1. Introduction
Lumi Kids (“we”, “our”, “the app”) is a children’s audiobook application designed for toddlers aged 2–5. We are deeply committed to protecting the privacy of children and their families. This policy explains what data we collect, how we use it, and the rights you hold as a parent or guardian.
Lumi Kids complies with:
- Apple App Store Guidelines (including the Made for Kids designation)
- The Children’s Online Privacy Protection Act (COPPA)
- The General Data Protection Regulation (GDPR) — applicable to French and EU users
- Apple’s App Privacy requirements
2. Who This App Is For
Lumi Kids is directed at children under 13 years of age and is used under the supervision and consent of a parent or guardian. We do not knowingly collect personal data from children without verifiable parental consent.
3. Data We Collect
3.1 Data You Provide
- Parent/guardian email address (account creation, optional)
- Parent-recorded voice audio (if you use the voice recording feature — stored locally on device only)
- PIN code for Kid Lock (stored locally on device, never transmitted)
3.2 Data Collected Automatically
- Anonymous usage statistics (e.g., number of sessions, books played) — no personal identifiers attached
- Crash reports — device model, iOS version, anonymised stack traces
- In-app purchase records (processed entirely by Apple; we do not receive payment details)
3.3 Barcode / ISBN Scanning
When you scan a book’s barcode, the ISBN number is sent to our barcode database provider to retrieve book metadata (title, author, cover image). We have verified that this provider does not retain or share the ISBN queries tied to any user identity.
3.4 Data We Do NOT Collect
- No precise location data
- No microphone data other than parent-recorded voice (which stays on-device)
- No camera data (the camera is used exclusively for barcode scanning; no images are stored)
- No advertising identifiers (IDFA)
- No third-party advertising or tracking SDKs
4. How We Use Data
- To deliver and improve the audiobook experience
- To manage your subscription and restore purchases
- To diagnose crashes and fix technical issues
- To comply with legal obligations
We do not sell, rent, or share personal data with third parties for marketing purposes.
5. Parental Controls & Kid Lock
Lumi Kids includes a Kid Lock feature that prevents children from leaving the app without a parent PIN. This feature is entirely local to the device. The PIN is never stored in the cloud or transmitted to our servers.
6. Subscriptions & Purchases
Subscriptions and in-app purchases are processed by Apple via the App Store. We do not have access to your payment information. You may manage or cancel your subscription at any time through your Apple ID account settings.
7. Data Retention
Anonymous analytics data is retained for up to 24 months, then deleted. If you create an account, you may request deletion of your account and associated data at any time by emailing privacy@lumi-kids.app. We will process deletion requests within 30 days.
8. Children’s Privacy (COPPA)
We do not knowingly collect personal information from children under 13. All account creation is intended for parents or guardians. If we become aware that personal data has been collected from a child without parental consent, we will delete it promptly. Parents may contact us at privacy@lumi-kids.app to review or delete any data.
9. Your Rights (GDPR — EU/French Users)
If you are located in the European Union, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate data
- Request erasure (‘right to be forgotten’)
- Object to processing
- Data portability
To exercise these rights, contact: privacy@lumi-kids.app. You also have the right to lodge a complaint with your national data protection authority (in France: the CNIL — www.cnil.fr).
10. Security
We use industry-standard security practices including HTTPS for all data in transit and encrypted storage for any data at rest. No method of transmission over the internet is 100% secure; however, we strive to protect your information using commercially reasonable means.
11. Third-Party Services
Apple App Store / StoreKit — In-app purchases & subscriptions
Anonymous Crash Reporting (no PII) — Crash diagnostics
Barcode Database API — ISBN lookup only, no user data retained
No advertising networks, social SDKs, or analytics platforms that profile users are included in this app.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by updating the ‘Last updated’ date at the top of this document and, where appropriate, through an in-app notice. Continued use of the app after changes constitutes acceptance of the updated policy.
13. Contact
For any privacy-related questions or requests:
Email: lumy@uginet.com
Ugitech SAS
