Lüt Privacy Policy

Last updated: February 19, 2025

Introduction

Your privacy is very important to us. This Privacy Policy describes how Lüt and our affiliates collect, manage, use, and share your personal information. It also explains how we may use or share your personal information to provide our services, as well as for marketing and advertising purposes. We collect personal information to register for our services, and personal information is also collected when you interact or communicate with us online, by using our mobile application, conducting transaction, and interacting with us through social sites through your mobile device, tablet, computer, or other devices.

The term “Lüt”, “us”, “we”, or “our” refers to Lüt Payment Processing, LLC (Lüt) and our affiliates or subsidiaries.  Lüt is a technology company and not a bank. Lüt utilizes banking partners to provide the financial services. You may review the online privacy policy practices of our banking partners for the specifics of how your information may be collected, used, and shared by those partners.

The Lüt platform requires enrollment in a mandatory rewards program.  Your purchase information including dates, amounts, and merchant data is used to process the rewards. If you do not agree to participate in the rewards program, do not register for Lüt or utilize any of Lüt’s services. By registering for a Lüt account, using our websites, mobile apps or services, you agree to the terms and conditions of this Privacy Policy including participation in the rewards program.

Updates to this Notice

This notice is subject to change and may be updated periodically. If there are changes that are made to this Privacy Policy, we will update the “Last Updated” date listed on this notice.

Protecting Your Personal Information

Lüt protects your personal information from unauthorized use by using industry standard security measures that comply with applicable law. These measures include safeguards such as firewalls, file encryption, intrusion detection, and other information security tools.

Children

Our sites, mobile app or services are not marketed or intended for individuals under the age of 18 (we consider these minors or children). Persons under the age of 18 are not eligible to use our Services even with parental consent. If we discover that a minor has registered for an Account with us, we will close the account.

Personal Information That We Collect

We collect personal information from information that you provide directly to us, or information that is provided to us through your computer or mobile devices by the use of cookies or similar tracking technologies. Please reference our Cookie Policy for details.

We also collect information from third-party service providers that are used in conjunction with Lüt to provide our services to you. These third-party providers are contractually obligated to comply with our policies to protect information that is shared or collected on our behalf.

Information that Lüt collects depends on the products and services you use and how you interact or communicate with us. This information may include:

• Contact and Identifying Information: Full name, mailing address, email address, phone number, date of birth, gender, social media handle, occupation, employer, or other similar identifying data
• Government Issued ID or Records: Social Security number, driver’s license, passport, state ID card, military ID, or other federally issued ID cards including photos on such identity cards or records
• Biometric information: Photos, videos, or other recordings of yourself that are used for identification and risk mitigation purposes
• Voice recordings when communicating with Lüt.
• Text, IM, email, chat, or other similar types of communication including content and technical data
• Payment information including the account details of your financial institution that you link to your Lüt account.
• Name, balance and statement information of your financial institution accounts that you link to your Lüt account.
• Access information such as your user ID, password, PIN, security questions and answers
• Debit or Credit Card information including card number, expiration date, billing address, and CVV2 code
• Search engine referrals
• Technical information such as geolocation information, device fingerprint, IP address, MAC address and other device information
• Social media information
• Marketing and Communication preferences
• Transaction information including your transaction history and transaction details
• Website browsing information and how you interact and use our mobile app

How We Use and Share Personal Information

Personal information collected from you may be used for the following purposes:

• To provide our products and services to you. This includes registering for an account and verifying your identity; processing your transaction(s); managing and maintaining your account, providing promotional offers and rewards; processing payments; finding participating merchants and other specialized location-based services near you; and providing customer service and other types of account support.
• For security and fraud prevention
• To comply with applicable laws such as OFAC, KYC (know your customer), AML (anti-money laundering), and other such related regulations.
• To improve our products and services: analyzing use and data to assist in design optimization, enhancement of our notices and alerts, how you respond to our emails, and pages that you view.
• To personalize your digital interaction with the Lüt websites and mobile app
• To market current and future Lüt products and services.
• With your consent: We may disclose your personal information for any other purpose with your consent.
• Protect and defend the rights or property of the Company
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Lüt will retain your personal information for a period of time as required by law, banking regulation, or any required business purpose. Data that includes personal information will be deleted when legally permitted.

Residents of California covered by the CCPA (California Consumer Privacy Act) may have additional rights.

With Whom Do We Share Your Personal Information?

• Corporate affiliates including our parent company, affiliates, and subsidiaries. Our corporate affiliates may process personal data on our behalf to provide our services or as permitted or required by law.
• Service Providers: We share personal information with our service providers that provide or support our core business functions and internal operations. This includes our bank and other financial institution partners that provide payment, financial services, or supporting third parties used for identity verification, KYC, transaction monitoring, fraud monitoring, email, text or messaging services, and outsourced customer service providers.
• Legal Process: We may disclose personal information in response to law enforcement requests, subpoenas, court orders, warrants, government investigations, or to comply with relevant laws and regulations.
• Social Media Platforms that may use widgets or other tools that may result in information being collected or shared between us and the social media platform. The social media platform will be governed by their own privacy policy, and not that of Lüt.
• With your consent: We may disclose your personal information to a third party with your consent.

Aggregated Data

We may collect share personal information that has been aggregated or de-personalized with third parties to assist with delivering or improving our products and services. This aggregated data will not contain any information that would identify you personally, and would be used for our own business purposes where permitted by law.

Non-Affiliates

Lüt does not sell or otherwise disclose and personal information to non-affliliates.

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If you have any questions regarding our Privacy Policy, you may contact us at (877) 588-4255 or by email at compliance@mylut.com.