“Children’s Online Privacy Protection Act” (“COPPA”) means the United States law for online protection of Children’s privacy.

“Children/Child” for the purpose of this policy refers to individuals who are under the age of ability to consent to Personal Data processing in their jurisdiction (e.g. < 13 in the USA, Brazil; < 16 in California; < 16 in parts of the EEA, etc). Please refer to your state’s or jurisdiction’s specific privacy/data protection laws to learn more. Generally, we will always regard all users < 13 years of age to fall into this category. Age used for determination of Child/Children users in the Service is based upon Age Gate entry

“Persistent Identifier” also referred to as “device identifiers” are anonymous numeric or alpha-numeric character sequences that uniquely identify a specific device. Alone, and with limited usage, these identifiers can’t be reasonably linked back to a specific individual. In some cases, however, you may see in this policy we regard these as “Personal Information”. This is because in unique circumstances or over time, these identifiers can become personally identifiable and traceable back to you. Examples may be in cases where they’re used to track behavior across third parties services, depending on how they may be shared/stored, and if they’re used to build behavioral profiles for targeted advertising. (e.g. Consider an IP Address that identifies avcomputer (or a group of) on the internet. Alone, this doesn’t identify who that computervbelongs to or is used by, etc. unless possibly combined with additional records fromvsay an Internet Service Provider(i.e. “ISP”) that may link that identifier to some individual.)

Childen Privacy

At Lumos Apps, we make apps that are for all audiences. Our Service is designed for a broad general audience of users. While we do not primarily direct the apps we publish or our website towards Children, we are committed to protecting all users’ privacy. Therefore, we’ve implemented the following features specifically to protect any Children Users, in addition to the rest of our general privacy policy.

While we’ve worked hard and carefully to design the above measures, we still always encourage parents and guardians to discuss safe internet and mobile device use with Child users and to monitor their Children’s safe mobile application use. We ask you to always facilitate any communications with us they need for support, feedback, etc. related to the Service to comply with our communication processes and this policy.

Children Personal’s Information

Collection is limited to Persistent Identifiers – The Service is intentionally designed such that if we collect a Persistent Identifier of a known Child user, it’s never used to communicate with (unless under one-time contact exception per COPPA 16 C.F.R. § 312.5(c)(3)), behaviorally track across third party services, or provide any Personalized Advertising. For Child users all Persistent Identifiers are limited in use and scope to solely Internal Operations (COPPA 16 C.F.R. § 312.5(c)(7)).

Children & Child Online Privacy Protection (e.g. COPPA, GDPR-K)

The apps we publish and website are intended for a general audience, and are not primarily directed to Children. However, we also recognize that in some cases the apps we publish may attract a mixed audience of users and age demographics. We therefore take additional steps to determine ages of users (via age gate) and configure the Service appropriately to protect Children’s privacy when we gain knowledge of a Child user (via age gate). For clarity and emphasis, these steps are detailed at the beginning of this document in the outlined block titled “Children’s Privacy”. Note for protection we do not allow the age gate to be bypassed and a user cannot go back and change their age once entered (the only exception to this is via the completion of parental consent form and signature in the procedure outlined in section 21 for exercising a right of updating/correcting information). Lumos Apps does not knowingly or intentionally collect Personal Information from children under the age of 13 (or the legal age of able to consent to Personal Data processing in their jurisdiction if greater, e.g. 16 in parts of the EEA), unless one or more of the following is met:

  1. The subject falls under COPPA and Personal Information is limited to the use of a Persistent Identifier for purposes of supporting internal operations, and/or
  2. Guardian or parental consent has been given.
  3. The Subject falls under GDPR, LGPD, or similar and the collection/processing falls under the basis of Legitimate Interest