SMARTNET – PRIVACY POLICY

1. Introduction

This Privacy Policy explains how Luturex Technologies, a company incorporated in France, collects, uses, processes, and protects personal data when you use the SmartNet platform.

SmartNet is a secure communication platform integrating messaging services with future access to financial functionalities provided exclusively through licensed third-party partners.

By using SmartNet, you agree to the processing of your personal data in accordance with this Privacy Policy and applicable European data protection laws, including the General Data Protection Regulation (GDPR).

2. Data Controller

Company: Luturex Technologies
Address: 19 Rue Thiergarten, 67000 Strasbourg, France
Legal Form: SAS
Data Controller: Luturex Technologies
Contact: [email protected]

3. Nature of the Service

SmartNet provides:

• Secure messaging services;
• Communication tools (text, voice, media sharing);
• Future integrations with regulated financial service providers.

4. Categories of Personal Data

We may collect and process the following categories of personal data:

4.1 Identification Data

• Your name, address, place of birth, date of birth, and citizenship;
• Your email address, phone number and details of the device you use (for example, your phone, computer or tablet);
• Trusted locations you have identified for security purposes;
• Your SmartNet username (randomly assigned at registration, changeable);
• Your registration information;
• Records of our discussions if you contact us (including records of phone calls);
• Your image in photo or video form, and facial scan data (biometric data), or voice data, extracted from your photo or video, to verify your identity during onboarding as part of Know-Your-Customer (KYC) checks, to authenticate you as an authorised user, or to detect and prevent fraud.

4.2 Account Data

• User profile information;
• Authentication credentials;
• Security verification information.

4.3 Communication Data

• Message metadata;
• Contact information;
• Media files voluntarily uploaded by users;
• Call session information.

4.4 Technical Data

• IP address;
• Device identifiers;
• Operating system and browser type;
• Language and timezone settings;
• Security and diagnostic logs.

4.5 Usage Data

• Interaction with platform features;
• Session duration;
• Performance diagnostics;
• Security monitoring information.

4.6 Financial Interaction Data (via licensed partners)

Where financial services are integrated through licensed partners, SmartNet may receive limited operational information such as:

• Transaction references;
• Operation status;
• Payment confirmation data.

5. Legal Basis for Processing (GDPR)

We process personal data under the following legal bases:

• Consent;
• Performance of a contract;
• Compliance with legal obligations;
• Legitimate interests related to security, fraud prevention, and service improvement.

6. Purpose of Processing

We use personal data to:

• Provide and maintain the SmartNet platform;
• Enable communication functionalities;
• Ensure platform security and fraud prevention;
• Improve user experience and technical performance;
• Integrate partner-provided financial services;
• Comply with applicable legal obligations.

7. Financial Services & Licensed Partners

SmartNet may integrate services provided by licensed third-party partners, including:

• Remittance providers;
• Banking-as-a-Service providers;
• Payment institutions;
• BNPL or credit institutions.

These partners:

• Operate under their own licenses and regulatory supervision;
• May independently perform KYC/AML verification where legally required;
• May act as independent data controllers or processors.

SmartNet acts solely as a technical interface facilitating access to such services.

8. Data Sharing

We may share personal data with:

• Infrastructure and hosting providers;
• Analytics and security service providers;
• Licensed financial partners when users initiate financial operations;
• Competent public authorities where legally required.

We do not sell personal data.

9. Data Retention

Personal data is retained:

• For as long as necessary to provide services;
• To comply with legal obligations;
• For security, fraud prevention, and dispute resolution purposes;
• Based on security needs.

Users may request deletion of their personal data at any time, subject to applicable legal limitations.

10. International Data Transfers

Personal data is processed primarily within the European Union. Where international data transfers occur, appropriate safeguards are implemented, including Standard Contractual Clauses (SCCs) where required under GDPR.

11. Security Measures

SmartNet applies security-by-design principles, including:

• Encrypted communications;
• Secure EU-based infrastructure;
• Access control systems;
• Monitoring and incident detection mechanisms;
• Technical and organizational security measures aligned with industry standards.

While no system can guarantee absolute security, SmartNet applies commercially reasonable and industry-standard protections.

12. User Rights

Under GDPR, users may have the right to:

• Access personal data;
• Request correction of inaccurate data;
• Request deletion of personal data;
• Restrict or object to processing;
• Request data portability;
• Withdraw consent where applicable.

Users may also lodge complaints with their competent Data Protection Authority. Privacy preferences may also be managed through platform settings where available.

13. Cookies & Analytics

SmartNet may use:

• Essential cookies;
• Functional cookies;
• Analytics technologies;
• Security-related tracking technologies.

Users may manage cookie preferences through browser settings where applicable.

14. Children's Data

SmartNet is not intended for children under the minimum legal age applicable in the relevant jurisdiction. We do not knowingly collect personal data from children without appropriate legal authorization.

15. Changes to this Policy

This Privacy Policy may be updated periodically. Users will be informed of significant changes where required by applicable law.

16. Contact

For any privacy-related request or inquiry:

Luturex Technologies
19 Rue Thiergarten, 67000 Strasbourg, France
Email: [email protected]