Lustum

Account Deletion & Data Retention Policy

Updated October 12, 2026

Keysuccess Limited (“Lustum”, “we”, “us”, or “our”) is committed to protecting your privacy and providing transparent control over your personal data. This Account Deletion & Data Retention Policy explains how users of the Lustum mobile application (available on Android and iOS) and the Lustum web platform (lustum.com) can request the deletion of their account and associated personal data, outlines what data is permanently erased, and details what data is retained pursuant to statutory legal, regulatory, and financial compliance requirements.

1. Important Prerequisites Before Requesting Deletion

Before submitting an account deletion request, please ensure you have completed the following steps to ensure an orderly account closure:

  1. Withdraw Remaining Balances: Transfer out or spend all remaining USD balances, stablecoins, or digital asset balances held in your Lustum account. Once your account is deleted, you will permanently lose access to the app and wallet interfaces, and unwithdrawn funds cannot be recovered through the app.
  2. Settle Pending Transactions: Ensure there are no pending card authorizations, outgoing or incoming transfers, active chargebacks, disputed payments, or fee settlements. Accounts with pending or unresolved transactions cannot be closed until all operations have settled.
  3. Cancel Active Lustum Spend Cards: All virtual and physical payment cards associated with your Lustum account will be permanently deactivated and canceled upon account closure. Please update any recurring subscriptions or merchant billing profiles tied to your Lustum card with an alternate payment method before closing your account.
  4. Resolve Negative Balances: Any outstanding liabilities, negative balances, or unpaid fees owed to Lustum or our partner institutions must be cleared prior to account deletion.

2. How to Request Account Deletion

You can request the deletion of your Lustum account and associated data using either of the two methods described below.

Option A: In-App Account Deletion (Fastest & Recommended)

If you currently have the Lustum App installed on your mobile device:

  1. Open the Lustum App and log in to your account.
  2. Navigate to Settings or Profile by tapping your avatar or the settings icon in the navigation bar.
  3. Select Security & Privacy (or Account Settings).
  4. Scroll to the bottom of the screen and tap Delete Account.
  5. Carefully review the on-screen information regarding balance withdrawal, card termination, and regulatory record retention.
  6. Confirm your deletion request by authenticating with your biometric credential (Face ID / Fingerprint) or entering your device PIN / account passcode.
  7. Upon confirmation, your session will immediately terminate, your cards will be deactivated, and the deletion process will begin.

Option B: Web & Email Deletion Request (If App Uninstalled or Device Inaccessible)

If you have uninstalled the Lustum App, no longer have access to your mobile device, or prefer to submit a request via web/email:

  1. Compose an email from the email address registered with your Lustum account.
  2. Send the email to [email protected] with the subject line: Account Deletion Request - [Your Registered Email].
  3. In the email body, provide:
    • Your full legal name as registered in the Lustum App;
    • The mobile phone number associated with your account;
    • A clear statement confirming: “I request the permanent closure of my Lustum account and the deletion of my associated personal data.”
  4. Identity Verification: To protect your account against unauthorized or fraudulent deletion requests, our support team will verify your identity before executing the deletion. Please do not attach sensitive identity documents (such as passports or national IDs) to unencrypted emails unless directed via our secure verification portal.
  5. Once your identity and the prerequisite conditions are verified, our support team will process the account closure and notify you via email.

3. Personal Data That Is Permanently Deleted

Upon verification and processing of your deletion request, Lustum permanently removes, anonymizes, or disassociates the following categories of data from active production systems:

  • Authentication & Credentials: Password hashes, login credentials, two-factor authentication secrets, biometric session tokens, and active session keys.
  • Profile Information: Profile avatar, display name, username, nickname, notification preferences, and application settings.
  • Marketing & Communications Data: Marketing opt-in records, promotional email lists, push notification registrations, and customer feedback surveys.
  • Device & Technical Telemetry: Mobile device identifiers (GAID, IDFV), push notification tokens, and temporary diagnostic crash logs not required for security or compliance auditing.
  • Active Platform Access: Immediate and permanent revocation of all access tokens, invalidation of card issuing profiles, and termination of all active sessions across all devices.

4. Data Retained Under Statutory Laws and Regulations

Lustum provides financial technology services, including payment cards, funds transfers, and digital asset functionality, in partnership with licensed and regulated financial institutions, banking partners, and card issuers.

Under applicable international and domestic statutory laws, financial entities are legally required to retain customer identification and financial transaction records for mandatory statutory periods. These legal retention mandates take precedence over general data erasure requests under data privacy legislation (including the Hong Kong Personal Data (Privacy) Ordinance, the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and equivalent privacy frameworks).

Lustum and its regulated partners retain the following categories of data:

4.1. Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and KYC Records

  • Data Retained: Customer Due Diligence (CDD) records collected during identity verification, including full legal name, date of birth, residential address, nationality, government-issued identification document details and copies (e.g., passport, national identity card, driver’s license), proof of address documentation, tax identification number, Politically Exposed Persons (PEP) screening records, sanctions check logs, and verification outcome timestamps.
  • Legal Justification: Mandatory compliance with anti-money laundering and counter-terrorist financing legislation, including the Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (AMLO), the U.S. Bank Secrecy Act (BSA) / FinCEN regulations, Financial Action Task Force (FATF) recommendations, and partner bank compliance obligations.
  • Retention Period: Typically 5 to 7 years following the date of account closure and cessation of the business relationship, depending on the governing jurisdiction.
  • Biometric Data Note: As set out in our Privacy Policy, Lustum does not store raw biometric facial geometry. Biometric liveness and matching are performed by licensed third-party identity verification providers under their independent regulatory and privacy obligations.

4.2. Financial Transaction, Ledger & Bookkeeping Records

  • Data Retained: Complete historical records of all financial transactions, including deposits, withdrawals, cross-border transfers, card payments, currency conversions, fee assessments, chargebacks, payment reversals, transaction counterparties, timestamps, and account ledger statements.
  • Legal Justification: Statutory corporate bookkeeping requirements, tax reporting laws, financial auditing regulations, and payment card network operating rules (Visa/Mastercard).
  • Retention Period: Typically 5 to 7 years from the date the transaction was completed or from the close of the relevant financial tax year.

4.3. Fraud Prevention, Security Logs & Legal Defense Records

  • Data Retained: Security incident reports, fraud detection telemetry, suspicious activity monitoring records, dispute and chargeback resolution documentation, and correspondence relating to legal claims or regulatory inquiries.
  • Legal Justification: Legitimate interests in detecting and preventing financial crime, safeguarding platform integrity, complying with lawful regulatory or law enforcement requests, and establishing, exercising, or defending legal claims within applicable statutory limitation periods (typically 6 to 7 years).

4.4. Blockchain and Distributed Ledger Records

  • Immutable Records: Transactions broadcast to public decentralized blockchains (such as public wallet addresses, transaction hashes, block numbers, and timestamps) are permanent, mathematically immutable, and recorded on distributed public ledgers. Neither Lustum nor any third party has the ability to alter, redact, or delete public blockchain data.

4.5. Regulated Third-Party Service Providers

  • Independent Obligations: Regulated third-party service providers involved in providing services through the App (such as banking partners, licensed card issuers, and payment processors) act as independent data controllers and are subject to their own statutory retention obligations under their respective banking and financial licenses. Deletion of your data by Lustum does not alter the independent legal duties of such regulated partners.

5. Safeguarding of Retained Data & Eventual Deletion

Lustum implements strict safeguards to protect personal data during statutory retention:

  1. Access Restrictions & Segregation: Following account closure, retained data is isolated from active operational environments and placed into restricted-access archives. It is accessible solely by designated compliance, legal, security, and audit personnel for regulatory, legal, or auditing purposes.
  2. No Commercial Use: Retained records are strictly quarantined and never used for marketing, advertising, automated decision-making, or commercial purposes.
  3. Technical Safeguards: All retained data is protected with strong industry-standard encryption both in transit and at rest, multi-factor access authentication, and comprehensive audit logging.
  4. Permanent Destruction: Once the mandatory statutory retention period expires (e.g., 5 to 7 years post-closure), the retained data is securely and permanently purged from archives or irreversibly anonymized in accordance with industry best practices.

6. Processing Timeframe

  • Account Deactivation: Immediate upon in-app confirmation, or within 24 to 48 business hours following verification of an email request, provided all account balances are zero and transactions settled.
  • Purge of Eligible Personal Data: Deletion of non-retained personal data across active production systems is completed within 30 calendar days of the verified request.
  • Confirmation: You will receive an email confirmation once your account has been permanently closed and eligible data deleted.

7. Contact and Support

If you have any questions about deleting your account, data retention periods, or exercising your privacy rights, please contact us: