Last Updated: December 1, 2025

This Privacy Policy explains how Luminoah Inc. (“we,” “our,” “us”) collects, uses, shares, and protects information when you use the Luminoah FLOW^TM mobile application, connected devices, and related services (together, the “Services”). “Personal Information” means information you provide to us about yourself through your use of the Services.

By creating an account or using the Services, you consent to the practices described in this Privacy Policy.

1. Personal Information We Collect

1.1 Personal Information You Provide

• Account Personal Information: name, email, password, profile details.
• Demographic Personal Information: age, date of birth, and caregiver information if applicable.
• Preferences & Settings: goals, units, formula selections, and other configuration data.
• Support Communications: messages, feedback, and interaction with customer support.

1.2 Personal Information Collected Automatically

• Device Data: device model, operating system, unique identifiers, IP address.
• Usage Data: app interactions, session duration, and feature usage.
• Connected Device Data: data transmitted from supported medical or nutritional devices, if you link them to the app.

1.3 Health-Related Personal Information

If the Services collect or display health-related data (e.g., feeding volume, compliance data, device adherence data), we treat this as sensitive information and protect it accordingly.
Depending on your implementation environment, some data may qualify as Protected Health Information (PHI) under HIPAA.

1.4 Personal Information From Minors

We do not allow accounts for minors.
We do not collect personal information for individuals under the age of 18 with verified parental or guardian representation.      

2. How We Use Personal Information

We use the information we collect to:

• Provide, maintain, and improve the Services
• Configure and personalize the user experience
• Perform de-identified population based clinical evaluations for publication and reimbursement purposes
• Display device data, progress, and analytics
• Support offline functionality and device syncing
• Communicate with users about updates, support, and security
• Enforce Terms & Conditions
• Comply with legal, regulatory, and safety obligations

We do not sell your Personal Information.

3. How We Share Personal Information

We may share information with:

3.1 Service Providers

Vendors who support hosting, analytics, customer support, authentication, and data processing. They may access information only as needed to provide contracted services.

3.2 Caregivers or Linked Accounts

If a user is a minor or links an account to a caregiver or provider portal, authorized caregivers may view relevant data.

3.3 Clinical or Institutional Partners

When the app is deployed through a healthcare provider or institution, information may be shared with that provider as permitted under HIPAA or applicable law.

3.4 Legal and Safety

We may disclose Personal Information if required by law, regulation, court order, or to protect the safety, rights, or property of users or the company.

3.5 Insurance Providers

We may disclose Personal Information necessary to support activities related to reimbursement or the continuum of care with regards to user data.

We do not share Personal Information with third parties for marketing purposes.

4. How We Protect Personal Information

We use industry-standard administrative, technical, and physical safeguards, including:

• Encryption in transit and at rest
• Access controls and role-based permissions
• Audit logging and monitoring
• Secure data storage environments

You should also help protect your Personal Information by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and Personal Information that we hold in the Services, please be aware that no method of transmitting data over the internet or storing data is completely secure, and we cannot guarantee absolute security.

5. Data Retention

We retain Personal Information:

• For as long as the account is active
• As needed to provide the Services
• As required by law or institutional agreements

Upon account deletion, Personal Information will be removed or replaced with an alias for system integrity, analytics, or safety monitoring needs, unless prohibited by law.

6. User Rights and Choices

Users may:

• Access, update, or correct Personal Information
• Change settings and preferences
• Delete their account
• Request information about stored data
• Request deletion of certain data (subject to legal/regulatory limits)

For minors, these rights must be exercised by the parent/guardian.

7. Minors and Parental Consent

• Users under the age of 18 years old are not permitted to create an account for the Luminoah mobile application.      .
• Parents/guardians can manage an account on behalf of a minor.     

8. Data Transfers

We are located in the United States.  We may store and process your Personal Information in any country where we have facilities or in which we engage service providers.  By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  When Personal Information is transferred outside of the United States, we comply with applicable law, including obtaining your consent when required. 9. Changes to This Privacy Policy

We may update this Policy periodically. When we do, we will provide notice through the Services or via email. Continued use of the Services after updates constitutes acceptance of the revised Policy.

10. Contact Us

For questions or privacy-related requests:

Luminoah Inc
1 Morton Drive, Ste 100
Charlottesville, VA 22903

info@dmw.310.myftpupload.com

11, ADDITIONAL DISCLOSURES

This section supplements the above Privacy Policy and provides additional details regarding our collection, use, and disclosure of Personal Information relating to residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, New Hampshire, Nebraska, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia.

Collection, Disclosure, Sale, Sharing, and Processing of Personal Information

The following chart details which categories of Personal Information we collect, process, and disclose, including for purposes of targeted advertising. 

Luminoah Personal Information Category Matrix

Individual Rights and Requests

Subject to applicable law, you may make the following requests:

1. You may request to know whether we process your Personal Information and to access such Personal Information.
   
   1. If you are a California resident, you may request the following information:
      
      1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
      2. The business or commercial purpose for collecting, selling, or sharing Personal Information about you;
      3. The categories of Personal Information about you that we sold or shared and the categories of third parties to whom we sold or shared such Personal Information; and
      4. The categories of Personal Information about you that we otherwise disclosed and the categories of third parties to whom we disclosed such Personal Information.
2. You may request to correct inaccuracies in your Personal Information.
3. You may request to have your Personal Information deleted.
4. You may request to receive a copy of your Personal Information, including, where applicable, in a portable format.
5. You may request to opt out of the “sale” of your Personal Information.
6. You may request to opt out of targeted advertising, including the “sharing” of your Personal Information for purposes of cross-context behavioral advertising.

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law.  To make a privacy request, please contact us at support@dmw.310.myftpupload.com., stating