Subscription Services Agreement

Effective Date: January 1, 2026

Last Updated: January 1, 2026

These Terms of Service ("Terms," "Agreement") constitute a legally binding agreement between you ("User," "Subscriber," or "you") and LumaClaims, LLC ("Company," "we," "us," or "our") governing your access to and use of the LumaClaims Platform (the "Platform") and all related services, tools, data, and content.

BY CREATING AN ACCOUNT, COMPLETING THE SUBSCRIPTION PURCHASE PROCESS, OR ACCESSING OR USING THE PLATFORM IN ANY WAY, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS IN THEIR ENTIRETY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT ACCESS OR USE THE PLATFORM.

If you are entering into this Agreement on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms.

The Platform is intended solely for use by individuals and entities located in the United States. By accessing or using the Platform, you represent and warrant that you are located in the United States. We make no representation that the Platform or its content is appropriate or available for use in any other jurisdiction. Access from outside the United States is prohibited, and we reserve the right to terminate any account we determine to be accessing the Platform from a non-US location.

2.1 Description of Services

The Platform provides subscribers with access to Medicare Part B claims data analytics, sourced from the Centers for Medicare & Medicaid Services ("CMS") through Freedom of Information Act ("FOIA") requests. The Platform is not endorsed by, affiliated with, or sponsored by CMS or any government agency.

Currently, the dataset covers Medicare Part B claims with dates of service from January 1, 2020 through December 31, 2025, containing over 10 billion records across Carrier and Durable Medical Equipment ("DME") claim types.

2.2 Subscription Configuration

Upon subscribing, you will configure your subscription by selecting:

• Claim Type: Either Carrier claims or DME (Durable Medical Equipment) claims — not both simultaneously
• HCPCS Codes: Exactly three (3) Healthcare Common Procedure Coding System ("HCPCS") codes within your selected claim type

Your selected configuration defines the scope of data and analytics you may access during your subscription term.

2.3 Data Exports

Subscribers may export data and analytics in the following formats:

• Tabular data: CSV (.csv) files
• Chart visualizations: PNG (.png) image files

3.1 Subscription Period

Subscriptions are sold in one (1) year increments. Your subscription term begins on the date your payment is successfully processed and expires twelve (12) months thereafter, unless earlier terminated in accordance with these Terms.

3.2 Fees and Payment

Subscription fees are disclosed at the time of purchase. All fees are quoted in U.S. dollars and are exclusive of applicable taxes.

3.3 Taxes

You are responsible for all taxes, duties, and similar governmental assessments associated with your subscription, excluding taxes on our net income. If we are required to collect taxes on your behalf, such amounts will be added to your fees.

4.1 License Grant

Subject to your compliance with these Terms and timely payment of all fees, we grant you a limited, non-exclusive, non-transferable, non-sublicensable license to access and use the Platform, and to download and use exported data and chart images, solely for your internal business purposes as set forth herein.

4.2 Permitted Uses

You may use data, analytics, and exported content from the Platform for:

• Internal business analysis, reporting, and decision-making
• Research and market assessment within your organization
• Incorporation into your own reports, presentations, or publications, provided that such use does not constitute a Prohibited Use as defined in Section 4.3
• Sharing with clients, partners, or third parties as part of your ordinary business operations, subject to the restrictions in Section 4.3

4.3 Prohibited Uses

The following uses are strictly prohibited:

• Competitive Analytics Products: You may not use any data, analytics, exports, or derivative works from the Platform to build, train, develop, operate, or market any product, service, application, tool, or platform that is substantially similar to or competitive with the Platform, including but not limited to Medicare claims analytics services, HCPCS utilization data products, or Medicare Part B data subscription services.
• Resale of Raw Data: You may not resell, redistribute, relicense, or otherwise commercialize the raw underlying data obtained from the Platform as a standalone data product.
• Reverse Engineering: You may not attempt to reverse engineer, decompile, disassemble, or otherwise derive the source code, data structures, or methodologies underlying the Platform.
• Unauthorized Access: You may not use automated means (bots, scrapers, spiders) to access, download, or extract data from the Platform beyond what is expressly permitted through the Platform's export features.
• Circumvention: You may not create multiple accounts, manipulate configurations, or otherwise attempt to circumvent subscription limits, configuration change restrictions, or export limitations.
• Account Sharing: Your subscription is for your sole use. You may not share your account credentials with, or transfer access to, any third party.
• Unlawful Use: You may not use the Platform for any purpose that violates applicable law, including healthcare regulations, export control laws, or anti-discrimination statutes.
• Medical or Legal Advice: You may not use Platform data or analytics as a substitute for professional medical, clinical, legal, regulatory, or compliance advice.

5.1 Account Registration

You must create an account to access the Platform. You agree to provide accurate, complete, and current information during registration and to update such information as necessary. You must be at least 18 years of age and have the legal capacity to enter into this Agreement.

5.2 Account Security

You are solely responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You agree to notify us immediately of any unauthorized use of your account or any other breach of security at https://lumaclaims.com/contact.

We are not liable for any loss or damage arising from your failure to maintain adequate account security.

6.1 Source and Nature of Data

All data provided through the Platform originates from CMS Medicare Part B claims, obtained via FOIA requests. The data has been anonymized by CMS prior to release. Accordingly:

• The data does not contain personally identifiable information (PII) of Medicare beneficiaries
• The data does not enable longitudinal tracking of individual patients across claims
• The data does include certain demographic fields retained by CMS, including beneficiary race, sex, and mailing ZIP code
• The Platform is not a covered entity or business associate under the Health Insurance Portability and Accountability Act (HIPAA), and the data provided does not constitute Protected Health Information (PHI) as defined by HIPAA

6.2 No Guarantee of Accuracy

While we apply rigorous data processing and validation procedures, we cannot guarantee the complete accuracy, completeness, or timeliness of the underlying data as provided by CMS. The data is provided on an "as is" basis. We are not responsible for errors, omissions, or inaccuracies in the source data.

During processing, a small percentage of records (less than 0.003% of Carrier claims and less than 0.0001% of DME claims) were excluded due to data quality issues. These exclusions are documented in the Platform's data disclosure materials.

6.3 Not Medical or Legal Advice

The data, analytics, visualizations, and analyses provided through the Platform are for informational and research purposes only. Nothing on the Platform constitutes medical advice, clinical guidance, legal counsel, financial advice, or regulatory guidance. You should consult qualified professionals for any such needs.

6.4 Disclaimer of Warranties

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE PLATFORM AND ALL DATA, CONTENT, AND SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

WE DO NOT WARRANT THAT THE PLATFORM WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE, OR THAT ANY DEFECTS WILL BE CORRECTED.

7.1 Our Intellectual Property

The Platform, including its design, software, algorithms, data processing methodologies, visualizations, user interface, and all content we create (excluding the underlying CMS source data), is owned by or licensed to us and is protected by copyright, trade secret, and other intellectual property laws. These Terms do not transfer any intellectual property rights to you beyond the limited license described in Section 4.1.

7.2 CMS Data

The underlying Medicare claims data is a work of the U.S. federal government. Your use of that data is subject to the terms of these Terms and any applicable CMS data use conditions. We make no additional intellectual property claims over the raw government data itself.

7.3 Feedback

If you provide suggestions, feedback, or ideas regarding the Platform, you grant us a perpetual, irrevocable, royalty-free license to use such feedback for any purpose without obligation or compensation to you.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

• IN NO EVENT WILL WE BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING LOST PROFITS, LOSS OF DATA, LOSS OF BUSINESS OPPORTUNITY, OR REPUTATIONAL HARM, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
• OUR TOTAL CUMULATIVE LIABILITY TO YOU FOR ANY CLAIMS ARISING UNDER OR RELATED TO THESE TERMS OR THE PLATFORM SHALL NOT EXCEED THE TOTAL SUBSCRIPTION FEES YOU PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

Some jurisdictions do not allow the exclusion or limitation of certain damages. In such jurisdictions, our liability will be limited to the maximum extent permitted by law.

You agree to indemnify, defend, and hold harmless us and our officers, directors, employees, agents, and contractors from and against any claims, liabilities, damages, losses, and expenses (including reasonable attorneys' fees) arising out of or in any way connected with: (a) your violation of these Terms; (b) your use of the Platform or exported data in a manner not expressly authorized herein; (c) your violation of any applicable law or the rights of any third party; or (d) any content or materials you submit or transmit through the Platform.

10.1 Term

These Terms are effective as of the date you first access the Platform and remain in effect until your subscription expires or is terminated.

10.2 Termination by Us

We reserve the right to suspend or terminate your account and subscription immediately, with or without notice, if:

• You breach any provision of these Terms, including any prohibited use
• We determine that your use poses a risk of harm to the Platform, other users, or third parties
• You fail to pay any fees when due
• Required to do so by applicable law or court order

10.3 Effect of Termination

Upon termination or expiration of your subscription: (a) all licenses granted to you under these Terms immediately terminate; (b) you must cease all use of the Platform; (c) data exports you have legitimately downloaded prior to termination may be retained subject to the permitted use restrictions in Section 4. We are not obligated to retain your configuration settings or provide access to additional data following termination.

These Terms are governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of law principles.

11.1 Informal Resolution

Before initiating formal proceedings, you agree to attempt to resolve any dispute by contacting us at https://lumaclaims.com/contact. We will attempt to resolve the dispute informally within thirty (30) days.

11.2 Dispute Resolution

Any dispute not resolved informally shall be submitted to binding arbitration administered by AAA under its Commercial Arbitration Rules, with proceedings conducted in Tampa, Florida.

YOU AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION.

12.1 Entire Agreement

These Terms, together with our Privacy Policy, constitute the entire agreement between you and us regarding the Platform and supersede all prior agreements and understandings.

12.2 Modifications

We reserve the right to modify these Terms at any time. We will provide notice of material changes by email to the address on file with your account and by posting the updated Terms on our website at least thirty (30) days before the changes take effect. The updated Terms will display a revised "Last Updated" date. Your continued use of the Platform after the effective date of any modification constitutes your acceptance of the revised Terms. If you do not agree to the modified Terms, you must stop using the Platform before the effective date.

12.3 Severability

If any provision of these Terms is found to be unenforceable, the remaining provisions will continue in full force and effect, and the unenforceable provision will be modified to the minimum extent necessary to make it enforceable.

12.4 Waiver

Our failure to enforce any provision of these Terms shall not constitute a waiver of our right to enforce that provision in the future.

12.5 Assignment

You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. We may assign these Terms freely in connection with a merger, acquisition, or sale of our assets.