where required. 4. Authorize operational communications and, unless I object later, LÜM commercial communications via channels I provided. 5. Have been informed of my rights (access, rectification, erasure, objection, limitation, portability where applicable, withdrawal) at legal@lumapp.org under Panama Law 81 of 2019. 6. Accept LÜM Terms of Service (lumapp.org/terms.html), including limitation of liability. Date: _______________ Channel: _______________ Account/phone: _______________

5. Short texts for digital channels

5.1. WhatsApp — welcome / first message

Hi! I'm LÜM ✨ To credit your Lümis and personalize offers, I need to process receipts and data you send (photo, QR or forwarded email) using automated systems and AI — errors may occur; please review in the app or with support. Privacy: https://lumapp.org/privacy-policy.html Consent annex: https://lumapp.org/data-consent.html Terms: https://lumapp.org/terms.html You must be 18+ and authorized to share your receipts. Reply I ACCEPT to consent under Panama Law 81, or I DO NOT ACCEPT to stop. Withdraw anytime: legal@lumapp.org

5.2. Email to facturas@lumapp.org

By sending email to facturas@lumapp.org, I confirm I am 18+, authorized to share the content, and consent to processing per: https://lumapp.org/data-consent.html https://lumapp.org/privacy-policy.html https://lumapp.org/terms.html Withdrawal: legal@lumapp.org

5.3. Mobile app — registration (suggested UI)

6. Your declarations

You declare: 18+; legitimate receipts; no fraud; Lümis have no direct cash value; third-party platform terms (WhatsApp/Meta) also apply.

7. Withdrawal and objection

Email legal@lumapp.org with subject «Withdrawal of consent — Law 81». We stop processing new receipts for consent-based purposes; retention may continue where legally required. Object to marketing anytime.

8. Minors and third-party data

Do not submit minors' data. Third-party names on receipts are processed only as needed for your purchase.

9. Limitation of liability

CONSENT DOES NOT GUARANTEE SPECIFIC LÜMIS, OFFERS OR EXTRACTION ACCURACY. TO THE MAXIMUM EXTENT PERMITTED BY PANAMANIAN LAW, LÜM IS NOT LIABLE FOR INDIRECT OR CONSEQUENTIAL DAMAGES FROM AUTHORIZED PROCESSING. AGGREGATE LIABILITY IS GOVERNED BY THE TERMS AND PRIVACY POLICY.

10. Proof of consent

LÜM may log timestamp, channel, annex version, language, account/phone ID and affirmative response as evidence. Current version: https://lumapp.org/data-consent.html.