Child Protection Policy
[DRAFT — pending legal review]
Who Lumi Is For
Lumi is an educational voice tutor made for school-age children. Access is always created by an adult: a parent or legal guardian who opens a family account, or a school that contracts the service for its pupils. A child never signs up on their own.
Consent and the Age of the Child
Under Article 8 GDPR, and under Spanish law (LOPDGDD), which sets the age at 14, a child below that age may only use the service with the consent of a parent or legal guardian. Where a school provides access, the school is responsible for obtaining the corresponding authorisation from families: [PENDING DECISION: age-verification mechanism at sign-up].
What the Tutor Will and Will Not Talk About
Lumi is limited to schoolwork. Conversations are classified as they happen, and when a child raises a subject outside that scope — or one that is not appropriate for a minor — the tutor steers the conversation back to the lesson instead of engaging with it. Lumi does not give medical, legal, psychological or financial advice, does not discuss self-harm or sexual content, and does not ask a child for personal information about themselves or their family.
Adult Oversight
Every redirection of that kind is recorded and shown to the adult responsible for the child: the parent in a family account, the school in a school account. Parents and schools can also see session history, time spent and progress. Lumi is built to be supervised, not to replace supervision.
Data About Children
We collect the minimum needed to run a lesson: first name, school year, and the record of the sessions themselves. We do not build advertising profiles of children, we do not sell or share their data with third parties for marketing, and we do not use it to target them with advertising of any kind: [PENDING DECISION: retention period for session transcripts].
Time Limits
Daily usage limits are set by the parent or the school, so time with the tutor stays bounded by an adult's decision rather than the child's.
Reporting a Concern
If you are a parent, a guardian, a teacher or a child and something about a conversation worries you, write to [email protected]. Tell us what happened and roughly when, and we will review the session record: [PENDING DECISION: committed response time].
Rights Over a Child's Data
A parent or guardian may at any time request access to, correction of, or deletion of everything we hold about their child, by writing to [email protected]. The same applies to a school acting on behalf of the families it represents.