Lumi Kids1. Who we are
The app and this website are operated by APPFUSION LABS. For any privacy matter write to hello@lumikids.live; we answer within 30 days at the latest.
2. What we process
| Data | Why | Retention |
|---|---|---|
| Anonymous device id and secret (stored server-side only as a hash) | To recognise the device without an account and attach progress and purchased minutes to it | Until you delete it |
| Child profile: name or nickname, age, avatar, target language | So the app can address the child and adapt difficulty to age | Until you delete it |
| Progress: completed exercises, score, stars, badges, review schedule, games and room items | To resume, schedule revision and build the weekly report | Until you delete it |
| Talk-time records (seconds used, daily and weekly totals) | To enforce purchased minutes, Lumi Plus’s weekly minutes and the daily limit you set | Until you delete it |
| Purchase records: Apple transaction id, product, date, environment | To verify purchases, prevent double credit and restore purchases | Statutory retention period |
| Subscription records (Lumi Plus): Apple’s original transaction id, plan, status, renewal or expiry date, trial; the notifications Apple sends us about renewals, cancellations and refunds | To turn on the Lumi Plus levels and weekly minutes on the buyer’s devices, and to end them when the subscription ends | Statutory retention period |
| Parent PIN (stored only as a hash) | To protect the parent zone | Until you delete it |
| Technical events (e.g. “exercise finished”, “game started”) and app version | Debugging and improving the curriculum | Max. 24 months |
| Anonymous install id (a random value created on the device at first launch and kept in its keychain; it contains no name, Apple ID or advertising identifier) | To tie the usage records below to one installation | Until you delete it |
| Usage and health records: screens opened, exercises and tests completed, content downloads, purchase steps, errors (e.g. a clip that failed to play, a failed download), device model, iOS and app version | To notice and fix problems before you have to report them; the usage report in the parent zone | 90 days (an aggregated statistics copy also expires by itself within 90 days) |
| Audio during live conversation | So Lumi can hear the child and answer instantly | Not stored. Processed in real time only |
Usage records never contain names, free text or audio and go only to our own server; the app contains no third-party analytics or advertising SDK.
The app does not use location, contacts, photos, device advertising identifiers (IDFA) or cookie-like trackers. Microphone access is used only on the “Talk to Lumi” screen and only while the conversation lasts.
3. Legal basis and parental consent
Under GDPR (and Turkey’s KVKK) we process this data to perform the contract — providing the app — and on legitimate interests for security and debugging. The adult who installs the app and makes purchases is the person consenting on the child’s behalf. We collect no personal data directly from children beyond the name (which may be a nickname) entered by the adult.
4. Processors
- Cloudflare — servers, database and usage statistics (Workers, D1, Analytics Engine), where progress, minute and usage records live.
- OpenAI — the live conversation model and the voice-over generation. During a live chat, audio is streamed in real time so a reply can be produced, not used for model training; OpenAI may keep it for up to 30 days to detect abuse, then deletes it.
- Apple — app distribution and payment (App Store / StoreKit). We never see your card details.
These providers act only on our instructions. We never share or sell data for advertising.
5. International transfers
Servers and the providers above may be located in the European Union and the United States. Transfers rely on standard contractual clauses and the providers’ data processing agreements.
6. Your rights
- Deletion: in the app, parent zone → “Delete all data”. Profiles, progress, minute and usage records are removed from the server too.
- Access, correction, objection and portability: write to hello@lumikids.live. We may ask for a purchase reference or the last 8 characters of the device id to verify you.
- You may complain to your local data protection authority (in Turkey, the KVKK authority).
7. This website
Fonts and images are served from our own domain, so the page makes no third-party requests until you consent to statistics or start using the waitlist form (Cloudflare Turnstile, see below). There are no advertising scripts, social media buttons or advertising trackers at all. The site is hosted on Cloudflare, which may keep short-lived technical logs (IP address, browser type) for security.
Visit statistics (Google Analytics) — only with consent
We use Google Analytics 4 to see which pages are useful. We ask you on your first visit:
- If you decline, no cookie is written, any existing ones are deleted and measurement stops. The site works exactly the same.
- For visitors from the European Economic Area, the UK and Switzerland the tag is not loaded at all until you press “Accept” — not a single request reaches Google. (The region comes from Cloudflare’s country signal; when it is unclear we apply the strictest behaviour.)
- Elsewhere the tag loads with the page but writes no cookie until you consent
(Google Consent Mode v2,
analytics_storage = denied). - If you accept, Google Analytics loads and writes the
_gaand_ga_<id>cookies (2-year lifetime, used to count visits). What is collected is anonymous: page address, referring site, approximate location (IP anonymised), device and browser type. Advertising features are switched off (ad_storage,ad_user_data,ad_personalization= denied). - If your browser sends a Global Privacy Control or “Do Not Track” signal, we decline without asking.
- You can change your choice any time through the “Cookie choice” link in the footer.
Processor: Google Ireland Limited (under EU standard contractual clauses). Retention in our property is 14 months. Google Analytics runs on this website only — the app itself contains no analytics or advertising SDK, and none of your child’s app data reaches Google. You may also use Google’s opt-out add-on.
Launch waitlist (founding families)
If you join the Lumi Kids list on this website, the following applies. The list is run by the Lumi Kids web app (app.lumikids.live) for this website; the controller is the same (section 1).
- Data: your e-mail address; the page language; the country derived from your connection; if you choose to give them, your child’s age band and the language your child would like to learn; where you came from (the campaign parameters of the link, such as utm_source, the referring page and the page you signed up on); the referral codes (your own personal code and, if you came through another family’s link, theirs); the time of your consent and the version of the consent text; when we sent you e-mails and when you confirmed or unsubscribed; and a keyed hash of your IP address (not the address itself), kept for 30 days to stop mass sign-ups.
- Purposes: to confirm your address (double opt-in); to tell you when Lumi Kids opens; to send you the founding-family offer (30% off the first month of a monthly plan, applied when you sign in with the same e-mail address) and at most one reminder before it ends; to count how many families joined through your personal link.
- Legal basis: your consent (GDPR Art. 6(1)(a)), which you can withdraw at any time with the unsubscribe link in every e-mail or by writing to us. Bot protection and the abuse limit rely on our legitimate interest in a clean list (Art. 6(1)(f)).
- Retention: until you unsubscribe, and at most 400 days (about 13 months) after you signed up. Sign-ups that are never confirmed are deleted after 30 days, and so are entries 30 days after an unsubscribe.
- Recipient: Cloudflare, our processor for hosting, the database and e-mail sending (and Turnstile). We use no other e-mail or marketing service and never sell or share the list.
- Cloudflare Turnstile: when you start filling in the form, your browser loads Turnstile from challenges.cloudflare.com to check that a person, not a bot, is signing up. Cloudflare processes technical data such as your IP address and browser characteristics for this; Turnstile is not used for advertising. It is not loaded unless you use the form.
8. Buying Lumi Plus on our website (go.lumikids.live)
When you take the quiz and buy Lumi Plus on the web, we process your e-mail address (your Lumi Plus account, sign-in codes, receipts and the trial reminder), your quiz answers (the child's age, learning language, goal and, if you give it, the child's first name, which only personalises the app and is never shared with advertisers) and payment data, which Stripe (Stripe, Inc., USA) processes as an independent controller; we receive no card numbers.
With your consent (and, outside the EEA, the UK, Switzerland and Türkiye, unless you turn it off) we use Meta's measurement (Meta Pixel and Conversions API, Meta Platforms Ireland Ltd.) to see which ads bring families to Lumi: a hashed e-mail address, the IP address, browser data and click ids are shared with Meta for this purpose; we delete the IP address and browser data after 30 days. The Lumi Kids app itself sends nothing to Meta.
You can sign in to the app with this e-mail address. You can delete the account in the app (Parents → Lumi Plus account) or by writing to hello@lumikids.live.
9. Security
All connections are encrypted with TLS. Device secrets and the parent PIN are stored only as SHA-256 hashes. Purchases are verified server-side against Apple’s signature.
10. Changes
If this policy changes we update this page and notify you inside the app for significant changes.
Last updated: · hello@lumikids.live