The Digital Services Act (EU) Statement

Information on Average Monthly Active Recipients of Service in the European Union

The Digital Services Act (DSA) entered into force on November 16, 2022, as part of the European Parliament's initiative to protect consumer rights online and enhance transparency and accountability for intermediary services. Intermediary services encompass platforms that facilitate online interactions, including personalised content and training experience solutions.

Our company Lumos Labs Inc, USA provides personalised content and training experience through a platform in the European Union, offering secure and scalable solutions for managing and learning new experiences through content and training.

In accordance with Article 24(2) of the DSA, online platforms must publish information regarding the average monthly active recipients of their services within the Union. This metric is calculated as an average over the past six months to determine whether a platform qualifies as a Very Large Online Platform (VLOP), defined by having at least 45 million average monthly active recipients in the European Union.

We have analyzed the average monthly active recipients of our personalised content and training experience services through a platform in the EU for the past six months (as of 28 August 2025), and the number remains well below the 45 million threshold required for classification as a Very Large Online Platform.

To ensure accuracy, our calculation includes:

1. All enterprise customers/individuals utilizing our personalised content and training solution.
2. Administrators managing personalised content and training services within organizations.
3. Unique users accessing the platform for personalised content and training for learning new experiences.

We remain committed to transparency and will update this section periodically with the latest information on the average monthly active recipients of our personalised content and training services in the European Union.