PRIVACY POLICY AND TERMS OF USE FOR FAMILIES AND GUESTS

Version 1.3 – Effective Date: January 11, 2026

This document governs the access to and use of the Lumina Memorials platform (hereinafter, the "Platform"), a digital tribute technology service provided to you through the funeral home in charge of the service.

1. Who We Are

The service is technically operated by Pedro Sanz Bruguera (Lumina Memorials), holder of NIF 43503332M. We act as the Data Processor on behalf of the funeral home (which is the Data Controller of the service you have contracted).

2. Purpose and Use of the Platform

The Platform allows the family and loved ones to create a shared space for memories (photos, videos, messages) for the purpose of generating a final tribute video.

• Moderation Tools: The family, as the administrator of the "Capsule," has access to a control panel to supervise, accept, or delete any content uploaded by guests before the final tribute is generated.

3. Retention Period and Download (CRITICAL)

The service has a limited duration focused on the creation of the tribute:

• 30-Day Term: The platform will keep the capsule active and the contents accessible for a period of thirty (30) calendar days from its activation.

• Obligation to Download: It is the sole responsibility of the family to download the final tribute video and/or the collected files before this term expires.

• Notification and Deletion: Lumina Memorials will send a prior notice to the contact email before the expiration date. Once the 30-day period has elapsed, Lumina will proceed with the permanent and irreversible deletion of all multimedia content to protect user privacy. Recovery of such content will not be possible thereafter.

4. Data of Deceased Persons

In accordance with Article 3 of the Spanish LOPDGDD, we respect the right of relatives and heirs to manage the digital presence of the deceased, allowing them to request access to or erasure of their memories within the service's term of validity.

5. Content Standards

You and your guests agree not to post offensive, illegal content or content that violates the rights of third parties. Lumina reserves the right to remove content that violates these standards or upon receiving a legitimate complaint.

6. Liability

Lumina Memorials provides the technology but is not liable for the content posted by users or for the loss of files if the family fails to download them within the stipulated 30-day period. The family acts as the moderator and is ultimately responsible for what they choose to include in their tribute.

7. Rights (Access, Rectification, and Erasure)

You may exercise your data protection rights by sending an email to info@luminamemorials.com along with a copy of your government-issued ID.