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 totals) | To enforce purchased 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 |
| 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 |
| Audio during live conversation | So Lumi can hear the child and answer instantly | Not stored. Processed in real time only |
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 and database (Workers, D1), where progress and minute 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, configured not to be stored or used for model training (
store: false). - 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 and minute 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. 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.
If you join the launch list, we store your e-mail address solely to send the launch announcement and delete it no later than 3 months afterwards. Write to us any time to be removed.
8. 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.
9. Changes
If this policy changes we update this page and notify you inside the app for significant changes.
Last updated: 2026-09-16 · hello@lumikids.live