Lumino Connect — App Privacy Policy

1. Introduction

This Privacy Policy explains how EARLY SCHOLARS NURSERY (S.P.S - L.L.C) ("we", "us", "our") handles personal information in connection with the Lumino Connect mobile application ("the App") and related services.

By using the App, you agree to the practices described in this Policy.

2. Operator

EARLY SCHOLARS NURSERY (S.P.S - L.L.C)
Almouhat 1, Ajman
United Arab Emirates
Contact: info@lu-mino.com

3. How accounts are created

Lumino Connect accounts are created by your organization's administrator (such as a school, training center, clinic, or workplace). The App does not offer public self-registration.

If you believe you have an account but did not authorize its creation, contact info@lu-mino.com and we will investigate and remove it if appropriate.

4. Information we collect

(a) Account information

• Email address
• Password (stored only as a one-way cryptographic hash)
• Full name and display name
• Role assigned by your organization
• Organization or tenant identifier

(b) Session information

• Live sessions you join and the time you joined
• Your participant identity within each session
• Technical signalling data needed to keep the call connected
• If the session host enables recording on the Lumino platform, the recording is stored on Lumino infrastructure and is accessible only to your organization's authorized administrators and the session host

(c) Device information (minimal)

• App version
• Operating system type and version
• General device model

(d) Camera and microphone data

• Accessed only during active live sessions
• Transmitted in real time between participants
• The mobile App does not record camera or microphone data on the device
• If the session host enables recording, you will be notified visually inside the session before recording starts
• You may decline to participate if a session is being recorded
• Camera and microphone access ends immediately when you leave the session

5. Information we do not collect

• Your location
• Your contacts
• Your photos, files, or messages from other apps
• Advertising identifiers
• Behavioral profiles for advertising
• Cross-app or cross-website tracking data

6. How we use information

• To create and operate your account
• To connect you to live sessions hosted by your organization
• To provide technical support when you contact us
• To protect against fraud, abuse, and security threats
• To comply with legal obligations

7. How we share information

We do not sell your information. We do not share your information for advertising.

We share information only with:

• LiveKit, the real-time video and audio service used to carry live session media, bound by contract to handle this data solely to operate the call
• Cloud infrastructure providers that securely host our services
• Your organization's administrators, who can see account and session activity within their organization
• Legal authorities, only when required by valid legal process

8. Children and education use

Lumino Connect is intended for individuals 18 years or older, OR for minors under the supervision and consent of a parent, legal guardian, school, or qualifying organization.

If you are under 18, you must have permission from a parent, guardian, or school to use the App. Minors do not create their own accounts; their accounts are controlled by parents, guardians, or schools.

Age verification is the responsibility of the enrolling organization. We do not knowingly collect personal information directly from children under 13 without proper consent.

To report concerns, email info@lu-mino.com and we will investigate and delete information if appropriate.

9. Data retention

• Account information is retained while your account is active.
• Session participation logs are retained for up to 90 days.
• Session recordings, when enabled, are retained according to your organization's policy and applicable law.
• After account deletion, personal information is removed from active systems within 30 days.
• Backups are purged on a regular cycle.
• Some records may be retained where required by law (such as financial or audit records).

10. Your rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate information
• Request deletion of your account and personal data
• Withdraw consent where consent is the legal basis
• Lodge a complaint with a relevant data protection authority

11. Account and data deletion

To request deletion of your account and personal data:

1. Email info@lu-mino.com
2. Subject line: "Account Deletion Request"
3. Include the email address associated with your account
4. We may ask for identity verification before processing
5. We will confirm deletion within 30 days
6. You will receive a final confirmation email when deletion is complete

Some information may be retained where required by law (such as financial records or fraud-prevention logs) and will be deleted when no longer required.

12. Security

• Data in transit is encrypted using HTTPS / TLS
• Tokens are stored in the operating system's secure storage (iOS Keychain, Android Keystore)
• Passwords are stored only as one-way cryptographic hashes
• Internal access to personal data is limited on a need-to-know basis

No system is fully secure. If a security incident materially affects you, we will notify you in accordance with applicable law.

13. No advertising, no tracking

• The App displays no advertisements
• The App does not include third-party advertising SDKs
• The App does not track your activity across other apps or websites
• We do not sell, rent, or trade your personal information to data brokers, advertisers, or marketers

14. International use

The Service is operated from the United Arab Emirates. If you use the App outside the UAE, your information will be transferred to and processed in the UAE under appropriate safeguards.

15. Changes to this policy

We may revise this Policy from time to time. Material changes will be communicated through the App or by email. The "Last Updated" date at the top reflects the most recent revision.

16. Contact

Email: info@lu-mino.com
Address: Almouhat 1, Ajman, United Arab Emirates
Operator: EARLY SCHOLARS NURSERY (S.P.S - L.L.C)