Privacy Policy

Effective date: September 12, 2026

1. Introduction

lumingon ("we", "our", or "us") operates the lumingon mobile application (the "App") and the lumingon web portal (lumingon.com). This Privacy Policy explains how we collect, use, and protect your personal information when you use our Services.

lumingon is operated by lumingon DWC-LLC, a company licensed in the Dubai South Business Hub Freezone, United Arab Emirates (licence no. 14965, issued by the Dubai Aviation City Corporation on 6 August 2026). Our registered office is Business Centre, Floor 3, Building A3, Business Park, Dubai, United Arab Emirates. lumingon DWC-LLC is the data controller for your personal data.

Because our users and the professionals listed on lumingon are located in the Philippines, we also act as a Personal Information Controller under the Philippine Data Privacy Act of 2012 (R.A. 10173), and we are subject to Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data of the United Arab Emirates. Where the two impose different standards, we apply the stronger one.

lumingon DWC-LLC does not maintain a subsidiary, branch, or registered office in the Philippines. This does not reduce our obligations to you: we remain directly responsible as the controller of your personal data under the Data Privacy Act of 2012, and you can reach us using the contact details at the end of this policy.

You may contact our Data Protection Officer (DPO) at any time at dpo@lumingon.com.

By using lumingon, you agree to the collection and use of information as described in this policy.

2. Information We Collect

We collect the following types of information:

• Name — Used for your account profile and displayed on your property listings.
• Email address — Collected through Google Sign-In or Apple Sign-In for authentication purposes.
• Phone number (optional) — If you choose to provide it, your phone number is displayed on your property listings so that interested parties can contact you.
• Photos — Property images you upload or capture when creating listings, and your profile avatar photo.
• Listing content — The details, title, and description you write for a listing, including any text you paste in from elsewhere.
• User ID — A unique identifier generated for authentication and account management.
• Device Data — System information, device identifiers, and attestation tokens collected automatically to protect against fraud, bots, and platform abuse.
• Viewing bookings — When you book or accept a property viewing, video call, or chat, we store the booking: the listing, the requested time, the meeting type, an optional note you write to the professional, its status (requested, confirmed, declined, expired, or cancelled), and any no-show reports either party files within 7 days of a missed confirmed booking. When a booking is confirmed, each party's WhatsApp number is shared with the other so the meeting can happen — a request alone shares no contact details. Booking notifications are sent by email and push; the countdown reminders for a confirmed booking are scheduled on your own device, not from our servers.
• Notification token — If you allow notifications, we store the push token issued by Firebase Cloud Messaging together with your app's Firebase Installation ID, so we can send service notifications to your device and so the same device is not messaged more than once. Declining notifications does not affect any other feature.
• Professional credentials — For brokers and agents: your PRC licence number (brokers) or PRC salesperson accreditation number (agents), read from the PRC document you scan at verification, and — if you add it — your DHSUD registration number and its validity date, read from your DHSUD registration ID. These decide what you may list (see the Terms): the PRC credential is required to list at all; the DHSUD registration, which expires every 31 December, unlocks pre-selling / developer-project listings. The document photos themselves are deleted when the check concludes; only the extracted numbers, dates and outcome are kept.
• Consent records — When you authorise identity verification, we record which versions of these documents you accepted and when. We keep these records for as long as your account exists and for as long afterwards as we may need to evidence that consent; they are the proof that you agreed, so they are not deleted when you withdraw consent — withdrawing stops the processing going forward.
• Founding-cohort sign-up (lumingon.com/founding-broker) — If you join the founding-broker cohort on our website, we collect the email address you enter, an optional name, the wording of the consent you agreed to and when, whether your browser passed our bot check (Google reCAPTCHA Enterprise via Firebase App Check — the same check that runs on every page of lumingon.com; see the third-party services below), and basic attribution (the campaign parameters in the link you arrived by and the site that referred you — never the full page you came from). No account is created: this is a mailing-list entry, kept separately from App accounts, used only to send you the founding-cohort emails you asked for and to measure how many founding brokers go on to sign up in the App. Every cohort email carries a one-click unsubscribe; unsubscribing stops the emails immediately.
• Crash logs & Analytics — Collected automatically to help us identify and fix technical issues and track feature usage to improve app stability and user experience. Usage analytics is collected by two providers in parallel — Firebase Analytics and PostHog — which receive the same events: which screens you open, which features you use, and the approximate location (city, region and country) described elsewhere in this section. Neither receives your listing content, your identity documents, or your messages, and neither records your screen. Before you sign in these events are tied only to a randomly generated identifier for that installation; once you sign in they are linked to your account, and signing out starts a fresh anonymous identifier.
• Website usage (lumingon.com) — The pages you view and the links you click on our website are recorded by PostHog, so we can tell which guides and tools people actually find useful. The website has no sign-in, so this is never linked to an account; it is stored against a random identifier kept in your browser. If your browser sends a “Do Not Track” signal, nothing is recorded. Pages opened inside the App (the Help Center, the Buyer’s Guide, and these documents) are excluded, so reading them in the App is not also counted as a website visit.

Publicly Sourced Board-Passer Registry Data

The App includes a searchable directory of professional licensure-examination passers (for example, the Real Estate Brokers Licensure Examination). This data is not collected from you; it is compiled from examination results officially published by the Professional Regulation Commission (PRC), which are publicly available records.

• What it contains: The passer's name as published, the examination title, and the examination date — nothing more. We do not add contact details, addresses, or any other personal data to these entries.
• Purpose: To help users find licensed real estate professionals and support due diligence in property transactions.
• Your rights as a listed passer: If you appear in this directory and believe your entry is inaccurate, or you wish to object to its inclusion, contact our DPO at dpo@lumingon.com and we will review and act on your request in accordance with the Data Privacy Act of 2012 (see Section 9).

Publicly Sourced License-to-Sell Registry Data

The App includes a searchable directory of projects with a License to Sell, together with the associated developer names, compiled from lists officially published by the Department of Human Settlements and Urban Development (DHSUD). This information is not collected from you; it is drawn from publicly available records and is provided for general information and due-diligence support only. If a developer name in this directory identifies you as an individual and you wish to request a correction or its removal, contact our DPO at dpo@lumingon.com.

Face Data

Identity verification on lumingon is based on your government-issued documents. Only when you verify from the Philippines does the check additionally use your device camera to capture a short video; users verifying from anywhere else are never asked for a video, and no face data is collected from them. Where the video is used, it serves two purposes, both part of the same check and nothing else: confirming that you are a live person (liveness detection), and confirming that you are the same person shown on the government-issued ID you submit in that flow (face matching). The video is permanently deleted from our servers immediately after the verification check is complete, regardless of the result. We do not generate, store, or share any facial recognition template, biometric identifier, or face embedding, and the video is never used to recognise or identify you anywhere else. What is retained is a verified/unverified status on your account, how the verification was performed, and, for professional accounts, your name as printed on the verified ID.

• What we collect: The photo(s) of your government-issued ID captured in the verification flow and — Philippines verifications only — an 8-second face video recorded on your device.
• Purpose: Confirming your submitted documents are genuine and match your account and, where the video is used, that you are a real, live person who matches the photo on the ID you submitted. The video is not used for any other recognition or identification purpose.
• Where it is stored: Uploaded to a temporary, encrypted location on Google Firebase servers.
• How it is analyzed: The automated check is performed by Google's Gemini AI service, which processes your scanned ID image(s) — and, for Philippines verifications, the video — solely to complete the verification.
• Retention: The video (where used) is permanently and automatically deleted immediately after verification completes (whether it passes or fails). Captured ID photos are deleted when the verification flow concludes; any residual upload is automatically deleted within 24 hours.
• Sharing: Never shared with advertisers, data brokers, or any third party. Not retained by us.
• Checked on your device first: Before an ID photo is uploaded at all, the App looks at the picture on your phone to see whether it is usable — essentially whether it is too dark, too washed out by glare, or empty. This runs entirely on your device, nothing is sent anywhere, and if the photo is unusable you are simply asked to take it again.

Assisted (Manual) Verification

The automated check cannot complete on every device. If yours is one of them, you can ask us to verify you instead on a short video call with a member of the lumingon team, held over WhatsApp. On the call you show your PRC document — and your DHSUD registration, if you have one — to the camera, and the team member checks it against your face and against the licence number on your profile. Taking this route means no verification video is recorded, uploaded, or analysed by AI at all.

• What we keep: a record that the verification was granted by a named lumingon operator, the date, the channel used, a written description of what they saw on the call, and the credential numbers read from your documents. We do not record the call, and we do not keep copies of the documents you hold up to the camera.
• Why we keep it: a verification granted by a person, rather than by the automated check, has to be accountable afterwards — we must be able to show who granted it and on what basis. For the same reason this record is not deleted if the verification is later withdrawn; it is marked as withdrawn instead.
• WhatsApp: the call and any messages take place on WhatsApp, which is operated by Meta and is not run by us. Anything you send there — including any photograph of a document you choose to send rather than show on camera — is handled by Meta under its own privacy policy, and remains in your WhatsApp history and ours until one of us deletes it. We ask you to show documents on the call rather than send them, and we delete any that are sent once the check is done.
• Retention: the verification record is kept for as long as your account exists, and is deleted with it. Unlike consent records, it does not outlive the account: once you are gone your listings are gone too, and there is nothing left for it to account for.

Device Checks That Collect Nothing

Two checks read the state of your device and are acted on entirely on the device itself. Neither transmits, stores, nor shares anything, and we never learn the result:

• Screen recording. While your screen is being recorded, mirrored or cast, the App hides its content and restores it when the recording stops. This protects what is on your screen from being captured in bulk. Ordinary screenshots are unaffected — we do not block or detect them.
• VPN and proxy. At launch the App checks whether a VPN or proxy is active, because we rely on your approximate location to show relevant homes and to prevent fraud. If one is detected the App asks you to turn it off. This reads local network-interface state only; your IP address is not collected or logged by this check.

AI Assistance in the Listing Composer

When you post a listing, you can ask lumingon to help you write it. These features are optional — you can always type a listing yourself — and they work as follows:

• "Improve with AI" / "Write it for me": the title and description you have written (if any), together with the structured facts already entered for that listing (such as location, price, size, and features), are sent to Google's Gemini AI service, which returns suggested listing copy.
• "Paste your listing": if you paste an existing write-up (for example from a Facebook Marketplace post), the pasted text is sent to Gemini so its fields can be read out and pre-filled into the form. Contact details are stripped from the copy that is returned into the listing.
• Purpose and retention: the text is processed only to fulfil that single request. We do not use it to train AI models, and we do not retain the request beyond ordinary short-term operational logging.
• Your responsibility: please do not paste other people's personal information into the composer. You remain responsible for the accuracy of any listing you publish, including copy that was drafted or pre-filled with AI assistance.

Listing Engagement Measurement

So that property owners can see how their listings perform, lumingon records engagement events when you interact with a listing — both in the app and on listing pages at lumingon.com (including visits that arrive through a shared listing card or by scanning a listing's QR code).

• What is recorded: the listing involved, the kind of interaction (for example: viewed, saved, shared, contacted the owner, or visited the owner's profile), the date and time, your device platform, how you arrived at the listing (for example: the app, the website, a shared card, or a QR scan), and — in the app — your approximate location (city, region, and country, estimated from your network connection). Website visits do not record your location.
• What the listing's owner sees: aggregate statistics (counts, rates, and city-level summaries). For contact events, the owner also sees the time of the contact and the approximate city it came from — which corresponds to the conversation you are choosing to start with them. Owners are never shown your name, account, or any direct identifier through these statistics.
• Your identity: if you are signed in, your interactions are linked to your account internally (for example, so repeat views are not over-counted), but they are only ever presented to owners in pseudonymous or aggregate form. An owner's own interactions with their own listing are excluded.
• Purpose: providing listing owners with performance insights, improving search and feed relevance, and protecting the platform against abuse. This data is not sold or shared with advertisers.

Agent Invitations

If you are a verified broker, you can invite people to work as your agents by entering their email addresses (up to five at a time). This is the one place in lumingon where the personal data we process is somebody else's, so it is worth being exact about both sides of it.

• If you send an invitation: we store the address you entered, the fact that you invited it, when, and how many times, and we show that list back to you on your Approved Agents page so you can see what is outstanding. Nobody else can see it. It is deleted when you delete your account.
• If you receive one: we hold your address to send that one email and to record that it was sent. We do not create an account for you, we do not add you to any list, we share nothing about you with the broker who invited you, and you are not on their roster — an invitation is an email, and joining a broker is something you would do yourself in the App. Every invitation carries a one-click unsubscribe; using it stops any further email to that address, including future invitations from any broker. You can also write to dpo@lumingon.com and we will delete the record.
• Limits: five addresses per send and twenty invitations per broker per day, enforced on our servers. Addresses that have unsubscribed or previously bounced are never emailed, whoever enters them.

3. Camera and Media Access

The App requests camera and photo-library access for two separate purposes:

• Identity verification: the camera captures your ID documents (your PRC document and, optionally, your DHSUD registration ID) and — Philippines verifications only — the short verification video. Nothing from this session is stored beyond the verification check itself (see Face Data above).
• Property listings and your profile: you can capture a photo with the camera or choose one from your photo library to attach to a listing or to use as your profile avatar. These images are stored, and listing images are published publicly with the listing (see Section 4).

4. Information Sharing and Public Visibility

We do not sell, trade, or share your personal information with third parties for advertising or marketing purposes.

When you create a property listing, your contact details (phone number and/or WhatsApp number) are visible to other users so that buyers can reach you about your property.

Your listings and public profile are published on the open web. lumingon is not an app-only marketplace. Content you publish is also served as a public page on lumingon.com:

• Listings — every active, visible listing has a public page at lumingon.com/property/… showing its photos, details, and the name, avatar, role, and verification status of the broker or agent who posted it.
• Broker and agent profiles — verified brokers and agents have a public page at lumingon.com/broker/… showing their name, avatar, company, areas served, and active listings, and — while your DHSUD registration is current — a "DHSUD-registered" badge (the registration number itself is never shown). Your PRC licence number appears only if you switch on "Show license number publicly" — it is off by default.
• Search engines and AI answer engines — these pages are intended to be found. They are listed in our sitemap and may be indexed by search engines and read by AI assistants and answer engines, which may reproduce or summarise them.
• Shareable cards and links — listings can be shared as an image card or QR code that links back to the public listing page.

How to limit this. Switching off "List me in the directory" removes you from the in-app directory, from broker search, and from our sitemap, so your profile is no longer surfaced or submitted for indexing. Your profile page and your listings remain reachable to anyone who has a direct link, so that buyers who open your listing can still contact you. Deleting a listing removes its public page; deleting your account removes both (see Section 6).

Public-record directories. The board-passer, License to Sell, and developer directories described above are also published as public pages on lumingon.com (for example lumingon.com/board-passers/…), one per record, and are similarly indexable. These pages reproduce only what the PRC or DHSUD has officially published, and each carries its source and a correction contact. If you are named on one of these pages and wish to request a correction or removal, contact our DPO at dpo@lumingon.com.

We may share information if required by law or to protect the rights and safety of our users.

5. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Display your property listings to other users
• Allow potential buyers to contact you about your listings
• Perform identity verification checks — document authenticity everywhere, plus liveness for Philippines verifications — to ensure listing safety and authenticity
• Moderate property listings using automated moderation tools (e.g., analyzing description texts and images for placeholders, compliance, and safety policy violations)
• Protect our platform against security threats, spam, and abuse
• Send you transactional (service) emails — for example a welcome/verification confirmation, verification-renewal reminders, listing status updates, inquiry notifications, and broker–agent link updates. These are operational messages about your account and activity; we do not send marketing email without your consent. Two exceptions: the founding-broker cohort list on our website, which you opt into — if you join it, we send occasional cohort emails (early access, launch and product notes) to that address until you unsubscribe or convert to an App account — and, if you are a verified broker or agent, an occasional getting-started email from us (for example a reminder to post your first listing while your account has none). Every such email carries a one-click unsubscribe, which stops all marketing email to that address; service emails continue. Separately, if a verified broker invites you to join their team, we send that one invitation to the address they entered — see "Agent Invitations" in Section 2.
• Send you push notifications about the same kinds of events (for example when a listing is approved or rejected, when a buyer enquires, when a broker–agent link changes, or when your verification is about to expire), if you allowed notifications. If you are a verified broker or agent, we may also send an occasional getting-started notification (for example a reminder to post your first listing while your account has none); these are infrequent, are never sent to buyers, and use the same permission. You can turn notifications off at any time in your device settings; doing so stops every notification, service and getting-started alike, and does not affect anything else in the App.
• Generate or improve listing copy on request, and read a listing write-up you paste in so its fields can be pre-filled (see AI Assistance in the Listing Composer, above)
• Conduct A/B testing and analyze feature usage to improve the user experience
• Provide customer support

Where identity verification uses a face video (Philippines verifications only — see Face Data in Section 2), it is processed solely to confirm that you are a real, live person and that you match the government-issued ID you submitted, and it is permanently deleted immediately after the check completes. We do not create, store, or share any facial-recognition template or biometric identifier.

6. Data Retention

We retain your personal data only for as long as your account remains active and for as long as needed to provide the Services. Verification media is deleted immediately upon completion of the check. Consent records are the exception: because they exist to evidence that you agreed to something, they outlive the consent itself and are retained after account deletion for as long as we may need to rely on them. You may delete your account and all associated data at any time from within the App. Founding-cohort mailing-list entries are kept until you unsubscribe (the address is then retained only in a suppressed state so we do not email it again) or, if you later create an App account with the same address, until that account is deleted; you can also ask us to remove the entry outright at dpo@lumingon.com.

You can delete your account and all associated data at any time from within the App. When you delete your account, the following data is permanently removed:

• Your profile information (name, email, phone number, avatar)
• All property listings you have created
• All property images you have uploaded
• Your saved properties list, and the boards you group them into
• Your viewing bookings, office hours, and any no-show reports on them
• Your notification tokens, so the deleted account can no longer be messaged
• Any agent invitations you sent, including the addresses you entered

If you are an agent linked to a supervising broker, that link is cleared and your broker is notified before the account is removed, so their team list stays accurate.

All personal identifiers and verification status flags tying you to the account are permanently erased or fully anonymized to ensure your privacy. This action is irreversible.

Some data has its own lifecycle:

• Unfinished listing drafts are stored on your own device, not on our servers. They are removed when you publish or discard the draft, and when you delete the App.
• Notification tokens are removed when a device stops being used (we prune tokens that have gone unused for 30 days, and any token the notification service reports as invalid).
• Moderation and rate-limit records — a minimal record of listing-review outcomes and request counts is kept so the daily caps and the temporary posting pause described in our Terms can be enforced.

7. Third-Party Services

lumingon uses the following third-party services to support security, authentication, and analysis:

• Firebase Authentication — for secure user authentication (Google and Apple Sign-In)
• Firebase Data Connect — for storing application data
• Firebase Storage — for storing images
• Firebase App Check — for verifying that a request comes from a genuine copy of the App or a real browser on lumingon.com, so our services can turn away bots and tampered clients. In the App this relies on Apple's and Google's device attestation (DeviceCheck / App Attest on iOS, Play Integrity on Android). On lumingon.com it relies on Google reCAPTCHA Enterprise, which runs on every page of the website — not only the founding-broker form — and sends browser and interaction signals to Google so Google can judge whether the visitor is automated. We receive only the resulting token and whether it passed, never the signals themselves, and the check is not used to identify you.
• Firebase Analytics — for collecting anonymous app usage stats
• Firebase Remote Config — for dynamically updating app content and behavior
• Firebase Cloud Messaging and Firebase Installations — for delivering push notifications to your device and identifying that installation so it is not messaged twice
• Google Gemini (AI) — for automated analysis during identity verification (reading your scanned PRC and DHSUD documents and checking the liveness video, including that you match your ID), automated listing moderation, and the optional listing-copy assistance described in Section 2. Verification media is processed solely for the check and is not used to identify you across other services.
• PostHog — for product analytics: seeing which screens, guides and tools are used, in the App and on lumingon.com, so we know what to improve. PostHog receives usage events only. It does not receive your listing content, your identity documents, or your messages, and neither screen recording nor session replay is enabled on either surface.
• Resend — for delivering transactional emails (e.g., verification confirmations and reminders, listing status updates, inquiry notifications) agent invitations sent by a broker, and, if you joined the founding-broker cohort on our website, those cohort emails. Resend processes your email address, name, and the content of these messages solely to deliver them.

We also use WhatsApp (operated by Meta Platforms) for support conversations and for the assisted verification call described in Section 2. Unlike the services above, Meta is not acting on our instructions when it carries those messages — it runs the messaging service on its own terms, as an independent controller — so anything you send us on WhatsApp is also governed by Meta's privacy policy. Using WhatsApp is always optional; you can reach us at support@lumingon.com instead.

These services are operated by Google or their respective providers and are subject to their own Privacy Policies. Google Firebase, Google Gemini, PostHog, and Resend act as data processors on our behalf and process personal data only on our instructions.

8. Data Storage and Security

Your data is stored securely using Firebase services provided by Google. All data is encrypted in transit using HTTPS/TLS.

Authentication is handled through secure social providers (Google/Apple) via Firebase Authentication, which provides industry-standard security.

Property images and profile photos are stored in Firebase Storage with access controls in place.

Cross-border data transfer: Our infrastructure is provided by Google Firebase. Your data is stored and processed on Google Cloud servers in Singapore (asia-southeast1), and may be processed in other Google data centre regions for backup and resilience. Because we are established in the United Arab Emirates and most of the people whose data we hold are in the Philippines, this involves transfers across all three jurisdictions.

Those transfers are made under our data processing agreement with Google, which incorporates Standard Contractual Clauses and commits Google to appropriate technical and organisational safeguards. lumingon remains accountable for personal data it transfers, in line with Article 22 of the UAE Personal Data Protection Law and Sections 20–21 of the Philippine Data Privacy Act of 2012.

The usage analytics described in Sections 2 and 7 is additionally processed by PostHog on servers in the United States, adding a fourth jurisdiction to those transfers. It is made under our data processing agreement with PostHog, which likewise incorporates Standard Contractual Clauses. Only usage events travel this way — your listings, documents, images and messages stay within the Google infrastructure described above.

9. Your Rights under the Data Privacy Act of 2012

Under the Philippine Data Privacy Act of 2012 (R.A. 10173), you have the following rights regarding your personal data:

• Right to be informed: You have the right to know how your data is being processed.
• Right to object: You can object to the processing of your personal data.
• Right to access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can correct any inaccurate or incomplete data.
• Right to erasure or blocking: You can request the suspension, withdrawal, or removal of your personal data.
• Right to damages: You may claim compensation if you suffered damages due to a violation of your data privacy rights.
• Right to data portability: You can obtain and electronically move, copy, or transfer your data in a secure manner.

If you believe your rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC).

10. Your Rights under UAE Data Protection Law

If you are in the United Arab Emirates, or where UAE law otherwise applies to our processing, Federal Decree-Law No. 45 of 2021 gives you the right to access your data, to request correction or erasure, to restrict or object to processing, to data portability, and to withdraw consent where consent is the basis we rely on.

Contact dpo@lumingon.com to exercise any of these. If you are not satisfied with our response, you may complain to the UAE Data Office.

11. Your Rights in the European Economic Area and the United Kingdom

If you are in the EEA or the UK, you have the rights described above together with the right to lodge a complaint with your local supervisory authority. Our legal bases are the performance of our agreement with you (providing the Services), our legitimate interests in operating a verified marketplace and preventing fraud, and your consent where we ask for it. We do not perform biometric verification for users in the EEA or the UK: identity verification there is based solely on the documents you submit, and no face video is requested or processed.

12. Children's Privacy

lumingon is not intended for use by children under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and updating the effective date above.

We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy or your data, please contact us at:
General Inquiries: support@lumingon.com
Data Protection Officer (DPO): dpo@lumingon.com