Moment Lumina - Stories of Your Child's Day for Parents

Privacy Policy_Moment Lumina Privacy Policy for Moment Lumina Service Effective Date: June 1, 2026

Moment Lumina Service(“Moment Lumina,” “we,” “our,” or “us”) is committed to safeguarding your right to privacy. This Privacy Policy outlines our practices regarding collection, use, storage, transferring, and sharing of information through our services, including our website, mobile applications (including the Parents App and the Kids App), and any other products or services we offer (collectively, the “Services”). By visiting, accessing, or using our Services, you agree that your information, including your personal information, will be handled as described in this Privacy Policy, which is incorporated by reference into our Terms of Service. All references to “you” and “your” in this Privacy Policy refer to the user accepting this Privacy Policy.

1. Type of Data We Collect as You Use Our Service

1.1. Data You Create or Provide to Us We may collect personal data that you provide directly to us when you sign up for an account or interact with our Services. This may include:

Identifiers and Similar Information: Your name, email address, phone number, mailing address, gender, and other identifying information.
Account Information: Your username, password, and any information related to your account in the Parents App or Kids App.
Inquiries and Feedback: If you contact us, we may collect the content you provide, such as your name, email address, and information contained in your inquiry.

1.2. Data We Collect as You Use Our Services Our core Services involve measuring, collecting, and analyzing data extracted from spontaneous interactions with digital devices using digital phenotyping technology (“Digital Phenotyping Data”). Digital Phenotyping Data we collect may include:

Interaction patterns with digital devices (typing speed, application usage, browsing habits).
Data captured from device sensors, such as motion patterns, device orientation, screen interactions, and facial expression data (if applicable).
Information inferred from your interactions with technology, such as mood, stress levels, concentration level, emotions, and other mental wellness indicators.
User’s mental wellness states such as impulsion, anxiety, depression, compulsive behaviors, study habits or attitudes, and self-report data.

We also automatically collect certain data about how users access and use our Services. This may include:

Device Information: Mobile carrier, device type/model, operating system, device settings, and (depending on device settings) geographical location data such as country codes, approximate location, or precise geolocation (classified as Sensitive Personal Information (SPI) under CPRA when applicable).
Log Data: Web request information, IP address, browser type, unique device identifiers, referring/exit pages and URLs, number of clicks, interactions with Service UI elements, domain names, landing pages, video usage events, comments, likes, and other behavioral logs.
Usage Details: Access times, pages viewed, session duration, order of page views, and other usage details.
Analytics Data: Information collected through cookies, web beacons, SDKs, pixels, similar tracking technologies, and mobile advertising identifiers (AAID/IDFA). We do not currently use advertising cookies for third-party targeted advertising.

2. How We Use Your Information

We use the data we collect for various purposes, including:

2.1. To Provide and Improve Our Services

To personalize and enhance your experience with the Parents App and Kids App.
To analyze and monitor usage trends and activities to improve the quality, performance, and functionality of our Services.
To develop new features, products, and services.

2.2. To Communicate with You

To send technical notices, updates, security alerts, verification messages (including parental consent verification under COPPA), and support-related messages.
To respond to your comments, questions, and customer support requests.

2.3. To Conduct Research and Analysis

To conduct research and analysis to better understand how our Services are used and how to improve them.
To aggregate or anonymize data for statistical or research purposes, ensuring your personal data is not identifiable.
Under COPPA: For users under 13, we collect, use, and retain personal information only as permitted by verifiable parental consent and applicable U.S. child protection regulations.

2.4. To Comply with Legal Obligations

To comply with applicable laws, regulations, and legal processes.
To enforce our Terms of Service, protect our rights, and address safety, fraud, and security issues.
Additional U.S. Obligations: Includes compliance with CCPA/CPRA (California), COPPA (Children under 13), state privacy laws, and honoring Global Privacy Control (GPC) signals.

We do not sell personal information. We do not use personal information to target advertisements or market to users or anyone else for any purposes prohibited by applicable laws and regulations. We will not use personal data for any purpose other than specifically set forth in this Privacy Policy or any other agreement between 3R Innovation and its users.

We may share your personal data in the following circumstances:

3.1. Consent We may disclose information to third parties with your consent or when you direct us to do so. This includes verifiable parental consent for children under 13 (COPPA requirement).

3.2. Service Providers We may share your data with third-party vendors, consultants, contractors, or agents who process data on our behalf (“Service Providers”). These parties assist with tasks such as:

Service administration
Data processing
Analytics
Hosting
Communication delivery
Customer service

We do not share personal data with unaffiliated third parties for their own marketing purposes.

3.3. Business Transfers If Moment Lumina experiences a corporate transaction such as a merger, acquisition, asset sale, or bankruptcy, we may transfer collected information as part of the transaction.

3.4. Legal Compliance We may disclose information to comply with:

Laws
Court orders
Subpoenas
Government and regulatory requests

3.5. To Protect Ourselves and Others We may disclose information where necessary to investigate, prevent, or act regarding:

Illegal activities
Fraud
Threats to safety
Violations of our Terms or this Privacy Policy

3.6. Aggregated and Anonymized Data We may share aggregated, de-identified, or anonymized data that does not identify you, for any lawful purpose including research and product improvement.

3.7. To 3R Innovation Companies (Service : Moment Lumina) We may disclose information to our affiliates, parent entities, subsidiaries, or other related companies (“3R Innovation Companies”) where relevant to this Privacy Policy.

4. Data Security

While we are committed to safeguarding your personal data and employ industry-standard security measures to protect it, please be aware that no method of data transmission over the internet or electronic storage is 100% secure. As a result, we cannot guarantee the absolute security of your data. By using our Services, you acknowledge and accept this risk. You should take steps to protect against unauthorized access to your password, computer, mobile device, or web-enabled device, including but not limited to:

Signing off after using a shared computer
Setting strong passwords on your mobile devices
Keeping your password private
Not sharing your login information with others We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Additional U.S. Requirements:

If a data breach occurs affecting personal information, Moment Lumina will notify affected individuals in accordance with applicable state data breach notification laws, including but not limited to California Civil Code §1798.82.
For users under 13, additional breach notice obligations under COPPA may apply, and Moment Lumina will notify the parent or legal guardian as required.

5. Additional Information for California Residents and Other U.S. States Residents

California law requires us to provide you with additional information applicable to California residents and, where similar requirements exist, to other U.S. states residents.

5.1. Categories of Personal Information We Collect We collect the following categories of personal information:

Identifiers: such as name, email address, account credentials, and parent/guardian contact information (for parental consent)
Internet or other network activity information: how users interact with our Services, including Parents App and Kids App usage logs
Geolocation data: approximate or precise location depending on device settings (classified as Sensitive Personal Information (SPI) under certain U.S. laws)
Inferences: information derived from digital phenotyping, such as mental wellness indicators, focus level, or mood (SPI—Sensitive Personal Information—when applicable)
Other information that identifies or can reasonably be associated with you, such as your correspondence with us.

5.2. Purposes for Using Such Personal Information We use such personal information to:

Provide and improve our Services
Communicate with you, such as sending service notices
Conduct research and analysis, including digital phenotyping and mental wellness analytics Comply with legal obligations, including COPPA, CCPA/CPRA, and other applicable state privacy laws.

5.3. Retention of Personal Information We retain personal information as long as necessary to fulfill the purposes for which we collected it, unless:

longer retention is required by law,
or permitted by law due to operational, analytical, or compliance needs. We consider:
the nature and sensitivity of the data,
the purpose of processing,
regulatory or legal restrictions,
Moment Lumina’s legitimate interests in determining retention periods.

5.4. Privacy Rights in California and Certain Other U.S. States Under certain U.S. state laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), residents may have the right to:

Access: the categories and specific pieces of personal data collected
Know: the sources, purposes, and categories of third parties receiving their personal data
Delete: personal data under certain circumstances
Correct: inaccuracies in their personal data
Opt-out of “sale” or “sharing” of personal information (Moment Lumina does not sell personal data in the conventional sense)
Opt-out of targeted advertising and certain types of automated profiling
Appeal: if a privacy request is denied

COPPA Note: Moment Lumina does not knowingly “sell” or “share” the personal information of users under 16, and will never “sell” or “share” data of users under 13.

5.5. Sensitive Personal Information (SPI) Moment Lumina may receive or process personal data considered Sensitive Personal Information under certain state laws if you choose to enable certain features and provide necessary consent.

This includes:

precise geolocation
biometric-like indicators from digital phenotyping
wellness indicators inferred from behavior
account credentials and parental verification information

We process SPI only for:

Service provision
Authentication
Security and safety
Research and development
Legal compliance

We do not use SPI to infer characteristics for marketing or profiling beyond what is reasonably necessary for our Services. Where applicable, residents may have the right to limit the use of their SPI (CPRA §1798.121).

5.6. Non-Discrimination Moment Lumina will not discriminate against you for exercising any privacy rights.

5.7. Verification These rights are not absolute, are subject to exceptions, and may not be available to residents of all states. To verify your identity, we may request:

Confirmation by logging into your existing Moment Lumina account (Parent or Child)
A declaration under penalty of perjury
At least two data points we already hold (e.g., email and device info) You may designate an authorized agent by providing written permission and verification of identity.

6. European Data Protection Specific Information

6.1. General We process your information in a lawful, transparent, and fair manner.

6.2. Rights of EEA, Switzerland, or UK Users If you are located in the EEA, Switzerland, or the UK, you have rights under the GDPR/UK GDPR, including:

Right of access and/or portability
Right of erasure
Right to object to processing
Right to rectification
Right to restrict processing

We will respond within the legally required timeframe.

You may be asked to verify your identity before we process such requests.

6.3. International Data Transfer Moment Lumina operates globally. Therefore, personal data may be transferred, stored, and processed outside your country or region. Such transfers may include the United States or other jurisdictions where privacy laws may be less protective. We protect your information through:

Contractual safeguards
Technical safeguards
Standard Contractual Clauses (for EEA/UK transfers)

7. HIPAA Compliance

If your information includes Protected Health Information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA), you may have certain rights. However: Moment Lumina does not collect or process PHI. Moment Lumina is not a covered entity or business associate as defined under HIPAA.

Therefore, HIPAA generally does not apply to the data practices of our Services.

8. How We Store and Protect Your Personal Data

We take commercially reasonable measures to protect the personal data that we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include administrative, technical, and physical safeguards designed to protect your personal data. However, please be aware that no method of transmitting information over the internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We retain your data only for as long as necessary to satisfy the purposes for which your data was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. When your information is no longer required, we will take reasonable steps to destroy, erase, or de-identify it.

Additional U.S. Requirements:

Under CPRA and other state privacy laws, we retain data only for as long as reasonably necessary and proportionate to the disclosed purposes.
Data retention for children under 13 follows COPPA’s “no longer than reasonably necessary” principle.
For precise geolocation data (SPI), retention is minimized according to legal and operational necessity.

9. Third-Party Websites

Our Services may contain links to third-party websites. When you click on such links, you may be transferred to websites that are not under our control. This Privacy Policy does not apply to the privacy practices of those websites. We encourage you to read the privacy policies of those websites to understand how they collect, use, and share your information. Moment Lumina is not responsible for, and does not control, the content, privacy practices, or security of any third-party websites. Your interactions with such websites are governed solely by the policies of the third parties operating those websites.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons, pixels, SDKs, or analytics identifiers) to automatically collect information as you use our Services. Some cookies are set by us, while others may be set by third parties that perform services on our behalf, such as analytics or operational support.

10.1. What Data Do We Collect with Cookies? We use Cookies in the Services that automatically collect information to:

Understand usage of the Services and improve them
Authenticate your account (Parents App or Kids App)
Remember your preferences and account settings
Provide security protections and maintain service integrity We do not use advertising cookies for targeted third-party advertising.

Mobile devices may also transmit:

AAID (Android Advertising ID)
IDFA (Apple Advertising Identifier)

These identifiers are used strictly for analytics or service functionality and not for cross-context behavioral advertising.

10.2. Your Choices About Cookies You may learn more about how cookies work and how to disable them through your browser settings. Please note:

If you replace, change, or upgrade your browser, or delete cookies, you may need to re-adjust your cookie preferences.
Disabling cookies may affect certain functionalities of our Services.

10.3. Do Not Track (DNT) and Global Privacy Control (GPC) Do Not Track (DNT): Some browsers allow users to send DNT signals. At this time, our Services do not respond to DNT signals, because our systems do not track users across third-party websites.

Global Privacy Control (GPC): Moment Lumina does honor GPC signals as a valid request to opt-out of:

“Sale” of personal information
“Sharing” of personal information
Cross-context behavioral advertising (as required under CPRA §1798.135) This applies to both parents and children’s accounts within the Services.

11. Accessing and Modifying Your Personal Information

If you submitted personal information to us while using the Services, you may modify certain personal information—such as your profile name, phone number, or profile picture—by logging into your account in the Parents App. For personal information not modifiable through your account, including your email address, you may contact us via the email provided at the bottom of this Privacy Policy. We will try to comply with your request as soon as reasonably practicable.

We may decline requests where:

We believe the change would violate any law or legal requirement
We believe the change would cause inaccuracies
The request is overly burdensome
Verification fails
Certain data must be retained to comply with legal obligations (e.g., COPPA parental consent logs)

Please note that copies of information that you have updated, modified, or deleted may continue to reside on our systems for a period of time for backup, archival, or auditing purposes.

12. Changes to This Privacy Policy

Moment Lumina may amend this Privacy Policy from time to time. The use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will provide notice of such changes through:

A posting on the Service site
In-app notifications within the Parents App or Kids App
Or through any other reasonable means of communication.

You are bound by any changes to the Privacy Policy when you use the Services after such notice has been provided. Therefore, we encourage you to check the effective date of this Policy whenever you access or use the Services to determine whether the Policy has been updated. You must review this Privacy Policy on a regular basis to keep yourself informed of any changes. If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop using the Services. Your continued use of the Services following the posting or communication of any modifications will constitute your acceptance of the revised Privacy Policy.

Additional U.S. Requirements: For material changes affecting children under 13, Moment Lumina will comply with COPPA parental notice obligations and, when required, may obtain renewed verifiable parental consent before continuing to process the child’s personal information. No employee or agent of Moment Lumina has the authority to alter any of the terms within this Privacy Policy.

We cannot control the actions of other users with whom you share your information. We cannot, and do not, control:

The information you choose to share with other users within the Services,
How such users may use or further disclose such information,
Or any consequences of sharing information through interactive features.

If you share information with other users by using the Services (e.g., in comments, chats, emotion-sharing features, message boards, or any feature available in the Parents App or Kids App), you acknowledge that such information may become accessible to those users. Moment Lumina is not liable for how other users may use, store, copy, distribute, or disclose any information that you voluntarily provide. We encourage you to exercise caution when deciding to share personal or sensitive information with others on or through the Services.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact us at:

Moment Lumina Address: [Insert U.S. Address] Email: moment-care@momentlumina.com

For privacy rights under CCPA/CPRA or other state privacy laws, you may also reach us at the email provided above or through our dedicated privacy request form (if available). Parents seeking to review, delete, or revoke consent for a child’s information under COPPA may contact us through the same channels.

15. Additional Important Information

Depending on your jurisdiction, additional privacy rights or requirements may apply. These may include:

Rights under state privacy laws (e.g., Virginia, Colorado, Connecticut, Utah)
Rights under federal regulations

Moment Lumina may include or be integrated with platforms, services, or products that are subject to additional privacy terms. Where applicable, you will be notified separately.

If any provision of this Privacy Policy is found unenforceable, the remainder of the Policy will continue in full force.

This Privacy Policy, together with our Terms of Service, constitutes the entire understanding between you and Moment Lumina regarding data practices.

Attachments / Exhibits

Attachment A. Notice at Collection Table (CPRA §1798.100)
Attachment B. Data Retention Schedule
Attachment C. COPPA Direct Notice (Parent Notice for Children Under 13)

Attachment A_Notice at Collection Table Attachment A — Notice at Collection Table (Moment Lumina) Required under CPRA §1798.100 / Cal. Civ. Code §1798.130(a)(5) Applies to both Parents App and Kids App unless otherwise specified.

Notice at Collection: Categories of Personal Information Category of Personal Information Description / Examples Purpose of Collection Source Shared With Sold / Shared for Targeted Advertising? Sensitive Personal Information (SPI)? Retention Period

1. Identifiers

Name, email address, phone number, account ID, password, Parent account verification info Account creation, login, parental verification, communication User (Parent/Kid), device input Service Providers (account services, authentication) No If parental verification info includes government ID → Yes (SPI) Until account deletion + 2 years

2. Child Identifiers (COPPA)

Child nickname, age range, parental consent record Compliance with COPPA, linking Parent–Child accounts Parent (via Parents App) Service Providers (parental consent management) Never sold or shared Yes (child data is treated as SPI) As required by COPPA; deleted upon parental request

3. Contact Information

Parent email, phone number Notifications, customer support, legal notices Parent User Communication vendors No No Until account deletion

4. Digital Phenotyping Data

Typing speed, scroll patterns, interaction patterns, behavioral signals Mental wellness insights, behavioral analytics, feature improvement, research Device interactions, SDKs Service Providers (analytics processors) No Potentially SPI (when used to infer wellness state) 12 months (aggregated thereafter)

5. Sensor & Device Interaction Data

Motion data, accelerometer/gyroscope, screen interactions, facial expression metadata (if enabled) Feature functionality, behavioral analytics Device sensors Service Providers (data processors) No Yes, if inferring emotional/well-being indicators 12 months (minimum necessary)

6. Inferences / Mental Wellness Indicators

Mood inference, stress level, focus score, cognitive patterns Provide personalized insights to users (Kids App & Parents App), trend analysis Derived internally from analytics Service Providers (statistical processing) No Yes (SPI) under CPRA Retained in de-identified form; raw data retained 12 months

7. Internet / Network Activity

IP address, device IDs, session logs, error logs Service operation, fraud prevention, debugging, security Automatic (device/app) Service Providers (security, debugging) No No 12–24 months

8. Geolocation Data

Approximate location; precise location (only if user enables) Safety, fraud prevention, regional content/service availability Device OS settings Service Providers (location services) No Precise location = SPI Approximate: 12 months; Precise: only as needed, then deleted

9. App Activity / Usage Information

Page views, session duration, feature usage, navigation patterns Service improvement, personalization Automatic via SDK Analytics Service Providers No No 12 months

10. Communications

Emails, customer support chats, inquiry content Customer service, compliance documentation Parent User Service Providers (customer support platforms) No No 24 months

11. Children’s Content or Inputs

Text inputs, quiz results, emotion stickers, check-ins Providing insights to parents, generating feedback to child Child User via Kids App Service Providers (data analysis only) Never sold; not shared for ads Yes (child data treated as SPI) Until parental deletion request

12. Precise Wellness Inferences

High-level mental state grouping (e.g., “stress elevated,” “focus low”) Displaying insights to parents; generating self-feedback to kids Derived data Internal; limited Service Providers No Yes (SPI) Short-term storage; anonymized thereafter

13. Sensitive Account Metadata

Parent–Child linking data, parental consent timestamps COPPA compliance, parental control features Parent User Consent management vendors No Yes (SPI) COPPA-required retention only

14. Payment / Transaction Information (if in-app purchases exist)

Purchase history, receipt ID, platform transaction data Subscription/payment management App Store / Google Play Payment processors No No Financial record requirements: up to 7 years

Attachment B – Data Retention Schedule Attachment B — Data Retention Schedule Required under CPRA §1798.100(a)(3) & CPRA Regulations §7002 Applies to both Parents App and Kids App unless specified otherwise.

Data Retention Schedule (Category-Based Retention Periods) Moment Lumina retains personal information only for as long as is reasonably necessary and proportionate to provide the Services, meet operational requirements, and comply with legal obligations. After the applicable retention period, information is deleted or irreversibly de-identified.

1. Identifiers (Parent & Child)

Category Examples Retention Period Deletion / De-Identification Criteria Parent Identifiers Email, phone number, username, account ID Until account deletion + 2 years Retained for legal defense; permanently deleted thereafter Child Identifiers Child nickname, child account ID, parent–child link ID COPPA: deleted upon parental request; otherwise 12 months Automatically deleted if child account remains inactive for 12 months Password Hash Encrypted authentication data Until account deletion Immediately deleted

Category Examples Retention Period Notes Verifiable Parental Consent (VPC) Consent timestamp, parent email, verification metadata 3 years after consent revocation or child account deletion Required under COPPA recordkeeping provisions

3. Digital Phenotyping Data

Category Examples Retention Period Notes Raw interaction data Typing speed, scroll/touch behavior Up to 12 months Deleted after processed into aggregated data Sensor-derived signals Accelerometer/gyroscope, motion data 6–12 months Some device-level signals deleted after each session Derived metrics Stress level, focus score, cognitive patterns 12 months, then de-identified De-identified data may be retained for research

4. Behavioral & Usage Data

Category Examples Retention Period Notes Session logs Access time, navigation sequences 12 months Used for service improvement Error logs Crash data, app performance errors 90 days Deleted once resolved Analytics A/B testing, feature metrics 12–18 months May be de-identified for long-term analysis

5. Device & Technical Data

Category Examples Retention Period Device information Device ID, OS version, device model 12 months IP address logs Security and fraud prevention 30–180 days Push tokens Notification delivery Stored until device re-registration

6. Geolocation Data

Category Examples Retention Period SPI Status Approximate location Region, country 6–12 months Not SPI Precise location (if enabled) GPS-level location Stored temporarily during session; then deleted SPI under CPRA

7. User-Generated Content (Kids App Included)

Category Examples Retention Period Emotion check-ins Mood entries, emotional selections 12 months Wellness notes Children’s short reflections or activity logs 12 months Rewards/Points activities Points balance, earning history Until account deletion

8. Communication Records

Category Examples Retention Period Customer support messages Email, support chat transcripts 24 months Parental consent communications COPPA notice emails, confirmation messages 3 years

9. Payment & Transaction Data

Category Examples Retention Period Basis Subscription purchase records Platform receipts, transaction IDs Up to 7 years Required by U.S. financial and tax laws Refund/chargeback history Dispute logs Up to 7 years Compliance and audit requirements

10. Sensitive Wellness Inference Data (SPI)

Category Examples Retention Period Notes Emotional/behavioral indicators “Stress elevated,” “Low focus” 6–12 months, then aggregated Classified as SPI under CPRA Internal model outputs Non-medical risk indicators 12 months Must be de-identified for model training

11. Security, Fraud & Abuse Prevention Data

Category Examples Retention Period Security logs Suspicious IP access, device anomalies 90 days–12 months Authentication logs Login attempts, timestamps 12 months Abuse-prevention metadata Rate-limiting flags, misuse indicators 12 months

Attachment C – COPPA Direct Notice Attachment C — COPPA Direct Notice (Parent Notice for Children Under 13) Combined Legal + Parent-Friendly Format Required under COPPA (Children’s Online Privacy Protection Act), 16 CFR §312.4

COPPA DIRECT NOTICE To Parents and Legal Guardians of Children Under 13 This Direct Notice explains how Moment Lumina collects, uses, discloses, and protects personal information from your child who uses the Kids App, as required by the Children’s Online Privacy Protection Act (COPPA). You are receiving this notice because your child is requesting to use Moment Lumina’s digital wellness and behavioral insight services, which require the collection of certain data from your child’s device. Your verifiable parental consent is required before we collect any personal information from your child.

1. Who is Collecting Information from Your Child?

The operator collecting information is: Moment Lumina Email: [Insert Contact Email] Address: [Insert Address] All references to “we,” “our,” and “us” in this Notice refer to Moment Lumina.

2. What Information Do We Collect From Your Child?

Moment Lumina collects only the information reasonably necessary for your child to use our Kids App and receive digital wellness feedback. We may collect the following categories of information: (A) Child Identifiers

Child nickname
Child account identifier linked to the parent account
Age range (not precise birthday)

(B) Digital Phenotyping & Behavioral Data (Core Service Functionality) Collected automatically through the child’s device:

Typing speed
Scroll/touch patterns
Interaction behavior
App usage patterns
Focus/attention patterns inferred from behavior
Emotion-related interaction metadata
Motion data from device sensors (accelerometer/gyroscope)

Device model, OS version
IP address (used for security)
Session logs
Crash reports

(D) Inferences

Stress indicators
Focus level
Emotional patterns
Activity trends These are not used for targeted advertising.

(E) Content the Child Provides (e.g., when Kids App includes check-ins, emojis, self-rating)

Emotion check-ins
Short answers or reflections
Feature usage responses

We do not collect the following:

Child’s precise birthday
Home address
Phone number
Photos/videos from the camera without explicit opt-in
Voice recordings
Contacts
SMS/MMS Microphone/audio data unless explicitly enabled

3. How Do We Use the Information?

We use the information collected from your child to:

Provide core Kids App functionality
Generate supportive wellness insights for the child
Provide summarized insights to you (the parent)
Maintain and improve the service
Detect, prevent, or respond to security issues
Comply with legal requirements, including COPPA

We do not use your child’s information to:

Serve behavioral advertising
Create marketing profiles
Sell or share your child’s personal information

4. Do We Disclose Your Child’s Information to Others?

We may disclose your child’s information only in the following situations: (A) To Service Providers Vendors who support:

Data analytics
Hosting
Customer support
App functionality

These vendors may only use the data on our behalf for service-related functions. (B) To Parents/Legal Guardians

You may receive summaries or insights of your child’s activity.

Law
Subpoena
Court order
Safety and security purposes

(D) Business Transfers If Moment Lumina becomes part of a merger or acquisition, you will be notified. ❗ We Never “Sell” Personal Information Moment Lumina does not sell or share children’s personal information with advertisers or data brokers.

5. Your Rights as a Parent

Under COPPA, you have the right to: ✔ Review You may review the personal information we have collected from your child. ✔ Revoke Consent At any time, you may withdraw your consent and prevent further collection or use of your child’s data. ✔ Delete You may request deletion of your child’s information. ✔ Refuse Further Collection If you refuse or withdraw consent, your child’s account will be limited or disabled. ✔ Request Explanation You may request details about how your child’s data is used. To exercise these rights, contact us at: Email: [Insert Contact Email] Subject: “COPPA Request – Parent Review/Deletion/Consent Withdrawal”

To comply with COPPA, we require Verifiable Parental Consent (VPC). We use one or more of the following methods:

Email Plus Verification: Parent receives an email containing a verification link or confirmation code.
Password or Code Provided to Parent: A unique parent authorization code is sent to verify identity.
Parent Account Setup (In-App): Creating a Parent account and linking the child account acts as a consent mechanism.

Once verified, your child can begin using the Kids App.

You may withdraw consent at any time by:

Deleting your child’s account through the Parent App or
Emailing us at [Insert Email] with the subject line “COPPA Consent Withdrawal”

Upon receiving your request:

We will stop collecting any personal information from your child
We will delete your child’s existing information (unless legally required to retain logs for security or COPPA compliance)
The child’s Kids App access will be disabled

8. Data Retention for Children’s Data

Moment Lumina retains children’s information only for as long as reasonably necessary to:

Provide the service
Ensure security
Comply with COPPA-recordkeeping requirements

After this period, the data is either:

Deleted
Or permanently de-identified

For detailed retention periods, see Attachment B — Data Retention Schedule.

9. Contact Information

If you have questions about this notice or wish to exercise any COPPA rights, please contact: Moment Lumina Email: [Insert Parental Support Email] Address: [Insert Address]