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Terms and Conditions for Lummo

Last Updated: November 12, 2025

1. Description of Service
Lummo is a technology platform operated by Cowlabs Ltd that enables parents and guardians ("Parents," "you") to invest for their children's future by facilitating the purchase of assets for their children's accounts ("Child Accounts").
Key Points:

Lummo acts as a technology facilitator and interface platform only
We partner with third-party licensed cryptocurrency and investment service providers to enable asset purchases
We do not ourselves buy, sell, custody, or hold cryptocurrency or other assets
Parents create and manage Child Accounts on behalf of their children
The Service currently supports Bitcoin purchases with plans to expand to other assets (Gold, Stocks, etc.)
Family members (such as grandparents or friends) may be invited to contribute to Child Accounts

Important: Lummo is not a regulated investment firm, financial advisor, cryptocurrency exchange, or financial institution. We provide technology services only.

2. Eligibility
To use our Service, you must:

Be at least 18 years old
Be a resident of a jurisdiction where our third-party service providers are licensed to operate (currently including the United Kingdom, European Economic Area, and select US states)
Comply with all applicable laws and regulations in your jurisdiction
Not be located in a jurisdiction where cryptocurrency services are prohibited

By using the Service, you represent and warrant that you meet these requirements.
Specific jurisdictional restrictions may apply based on our third-party providers' licensing and operational capabilities.

3. Account Registration and Security
To use the Service, you must create an account. You agree to:

Provide accurate, current, and complete information during registration
Maintain and promptly update your account information
Maintain the security and confidentiality of your account credentials
Not share your account credentials with anyone
Notify us immediately at hello@getlummo.com of any unauthorized use or security breach
Accept responsibility for all activities that occur under your account

We reserve the right to suspend or terminate accounts that provide false information or violate these Terms.

4. Child Accounts
4.1 Creating Child Accounts
When you create a Child Account, you represent and warrant that:

The child is under 18 years of age
You will use the Child Account solely for the benefit of the named child

You acknowledge that:

You control all Child Accounts you create
Children cannot directly access or manage their accounts through the Service
You are responsible for all transactions made in Child Accounts
Assets purchased for Child Accounts are owned by you, as parent/guardian/relative, until transferred to the child in accordance with applicable laws in your jurisdiction

4.2 When Child Reaches Age of Majority
When a child reaches the age of 18 (or the age of majority in your jurisdiction):

The Child Account does not automatically transfer to the child
You, as the parent/guardian, retain control of the account and any assets unless you choose to transfer them
It is your responsibility to facilitate transfer of account access and assets to your child if desired
Transfer procedures will depend on the requirements of our third-party service providers
You should consult with legal and tax professionals regarding the proper transfer of assets to your child

We do not provide guidance on when or how to transfer assets to children, as this depends on individual circumstances and local laws.

4.3 Family Contributions
You may invite extended family members (such as grandparents, aunts, uncles, friends) to contribute to Child Accounts you control:

Family contributors must create their own Lummo accounts
Family contributors can make deposits to Child Accounts you've authorized them to access
You, as the account creator, maintain ultimate control over the Child Account
Family contributors cannot withdraw funds or modify account settings
Family contributors are bound by these Terms and must meet all eligibility requirements
You are responsible for managing which family members have contribution access


5. Third-Party Cryptocurrency and Investment Services
Lummo partners with licensed third-party providers to facilitate cryptocurrency and investment asset purchases.
You acknowledge and agree that:

When you purchase cryptocurrency or other assets through Lummo, you are entering into a separate, direct agreement with our third-party providers
Third-party providers have their own terms of service, privacy policies, and fee structures that govern your relationship with them
Third-party providers handle payment processing, Know Your Customer (KYC) verification, anti-money laundering (AML) compliance, transaction execution, and may custody cryptocurrency on your behalf
Lummo does not hold, custody, transmit, or control your funds or cryptocurrency or other assets at any time
Lummo is not responsible for the actions, services, failures, insolvency, or security breaches of third-party providers
You must comply with all terms and requirements of our third-party providers
Third-party providers may require identity verification before processing transactions
Third-party providers may restrict or refuse service based on their own compliance requirements

Your relationship with third-party providers is governed by their respective terms and policies. Lummo acts solely as a technology interface connecting you to these providers.

6. Fees and Costs
6.1 Lummo's Subscription Fees

Lummo charges a monthly subscription fee of $6/month or $49/year. (or equivalent in your local currency)
New users receive a 3-day free trial period
After the trial period, you will be charged $6/month or $49/year until you cancel
We reserve the right to modify subscription fees with 30 days' advance notice
Subscription fees are non-refundable except as required by law

6.2 Third-Party Fees
Third-party providers charge their own fees, which may include:

Cryptocurrency purchase fees (typically 1-5% of transaction value)
Payment processing fees
Network fees (blockchain transaction fees)
Currency conversion fees
Withdrawal or transfer fees

Important:

All third-party fees are disclosed by the provider before you complete a transaction
Fees are determined and charged by third-party providers, not Lummo
Third-party providers may change their fees at any time
You are responsible for all fees associated with using the Service


7. Cryptocurrency Risks and Disclaimers
IMPORTANT: Please read this section carefully.
Cryptocurrency and digital assets are highly risky and speculative. By using our Service, you acknowledge and accept the following risks:
7.1 Market Risks

Cryptocurrency prices are extremely volatile and can fluctuate dramatically within minutes
You may lose some or all of your invested capital
Past performance does not indicate future results
Cryptocurrency markets operate 24/7 globally and prices can change rapidly
There is no guarantee cryptocurrency will maintain any value

7.2 Regulatory Risks

Cryptocurrency regulation is evolving and uncertain across all jurisdictions
Future regulations may adversely affect cryptocurrency value, legality, or your ability to use it
Different countries and regions have different rules regarding cryptocurrency
Regulatory changes could make it illegal to own or trade cryptocurrency in your jurisdiction
Tax treatment of cryptocurrency varies by jurisdiction and may change

7.3 Technology Risks

Cryptocurrency transactions are irreversible - once sent, they typically cannot be recovered
Lost passwords, private keys, or recovery phrases may result in permanent loss of access to funds
Blockchain networks can experience delays, congestion, failures, forks, or attacks
Smart contract bugs or vulnerabilities may exist in cryptocurrency protocols
Technological obsolescence could affect cryptocurrency value

7.4 Custody and Counterparty Risks

Third-party providers who custody your cryptocurrency create counterparty risk
Custodians may be hacked, experience security breaches, go bankrupt, or lose access to funds
Cryptocurrency is NOT covered by the Financial Services Compensation Scheme (FSCS) in the UK or equivalent insurance schemes in other jurisdictions
Cryptocurrency is not legal tender in most jurisdictions
If a third-party provider fails, you may lose access to your cryptocurrency

7.5 Liquidity Risks

Withdrawal, transfer, or liquidation limitations may apply through third-party providers
Third-party providers may restrict, delay, or prevent access to your funds
During times of high volatility, services may be unavailable

NO GUARANTEES: We make no guarantees, representations, or warranties about cryptocurrency or any other asset performance, availability, security, or suitability for any purpose, including long-term investment for children.

8. Not Financial Advice
Lummo does not provide investment, financial, tax, or legal advice.

We do not recommend specific investments, strategies, or amounts to invest
Nothing on our Service constitutes a recommendation to buy, sell, or hold cryptocurrency
Information provided is for educational and informational purposes only
You are solely responsible for your own investment decisions and their consequences
You should consult with qualified financial, tax, and legal professionals before making investment decisions
We are not a regulated investment firm, financial advisor, or fiduciary

You invest at your own risk. All investment decisions are yours alone.

9. Prohibited Activities
You agree NOT to:

Use the Service for any illegal purpose or to violate any laws in your jurisdiction
Provide false, misleading, or fraudulent information
Create accounts on behalf of others without proper authorization
Attempt to gain unauthorized access to the Service, other users' accounts, or our systems
Interfere with, disrupt, or damage the Service, servers, or networks
Use automated systems (bots, scrapers, scripts) to access the Service without permission
Reverse engineer, decompile, disassemble, or attempt to derive source code from any part of the Service
Transmit viruses, malware, ransomware, or other malicious code
Use the Service to launder money, finance illegal activities, or evade taxes
Manipulate or attempt to manipulate cryptocurrency markets
Violate any third-party provider's terms of service or policies
Engage in any activity that could harm children or violate laws protecting minors
Use the Service if you are a competitor for purposes of monitoring, copying, or competitive analysis

Violation of these prohibitions may result in immediate account termination, forfeiture of funds, and legal action, including reporting to law enforcement.

10. Intellectual Property
10.1 Our Ownership
All content, features, functionality, and intellectual property of the Service are owned by Cowlabs Ltd or our licensors, including:

Software, code, and algorithms
Text, graphics, logos, images, and visual design
Trademarks, service marks, and trade names
The "Lummo" name and related branding

10.2 Your Content

You retain ownership of any information or content you provide through the Service
By using the Service, you grant us a worldwide, non-exclusive, royalty-free license to use, store, and process your content as necessary to provide and improve the Service
This license terminates when you delete your content or close your account, except where we must retain data for legal compliance

10.3 Restrictions
You may not:

Copy, modify, distribute, sell, or lease any part of our Service
Attempt to extract or access our source code
Create derivative works from our Service
Use our trademarks, logos, or branding without prior written permission
Remove or alter any copyright, trademark, or other proprietary notices


11. Cryptocurrency Ownership and Custody
IMPORTANT CLARIFICATION:
11.1 Where Your Cryptocurrency Lives

When you purchase cryptocurrency through Lummo, our third-party providers custody (hold) the cryptocurrency in wallets and accounts they control
Lummo tracks and displays your cryptocurrency balance but does not itself custody, hold, or control any cryptocurrency
Your legal and beneficial ownership rights to cryptocurrency depend on the terms and conditions of the third-party custodian

11.2 Legal Ownership

Cryptocurrency purchased through Child Accounts is legally owned by you, the parent/guardian/relative, until such time as you transfer it to your child in accordance with applicable laws
You bear all risks associated with holding cryptocurrency on behalf of your child
You are responsible for understanding and complying with tax obligations related to cryptocurrency held for children in your jurisdiction

11.3 Access and Control

You access and view your cryptocurrency through the Lummo Service interface
Actual withdrawal, transfer, or liquidation of cryptocurrency depends on third-party provider capabilities and policies
We cannot guarantee that you can withdraw, transfer, or liquidate cryptocurrency at any given time
Third-party providers may impose waiting periods, verification requirements, or other restrictions

11.4 Service Termination or Disruption

If Lummo ceases operations, experiences service disruption, or terminates your account, you will need to work directly with our third-party providers to access your cryptocurrency
We will provide reasonable advance notice and instructions in the event of planned service shutdown (subject to legal and practical constraints)
Keep records of your transactions, account identifiers, and third-party provider information to maintain access to your cryptocurrency independently of Lummo
We recommend periodically documenting your holdings and provider relationships

12. Privacy and Data Protection
Your privacy is important to us. Our collection, use, and protection of personal information is governed by our Privacy Policy, available at https://www.getlummo.com/privacy-policy.
By using the Service, you consent to:

Our collection and use of data as described in the Privacy Policy
Sharing necessary information with third-party providers to facilitate transactions and comply with their KYC/AML requirements
Our compliance with legal requirements to report certain transactions, users, or activities to regulatory authorities, law enforcement, or tax authorities
International transfer of your data to jurisdictions where our third-party providers operate


13. Account Termination
13.1 Your Right to Terminate
You may close your account at any time by contacting hello@getlummo.com.

Before closing your account:

Cancel your subscription to avoid future charges
Understand that cryptocurrency will remain with our third-party providers
Contact third-party providers directly regarding your cryptocurrency holdings
Be aware that third-party providers may charge fees for any transfers or withdrawals

13.2 Our Right to Terminate
We may suspend or terminate your account immediately, with or without notice, if:

You violate these Terms or any applicable laws
We suspect fraudulent, illegal, or unauthorized activity
Required by law, court order, or regulatory authority
We discontinue the Service or operations in your jurisdiction
Third-party providers terminate their relationship with us or with you
Your account has been inactive for an extended period
We believe termination is necessary to protect Lummo, other users, or third parties

13.3 Effect of Termination
Upon termination:

Your access to the Service will cease immediately
Your subscription will be cancelled (no refund for partial months)
You remain responsible for any outstanding obligations, fees, or liabilities
You must work directly with third-party providers to access any cryptocurrency or assets
Sections of these Terms that should survive termination (including indemnification, limitation of liability, and dispute resolution) will continue to apply
We may retain certain data as required by law or legitimate business purposes

14. Disclaimers and Warranties
TO THE MAXIMUM EXTENT PERMITTED BY LAW:
14.1 "AS IS" Service
THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO:

Warranties of merchantability, fitness for a particular purpose, or non-infringement
Warranties that the Service will be uninterrupted, timely, secure, or error-free
Warranties regarding the accuracy, reliability, or completeness of information
Warranties that defects or errors will be corrected
Warranties regarding the quality, performance, or results of the Service
Warranties regarding third-party services, providers, or their solvency

14.2 No Guarantees
WE DO NOT GUARANTEE OR WARRANT:

Cryptocurrency availability, price, value, or performance
Transaction processing speed, success, or finality
Third-party provider reliability, solvency, security, or continued operation
Protection against loss, theft, hacking, or unauthorized access
Regulatory compliance or legal status of cryptocurrency in your jurisdiction
Compatibility with your devices, software, or internet connection
That the Service will meet your specific requirements or expectations

14.3 Third-Party Disclaimer
We specifically disclaim all liability and responsibility for:

Actions, omissions, errors, or failures of third-party providers
Security breaches or hacks affecting third-party providers
Insolvency or bankruptcy of third-party providers
Changes to third-party provider terms, fees, or services

Your use of the Service is at your sole risk. You assume all risks associated with using the Service and investing in cryptocurrency.

15. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY LAW IN YOUR JURISDICTION:
15.1 Excluded Damages
COWLABS LTD, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AFFILIATES, AND LICENSORS SHALL NOT BE LIABLE FOR:

Any indirect, incidental, special, consequential, exemplary, or punitive damages
Loss of profits, revenue, business, data, use, goodwill, or other intangible losses
Loss of cryptocurrency value, investment losses, or opportunity costs
Damages arising from cryptocurrency market volatility or price fluctuations
Damages arising from third-party provider actions, failures, breaches, or insolvency
Damages from unauthorized access to your account due to your failure to maintain security
Service interruptions, delays, technical failures, or unavailability
Errors, bugs, viruses, or other harmful components
Your reliance on information provided through the Service
Tax liabilities or regulatory penalties you incur

15.2 Cap on Liability
IN NO EVENT SHALL OUR TOTAL LIABILITY TO YOU FOR ALL CLAIMS RELATED TO THE SERVICE EXCEED THE GREATER OF:

The subscription fees you paid to Lummo in the 12 months immediately preceding the claim, OR
$100 (or equivalent in your local currency)

15.3 Application
THIS LIMITATION APPLIES TO ALL CLAIMS, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
15.4 Exceptions
Nothing in these Terms excludes or limits our liability for:

Death or personal injury caused by our negligence
Fraud or fraudulent misrepresentation
Any other liability that cannot be excluded or limited under applicable law

Some jurisdictions do not allow certain limitations of liability, so some of the above limitations may not apply to you.

16. Indemnification
You agree to indemnify, defend, and hold harmless Cowlabs Ltd, its directors, officers, employees, agents, affiliates, and licensors from and against any and all claims, demands, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees and legal costs) arising from or related to:

Your use or misuse of the Service
Your violation of these Terms
Your violation of any laws, regulations, or third-party rights
Information, content, or data you provide through the Service
Your investment decisions and any resulting losses
Unauthorized use of your account resulting from your failure to maintain account security
Your failure to comply with third-party provider terms
Any claims made by your children or family members related to Child Accounts
Tax liabilities or penalties related to your use of the Service
Your negligence or willful misconduct

We reserve the right to assume exclusive defense and control of any matter subject to indemnification by you, at your expense. You agree to cooperate with our defense of such claims.

17. Dispute Resolution
17.1 Governing Law
These Terms are governed by and construed in accordance with:

The laws of England and Wales (if you are a UK resident)
The laws of your country of residence (for EU residents), to the extent they provide greater consumer protection
The laws of the State of Delaware, USA (for US residents), except to the extent state consumer protection laws apply

In all cases, governing law applies without regard to conflict of law principles.
17.2 Jurisdiction
For UK and EU Residents:
Any disputes arising from these Terms or the Service shall be subject to the exclusive jurisdiction of the courts of England and Wales, except where your local jurisdiction provides mandatory consumer protections that require disputes to be heard in your local courts.
For US Residents:
Any disputes arising from these Terms or the Service shall be subject to the exclusive jurisdiction of the courts of England and Wales, except where your local jurisdiction provides mandatory consumer protections that require disputes to be heard in your local courts.
17.3 Informal Resolution First
Before filing any legal claim, you agree to:

Contact us at hello@getlummo.com describing the issue
Provide us with 30 days to attempt informal resolution
Engage in good faith negotiations to resolve the dispute

This requirement does not prevent you from seeking urgent injunctive relief if necessary.
17.4 Class Action Waiver (US Residents Only)
IF YOU ARE A US RESIDENT: You agree that any dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action. You waive any right to participate in a class action lawsuit or class-wide arbitration against Lummo.
If this class action waiver is found unenforceable, the entirety of this arbitration provision shall be null and void.

18. Changes to Terms
We may modify these Terms at any time to reflect:

Changes in law or regulation
Changes to the Service or features
Changes to our third-party provider relationships
Security or operational requirements
Other business reasons

18.1 Notice of Changes
When we make changes:

We will update the "Last Updated" date at the top of these Terms
We will notify you by email (to your registered email address) or through prominent notice on the Service
Material changes will be announced at least 30 days in advance
Non-material changes (such as clarifications or formatting) may take effect immediately

18.2 Your Acceptance

Your continued use of the Service after changes take effect constitutes acceptance of the modified Terms
If you do not agree to changes, you must stop using the Service and may close your account

18.3 If You Disagree
If you do not agree to modified Terms:

Stop using the Service immediately
Contact us to close your account
Understand that cryptocurrency will remain with third-party providers (you must contact them separately)


19. General Provisions
19.1 Entire Agreement
These Terms, together with our Privacy Policy and any other policies referenced herein, constitute the entire agreement between you and Lummo regarding the Service and supersede all prior agreements, understandings, and communications.
19.2 Severability
If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable.
19.3 No Waiver
Our failure to enforce any right or provision of these Terms does not constitute a waiver of that right or provision. Any waiver must be in writing and signed by an authorized representative of Lummo.
19.4 Assignment

You may not assign, transfer, or delegate these Terms or your rights and obligations hereunder without our prior written consent
We may assign our rights and obligations under these Terms to any party, including in connection with a merger, acquisition, reorganization, or sale of assets
These Terms bind and benefit the parties and their respective successors and permitted assigns

19.5 Force Majeure
We are not liable for any delay or failure to perform resulting from causes beyond our reasonable control, including but not limited to:

Natural disasters, pandemics, epidemics, or public health emergencies
War, terrorism, riots, or civil unrest
Government actions, embargoes, or sanctions
Internet or telecommunications failures
Power outages or infrastructure failures
Cyberattacks or security incidents
Labor disputes or strikes
Failures or disruptions of third-party providers
Blockchain network failures, forks, or consensus failures
Regulatory changes that make performance illegal or impossible

19.6 No Third-Party Beneficiaries
These Terms do not create any third-party beneficiary rights except as expressly stated. Third-party providers are not parties to these Terms and have no rights or obligations hereunder.
19.7 Relationship
Nothing in these Terms creates any partnership, joint venture, agency, or employment relationship between you and Lummo. You are an independent user of the Service.
19.8 Language
These Terms are written in English. Any translations provided are for convenience only. If there is any conflict between the English version and a translation, the English version controls and prevails.
19.9 Headings
Section headings are for convenience only and do not affect the interpretation of these Terms.
19.10 Survival
Sections of these Terms that by their nature should survive termination will survive, including but not limited to: ownership provisions, warranty disclaimers, indemnification, limitations of liability, and dispute resolution provisions.

20. Contact Us
If you have questions, concerns, or complaints about these Terms or the Service, please contact us:
Email: hello@getlummo.com
Website: www.getlummo.com
Company: Cowlabs Ltd
Registered: England and Wales
For urgent security matters, please email immediately with "URGENT SECURITY" in the subject line. We will respond to all inquiries within 5 business days under normal circumstances.
For complaints or disputes that cannot be resolved through customer support, you may have the right to refer the matter to alternative dispute resolution or regulatory authorities in your jurisdiction.

21. Acknowledgment and Acceptance
BY CREATING AN ACCOUNT, ACCESSING, OR USING LUMMO, YOU ACKNOWLEDGE THAT:

You have read and understood these Terms in their entirety
You agree to be legally bound by these Terms
You understand that cryptocurrency investing involves substantial risk of loss
You are not relying on any statements, representations, or warranties not contained in these Terms
You have had the opportunity to seek independent legal and financial advice before using the Service
You understand that Lummo is a technology platform only and does not provide investment advice
You understand that your cryptocurrency is held by third-party providers, not Lummo
You accept all risks associated with cryptocurrency investing for yourself and your children

If you do not agree to these Terms, you must not use the Service.

BY USING LUMMO, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.