Children's Privacy Policy (COPPA)

This policy explains how we protect children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA).

Last Updated: March 19, 2025

1. Overview

Lumina Learn provides educational services to students of all ages, including children under 13. We are committed to protecting children's privacy and complying with COPPA requirements.

2. Parental Consent Requirement

Before collecting any personal information from a child under 13, we require verifiable parental consent.

2.1 Consent Methods

We obtain parental consent through:

  • Email verification with follow-up confirmation
  • Credit card verification (small charge, refunded)
  • Government ID verification
  • Signed consent form (mail/fax/scan)
  • Video call verification (upon request)

2.2 Parent Account Requirement

Children under 13 must have accounts created and managed by a parent or legal guardian.

3. Information We Collect from Children

We collect only information necessary for educational purposes:

Information We Collect

  • First name (last name optional)
  • Username (created by parent)
  • Grade level
  • Learning progress and scores
  • Homework submissions
  • Voice recordings (read-aloud, with consent)

Information We DO NOT Collect

  • Full address
  • Phone number
  • Social Security number
  • Photos (unless with consent)
  • Geolocation data
  • Social media accounts

4. How We Use Children's Information

We DO Use It For:

  • Providing educational services
  • Tracking learning progress
  • Personalizing learning content
  • Generating progress reports for parents
  • Improving our educational content

We DO NOT Use It For:

  • Behavioral advertising
  • Creating marketing profiles
  • Selling to third parties
  • Any non-educational purpose

5. Information Sharing

We share children's information only with:

5.1 Parents/Guardians

  • Full access to all child's data
  • Progress reports and activity logs

5.2 Teachers (with parental consent)

  • Information necessary for tutoring sessions
  • Teachers are bound by confidentiality agreements

5.3 Service Providers

  • Only providers necessary for Service operation
  • All providers are COPPA-compliant
  • Contractual protections in place

We NEVER share children's information with:

  • Advertisers
  • Data brokers
  • Marketing companies
  • Any third party for non-educational purposes

6. Parental Rights

Parents/guardians have the right to:

Review Information

  • View all personal information collected
  • Request copies of data in portable format

Modify Information

  • Update or correct your child's information
  • Change privacy settings

Delete Information

  • Request deletion of personal information
  • Delete your child's account entirely

Revoke Consent

  • Withdraw consent for future collection
  • Opt-out of specific features

To exercise these rights:
Email: coppa@lumina-learn.com
We will respond within 30 days.

7. Data Retention for Children

  • Active account data: Retained while account is active
  • After account deletion: Data deleted within 30 days
  • Educational records: May be retained up to 7 years for transcript purposes (with ongoing consent)
  • Inactive accounts: Automatically deleted after 18 months of inactivity

8. Security Measures for Children's Data

We implement enhanced security for children's data:

  • Encryption in transit and at rest
  • Access limited to essential personnel
  • Regular security audits
  • Separate data storage considerations
  • No data on public-facing systems

9. Third-Party Services

Third parties that may process children's data:

  • MongoDB Atlas (database hosting) - COPPA compliant
  • AWS (cloud infrastructure) - COPPA compliant
  • Stripe (payment processing) - Does not receive child data

All third parties are contractually bound to use data only for Service provision, maintain appropriate security, delete data upon request, and comply with COPPA.

10. Contact for COPPA Inquiries

Lumina Educational Services, LLC
Email: coppa@lumina-learn.com

Federal Trade Commission (FTC) COPPA Information:
https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy

By creating an account for your child, you confirm that you are the parent or legal guardian and consent to this Children's Privacy Policy.

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