Last Updated: 24 July 2026
Lumoni respects the privacy of its users and recognises responsible personal-data handling as an important part of providing secure digital financial services.
This Privacy Policy explains:
Please read this Privacy Policy before registering for or using Lumoni.
By using the Lumoni application or submitting information through the Service, you acknowledge that you have read this Privacy Policy. Where consent is legally required, Lumoni will request it separately before collecting or using the relevant information.
You may refuse or withdraw consent, but this may affect the availability of certain features that depend on the relevant information or device permission.
If you do not agree with this Privacy Policy, you should not register for or continue using Lumoni.
Lumoni is a digital financial-services application operated by:
Company Name: Lumoni Digital Technologies Ltd.
Business Address:
15a Admiralty Wy, Expressway
Lekki 106104, Lagos, Nigeria
Privacy and Customer Support Email:
lumoniCustomerService@gmail.com
Telephone:
+234 803 199 0410
Android Package Name:
app.Lumoni.service.ng
In this Privacy Policy:
This Privacy Policy applies to personal data processed through:
The Service may support account registration, identity verification, eligibility checks, virtual-card activation, transaction-related functions, payment support, security monitoring, customer support, and other features displayed within the application.
Not every feature or data category described in this Privacy Policy applies to every user.
Lumoni intends to process personal data in accordance with applicable Nigerian privacy, financial-services, anti-money-laundering, counter-terrorist-financing, consumer-protection, and cybersecurity requirements.
Relevant laws and regulatory requirements may include:
References to laws and regulations include applicable amendments, replacements, and implementing guidance.
Lumoni applies data-minimisation principles and seeks to collect only information reasonably necessary for a stated service, verification, security, compliance, transaction, or customer-support purpose.
We may collect:
We may collect or process:
Government-issued identifiers and identity-document information are used only for legitimate verification, compliance, fraud-prevention, security, assessment, and transaction-support purposes.
Lumoni does not sell, publicly disclose, or use government-issued identifiers for unrelated behavioural advertising.
Where relevant to a requested service, we may collect:
We may process:
Full payment-card credentials should be handled only through authorised payment infrastructure where applicable.
Where a service feature requires an emergency contact or reference, the user may be asked to enter limited information such as:
Lumoni does not require unrestricted access to copy or synchronise the user's complete address book for this purpose.
Manually entered contact information will not be:
Before submitting another person's information, the user should inform that person and ensure that the information may lawfully be shared.
To confirm identity and prevent impersonation or fraud, Lumoni may request:
Where a biometric template or similar biometric result is generated solely for a verification event, it will be deleted or irreversibly separated from the user's identity after the verification purpose has been completed, unless a longer retention period is required by law or is necessary for an active fraud investigation.
Where Lumoni's product implementation commits to deleting biometric verification data within 24 hours after successful verification, that period will be applied.
Lumoni does not use biometric data for:
For security, diagnostics, fraud prevention, and service reliability, Lumoni may collect limited technical information, including:
This information may be used to recognise suspicious access, detect duplicate or automated activity, investigate technical faults, and maintain the security and reliability of the Service.
Lumoni does not intend to use technical information to access unrelated personal content stored on the user's device.
Where Lumoni provides an SMS-based financial verification, transaction-security, or risk-management feature, the application will request the relevant operating-system permission before access.
Subject to the user's permission, Lumoni may process financial or transaction-related SMS information, including:
SMS information may be used only for proportionate purposes such as:
Lumoni does not use SMS information to:
Where SMS information is transmitted, it will be sent using a protected connection to infrastructure supporting the Lumoni Service.
Information that is not required for an ongoing lawful purpose will be deleted, de-identified, or placed beyond ordinary operational use after processing.
Where permitted by law, operating-system requirements, platform policy, and an applicable legal basis, Lumoni may process narrowly scoped security signals associated with applications that may create a material fraud or security risk.
Such signals may be used to detect:
Lumoni does not intend to:
Any collection must use authorised operating-system interfaces and be limited to what is reasonably necessary for the stated security purpose.
Lumoni may request camera access when the user initiates a function that requires an image, including:
Lumoni does not intentionally activate the camera silently or continuously in the background.
Where a document or image is required, Lumoni may use the Android system document picker or photo picker.
Lumoni receives only the document, photograph, or file selected and confirmed by the user.
Lumoni does not require broad or continuous access to the user's complete:
Selected files may be transmitted through protected connections and will be subject to access, security, and retention controls appropriate to their purpose.
When a user contacts Lumoni, we may collect:
Calls may be recorded only where lawful and where an appropriate notice is provided.
Lumoni may receive information from:
Information received may include:
Information will be received only where the transfer is lawful and relevant to an authorised purpose.
Lumoni may request certain device permissions only where they are required for an available feature.
Permissions may include:
Used when the user chooses to:
Used only where an SMS-based financial-verification, security, or proportionate risk-management feature is available and the user has granted permission.
Used through the Android system picker to allow the user to select a specific file or photograph.
Lumoni receives only the selected item and does not require unrestricted access to all media files.
Used to connect to the Service, protect account sessions, transmit information securely, diagnose technical faults, and maintain application functionality.
Before requesting a sensitive permission, Lumoni will provide an appropriate permission prompt or explanation where required.
Users may manage permissions through their device settings. Disabling a permission may prevent the related feature from functioning.
Lumoni may use personal data to:
Personal data will not be used for a materially incompatible purpose without an appropriate legal basis or additional notice where required.
Depending on the relevant purpose, Lumoni may process personal data on one or more of the following grounds.
Processing may be necessary to:
Processing may be necessary for:
Lumoni may request specific and voluntary consent before processing certain optional information or accessing a device capability.
Consent may be withdrawn through:
Withdrawal will not affect processing that was lawful before consent was withdrawn.
Lumoni may rely on legitimate interests where necessary to:
Before relying on legitimate interests, Lumoni will consider whether the processing is necessary and whether the user's rights, interests, or reasonable expectations should take priority.
In limited situations, information may be processed to protect a person's life or safety or to carry out a task supported by an applicable public-interest or official-authority requirement.
Lumoni may use automated tools to support identity verification, fraud detection, service eligibility, transaction security, or risk assessment.
Automated tools may analyse information provided by the user, verification results, transaction information, device-security signals, and other relevant indicators.
Lumoni does not intend to make a materially significant decision solely through automated processing where applicable law requires:
Where applicable, a user may contact Lumoni to:
Lumoni shares personal data only where the disclosure is connected to a legitimate purpose and limited to information reasonably necessary for that purpose.
Lumoni may use providers of:
Service providers may process information only for agreed services and are expected to follow confidentiality, privacy, and security requirements.
Information may be shared with:
Such information may be shared to:
Information may be shared with authorised:
Such disclosure will be limited to what is permitted and necessary for the relevant verification, security, assessment, or legal purpose.
Lumoni may disclose personal data where required by:
Information may also be disclosed where reasonably necessary to:
If all or part of Lumoni's business is reorganised, financed, merged, sold, or transferred, relevant information may be disclosed under appropriate confidentiality protections to:
Users will be notified where applicable law requires notice or consent.
Lumoni does not:
Personal data may be stored or accessed in Nigeria or in another country where an approved service provider operates.
Where personal data is transferred outside Nigeria, Lumoni will assess the transfer and apply safeguards required by applicable Nigerian data-protection law and implementation guidance.
Depending on the circumstances, safeguards may include:
Users may contact Lumoni for general information about the safeguards applied to relevant international transfers, subject to confidentiality and security limitations.
Lumoni retains personal data only for as long as reasonably necessary for the purpose for which it was collected.
Retention periods may take account of:
Indicative retention periods include:
Retained while the account is active and generally for no more than six years after account closure or the end of the customer relationship.
May be retained for up to six years after the customer relationship ends where required for compliance, audit, fraud-prevention, or dispute purposes.
Generally retained for up to six years, or longer where a binding financial, tax, regulatory, or legal requirement applies.
Where Lumoni's product implementation includes a 24-hour deletion commitment, biometric verification data will be removed within 24 hours after successful verification.
An exception may apply where continued retention is:
Ordinarily retained for no more than twelve months unless a longer period is justified by:
Manually entered contact information will be deleted or de-identified following account deletion unless limited retention is necessary for an unresolved matter or legal obligation.
Retained for the period needed to resolve the issue and for a reasonable audit, complaint, or dispute period afterward.
At the end of an applicable retention period, personal data will be:
Deletion may be subject to backup cycles, legal holds, and mandatory retention requirements.
Subject to identity verification, applicable law, and lawful limitations, a user may have the following rights.
A user may ask whether Lumoni processes their personal data and request a copy of eligible information together with available details about the processing.
A user may request correction or completion of personal data that is inaccurate, outdated, or incomplete.
A user may request deletion of personal data where there is no continuing lawful reason to retain it.
This right does not override mandatory:
A user may request temporary limits on processing while an issue relating to accuracy, lawfulness, or an objection is being assessed, where applicable law provides that right.
A user may object to:
Lumoni will stop direct marketing following a valid objection.
Other objections will be assessed against any compelling lawful reason to continue processing.
A user may request eligible personal data in a structured, commonly used, and machine-readable format.
Where technically feasible and legally required, the user may request that eligible information be transmitted to another controller.
A user may withdraw consent previously provided.
Withdrawal will affect future consent-based processing but will not make earlier lawful processing invalid.
Where applicable law provides protection against solely automated decisions with significant effects, a user may request:
A user may submit a complaint to Lumoni or to the Nigeria Data Protection Commission where the user believes personal data has been handled unlawfully.
Privacy requests may be sent to:
lumoniCustomerService@gmail.com
Lumoni may request information needed to verify the user's identity and protect the relevant account.
Lumoni will respond within the period required by applicable law and will explain any lawful reason for refusing or limiting a request.
Users may request deletion of a Lumoni account through:
The online account-deletion page allows a user to submit a deletion request without reinstalling the application.
Lumoni may verify the user's identity before processing a deletion request to prevent unauthorised or fraudulent account deletion.
After verification, the account and associated personal data will be deleted or irreversibly de-identified, except for information that Lumoni is required or permitted to retain for:
The account-deletion page will explain:
Lumoni uses administrative, organisational, and technical controls intended to reduce the risk of:
Security controls may include:
No online system can completely eliminate every security risk.
Users should:
If a security incident affects personal data, Lumoni will take reasonable steps to:
Where the applicable legal risk threshold is met, Lumoni will notify the Nigeria Data Protection Commission and affected users within the time and manner required by law.
A notification may explain:
Lumoni is intended only for persons aged 18 years or older.
Lumoni does not knowingly:
If Lumoni learns that a person under 18 has submitted personal data, Lumoni will take reasonable steps to:
Limited information may be retained where required by law, security requirements, or fraud-prevention obligations.
A parent, guardian, or person with a genuine concern may contact:
lumoniCustomerService@gmail.com
Lumoni may update this Privacy Policy to reflect:
The effective or updated date shown at the beginning of the Privacy Policy identifies the current version.
Where a change materially affects users' rights or how personal data is processed, Lumoni may provide additional notice through:
Continued use of the Service after an updated Privacy Policy becomes effective will be subject to applicable legal requirements.
This Privacy Policy may be provided in more than one language.
Where permitted by law, the English version will govern if there is an inconsistency between the English version and a translated version.
For privacy questions, personal-data requests, account-deletion enquiries, security concerns, or complaints, contact:
Lumoni Digital Technologies Ltd.
15a Admiralty Wy, Expressway
Lekki 106104, Lagos, Nigeria
Email:
lumoniCustomerService@gmail.com
Telephone:
+234 803 199 0410
Users should provide enough information for Lumoni to identify the relevant account or issue.
Users should not send the following information by email:
If a user is not satisfied with Lumoni's response, the user may lodge a complaint with the Nigeria Data Protection Commission or another competent authority with jurisdiction over the matter.