Lasted Updated: June 6, 2025
Company Name: Luno
Contact: \[Insert address, email, phone]
Luno provides a screen-time monitoring platform (mobile app) for parents to supervise their children’s device use. We are committed to protecting your privacy and the privacy of your children. This Privacy Policy explains what information we collect, how we use and share it, and your rights. Because our service is used by families, we follow all applicable U.S. laws on children’s privacy, including the Children’s Online Privacy Protection Act (“COPPA”).
When a parent creates an account, we collect their name and email address. We verify that the account holder is a parent or legal guardian (COPPA requires parental consent).
Parents set up profiles for each child (under 13). We collect each child’s name and age (or birthdate) to personalize the experience. A unique QR code is generated and sent to the child's device, which allows the child to log in. This method ensures secure access without requiring children to enter passwords.
We collect technical details from the child’s device, such as device type, operating system, unique device identifiers, and usage metrics (apps used, screen time, etc.). These “persistent identifiers” fall under personal information as defined by COPPA.
If enabled by the parent, we may collect a child’s device geolocation (latitude/longitude or city-level location). COPPA considers precise geolocation (street-level) as personal information.
For paid plans or in-app purchases, we use a third-party payment processor (Stripe). We do not directly collect credit card numbers or billing details; Stripe handles this securely.
We use Google Analytics and Firebase for usage analysis. These services may use cookies or identifiers to track how the app and website are used. We configure these tools to minimize collection of personal data in compliance with COPPA. (For example, Google Analytics can anonymize IP addresses.)
If you contact customer support, we collect information in that correspondence (e.g. email contents).
Note: Children can access the app independently using the QR code generated by the parent. However, child profiles are monitored and have restricted permissions. Only parents can register accounts and manage settings.
* Provide Service: We use your child’s profile and device data to enable the core features (e.g. tracking screen time, setting limits, etc.).
* Communicate: We use your email to send account notifications, support replies, and changes to terms.
* Payment Processing: Parent payment information is securely processed by Stripe to charge for premium features; we use minimal information necessary (name, email, plan, Stripe tokens).
* Analytics and Improvement: We analyze anonymized usage data (via Firebase/Google) to improve and personalize the service. This helps us understand feature usage and fix issues.
* Legal and Safety: We may use information to comply with laws or protect our rights. For example, COPPA requires we maintain audit logs if needed.
* Security: We use your data for fraud prevention and security (detecting misuse of accounts, unusual activity, etc.).
Under COPPA, we do not disclose a child’s personal information to third parties except as required for the operation of the service or with parental approval. For example, we do not sell children’s information to advertisers.
We share data only with trusted partners and as required by law:
We share necessary data with our sub-processors who help run the service:
* Firebase/Google Cloud: We store data on Google Cloud Firestore and use Firebase services for authentication, notifications, and analytics. Firebase services encrypt data in transit (HTTPS/TLS) and encrypt many data-at-rest. Google limits access to data by employees and uses two-factor authentication for systems that handle user data.
* Google Analytics: We use Google Analytics to track app usage. We only transmit non-identifiable information (no names or exact locations), and we disable any ad-targeting features.
* Stripe: For paid features, we send payment and limited personal information (name, email, transaction amount) to Stripe. Stripe is certified to PCI standards and uses industry-standard encryption (AES-256) for data at rest and TLS for data in transit. We do not see or store full credit card details.
We may disclose information if required by law enforcement, court order, or government regulation.
If our company is acquired or assets transferred, user data may be part of that transaction (but will remain subject to privacy commitments).
Any third-party service that collects personal information on our behalf is described here. We do not share children’s data with ad networks or marketing partners. As required by COPPA, our privacy policy clearly discloses all third-party data sharing and usage.
We implement reasonable security measures to protect data:
* Encryption: All data in transit is encrypted using HTTPS/TLS. We store data in managed cloud databases (Google Cloud) that encrypt data at rest with strong algorithms (AES-256).
* Access Controls: Only authorized company personnel with a business need can access personal data. Access is logged and requires multi-factor authentication.
* Industry Standards: We follow industry best practices (OWASP guidelines, regular security reviews, etc.) to prevent unauthorized access.
* Data Minimization: We collect only the data needed to provide the service and delete it when no longer necessary.
* COPPA Security: In compliance with COPPA, we take “reasonable steps to release such information only to parties capable of maintaining its confidentiality and security.”
We retain personal information (parent and child data) only as long as needed to operate the service and for legal compliance. When a parent requests deletion of a child’s data or closes an account, we delete the data from live systems and backups within a reasonable period. As COPPA requires, we “retain personal information collected online from a child for only as long as is necessary” and then securely delete it.
Parents can request access, correction, or deletion of their child’s data at any time by contacting us. We also allow parents to withdraw consent and stop future data collection, in which case we will disable data collection for that child.
Our service is intended for use by parents of children under 13. We require verifiable parental consent before collecting any personal information from a child. By registering and providing your child’s information, you confirm you are the child’s parent or guardian. We do not allow a child to sign up or use the app independently without a parent account.
In accordance with COPPA:
* We have provided direct notice to parents and obtained consent before collecting children’s data.
* We maintain a child’s data only for the duration of the parent’s account, and allow deletion or correction on demand.
* We do not condition participation on collecting unnecessary information.
* We place parents firmly in control: parents can review their child’s data and revoke consent anytime.
## Your Rights
* Parental Controls: As a parent, you can access and review all personal information about your child. You may request corrections or deletion by contacting us.
* Data Portability: You can obtain your personal data (account and child profile data) by requesting a download.
* Withdraw Consent: You may withdraw consent for data collection, which will stop further data gathering on your child’s activities.
* No Sale: We do not sell or rent your personal information.
If you are a California resident, note that California law grants minors certain privacy rights. We respect any such rights by allowing parental requests for data deletion.
We may update this Privacy Policy from time to time. We will post any revised policy with a new effective date and notify registered parents by email or in-app notification. Substantive changes (e.g. new data uses) will be communicated, and continued use of the service implies acceptance.
For questions about this Privacy Policy or to exercise your rights, please contact:
\[Company Name]
\[Address]
Email: \[email]
Phone: \[phone number]
We follow all applicable U.S. laws for children’s privacy. Please review this policy carefully and keep a copy for your records.
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