Children's Online Privacy Protection Act (COPPA) Policy

Infinite Future, Inc ("Company," "we," "us," or "our") is committed to protecting the privacy of children who use our mobile application, Lumie (the "App"). This Children's Online Privacy Protection Act (COPPA) Policy explains our practices with respect to the online collection, use, and disclosure of personal information from children under the age of 13. This policy is in accordance with the U.S. Children's Online Privacy Protection Act and its rules.

The Lumie App is an AI Reading Tutor designed to create personalized learning experiences for children. This COPPA Policy supplements our general Privacy Policy. For any terms not defined in this COPPA Policy, please refer to our general Privacy Policy.

1. Information We Collect from Children, How We Collect It, and How We Use It

We collect only the personal information from children that is reasonably necessary for them to participate in the activities offered by our App. We obtain verifiable parental consent before collecting, using, or disclosing personal information from a child. The specific types of personal information we may collect from a child include:

A. Direct Collection (with Verifiable Parental Consent):

• Child's First Name: We collect a child's first name to personalize the content created by the App and to personalize the in-app experience (e.g., addressing the child by name).
• Child's Age or Birthdate: We collect a child's age or birthdate to ensure the content is appropriate for their developmental stage and reading level. This also helps in personalizing the learning journey.

B. Automatic Collection (with Verifiable Parental Consent as part of App usage):

• Child's Interests for Personalization: We may collect information about your child's interests, either through direct input (e.g., selecting preferred genres or themes, with your guidance) or by inferring them from the types of content they engage with or the prompts they use. This helps us tailor recommendations and ensure the content remains engaging and appropriate for your child.
• Child's Prompts : When a child uses the App to request or generate content, we collect the specific prompts, topics, or instructions they provide. This information is directly used to create the personalized content for your child.
• Reading Metrics: As a child uses the App, we automatically collect information about their reading activities. This includes data such as reading progress, words learned, time spent consuming specific content, assesments completed, and areas where the child may be experiencing difficulty. This information is essential for the App to generate new, personalized bocontentoks, track progress for both the parent and child, and to continuously improve the educational effectiveness and adaptivity of the App. These metrics are sent to our secure servers.
• Usage Data: We collect information about how your child interacts with the App, such as features used and session duration, to improve the App's functionality and user experience.
• Device Information: We may collect device type, operating system, and IP address to ensure the App functions correctly on various devices and for security purposes.

C. How We Use Children's Information:

• To personalize the learning experience, including generating and adapting content.
• To track reading progress and provide feedback to the child and parent.
• To improve the features, functionality, and educational value of the Lumie App.
• To ensure the security and integrity of our Services.

We do not require a child to disclose more information than is reasonably necessary to participate in an activity. Children cannot make their personal information publicly available through our App (e.g., there are no public chat rooms or profiles visible to other users outside their family account, if applicable).

D. Information Storage:

• On Your Device: Your child's first name, age/birthdate, and the content created for them are primarily stored on your device.
• On Our Servers: To provide personalized recommendations and improve our Services, your child's first name (or a de-identified identifier), age/birthdate, and their reading metrics are securely transmitted to and stored on our servers.

2. Verifiable Parental Consent

We provide direct notice to parents and obtain verifiable parental consent before collecting, using, or disclosing personal information from children. When a parent or guardian creates an account for a child to use Lumie, we will request consent for the collection of the child's first name, age/birthdate, and the subsequent collection of reading metrics and usage data as described above.

The method for obtaining verifiable parental consent may include [Note to User: You will need to specify your chosen COPPA-compliant consent method here. Examples include: providing a consent form to be signed and returned, requiring a credit card transaction, or other methods approved under COPPA. For now, this is a placeholder.] an email to the parent with a request for confirmation, followed by a clear mechanism within the parent's account settings to manage consent.

Parents can revoke their consent at any time by contacting us as described in the "Parental Rights" section below.

3. Parental Rights

As a parent or guardian, you have the following rights regarding your child's personal information:

• Right to Review: You can request to review the personal information we have collected from your child.
• Right to Delete: You can request that we delete the personal information collected from your child from our records.
• Right to Refuse Further Collection or Use: You can refuse to permit us to further collect or use your child's personal information.
• Right to Revoke Consent: You can revoke your prior consent at any time.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request in a reasonable timeframe. Please note that a request to delete personal information or to refuse further collection or use may limit your child's ability to use some or all features of the Lumie App. Exercising these rights will not result in any penalty to you or your child, beyond the potential inability to use certain services that require such information.

4. Disclosure of Children's Information to Third Parties

We do not sell children's personal information, and we do not share it with third parties for their marketing or advertising purposes.

We may share a child's personal information in the following limited circumstances:

• Service Providers: We may share information with our trusted third-party service providers who need access to such information to perform services for us (e.g., cloud server hosting, database management, customer support related to the App). These service providers are contractually required to maintain the confidentiality, security, and integrity of the children's personal information they process and are prohibited from using it for any purpose other than providing services to us.
• Legal Requirements and Safety: We may disclose children's personal information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of the App or the public, or (d) protect against legal liability.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, children's personal information may be transferred as part of the transaction. We will provide notice to parents before children's personal information is transferred and becomes subject to a different privacy policy.

5. Data Security and Confidentiality

We have implemented reasonable administrative, technical, and physical security measures to protect the confidentiality, security, and integrity of children's personal information. These measures are designed to prevent unauthorized access, use, disclosure, alteration, or destruction of information. Such measures include data encryption, access controls, and secure server environments. We restrict access to children's personal information to those employees and service providers who need to know that information to operate, develop, or improve our Services and who are bound by confidentiality obligations.

6. Data Retention for Children's Data

We retain personal information collected from a child for only as long as is reasonably necessary to fulfill the purpose for which it was collected (e.g., to provide the personalized reading services within the App) or as required by law. If a parent revokes consent or requests deletion of their child's information, we will delete the information from our active databases in accordance with our standard procedures and applicable law, unless we have a legal obligation or legitimate interest to retain it (e.g., for security or legal compliance, using anonymized data for service improvement).

7. Changes to this COPPA Policy

We may amend this COPPA Policy from time to time. If we make any material changes we will also update the "Last Updated" date at the top of this policy.

8. Contact Information for COPPA Inquiries

If you have any questions, concerns, or comments about this COPPA Policy, our data practices concerning children, or if you wish to exercise your parental rights, please contact us at: