Legal Document

Privacy Policy

For Wisdom For Kids (School Edition)

Last Updated: January 12, 2026

1Introduction

Wisdom For Kids is a product owned and operated by THEOS LUMEN LTD ("the Company," "we," "us," or "our"). This Privacy Policy governs the use of the Wisdom For Kids mobile application and school dashboard (collectively, the "Platform").

We provide this Platform as an educational tool for schools, districts, and teachers ("Clients"). We are deeply committed to protecting the privacy of students. This policy describes how we collect, use, and safeguard the information provided to us by schools and students.

2Information We Collect

We limit the data we collect to only what is necessary to provide our educational services.

A. Information Provided by Schools

To set up student accounts, we rely on the School or Teacher to provide the following Roster Data:

  • Student Full Name: Used to identify the student within the Teacher Dashboard.
  • Class/Grade Level: Used to segregate students into different groups.
  • Login Credentials: The school assigns a Password. We do not collect student email addresses.

B. Information Collected from Students

When a student uses the mobile application, we process the following data:

  • Behavioral Interactions: We record student responses to in-app scenarios and quizzes (e.g., choosing a response to a moral dilemma).
  • Voice Interactions: When a student uses the voice chat feature, audio is processed using a real-time voice-to-voice model. After the conversation ends, the session is analyzed by AI to generate structured insights for the teacher, and the raw conversation data is then permanently deleted. We do not permanently store, record, or archive audio recordings of students.
  • Text Chat Logs: We process text inputs to generate AI responses. After each session, the conversation is analyzed by AI to produce a structured report for the teacher (including a session summary, SEL competency mapping, and follow-up prompts). The raw conversation is then permanently deleted. Only the analysis report is retained, not the original chat logs.

C. Automatically Collected Information

To ensure the app functions correctly, we use tools like Google Analytics and Crashlytics to collect:

  • Device Information: Device model, operating system version.
  • Usage Data: App crashes, performance metrics, and feature usage stats.

Note: We have configured these tools to avoid collecting Personally Identifiable Information (PII) or tracking students for advertising purposes.

3How We Use Information

We use the information collected strictly for educational and operational purposes:

  1. To Provide the Service: Allowing students to log in and interact with stories and the AI mentor.
  2. To Generate Insights: After each AI conversation, we generate a structured analysis report for the teacher (session summary, key quotes, SEL competency mapping, and follow-up prompts). We also produce bi-weekly aggregate reports that summarize each student's SEL growth over time.
  3. To Improve the Platform: Using aggregated, anonymized data to fix bugs and improve content.

Strict Prohibitions

  • We DO NOT sell student data.
  • We DO NOT use student data for targeted advertising.
  • We DO NOT build profiles of students for non-educational purposes.

4Student Privacy & Compliance

COPPA

Children's Online Privacy Protection Act

Wisdom For Kids complies with COPPA. We rely on the "School Official Exception" (16 CFR § 312.5) to collect information from students under 13. We do not obtain consent directly from parents; instead, we contract with the School, which consents on behalf of the parent for educational purposes.

FERPA

Family Educational Rights and Privacy Act

We act as a "School Official" with a legitimate educational interest in the student data. We remain under the direct control of the School with respect to the use and maintenance of education records.

5International Data Subjects (GDPR)

If you are accessing our Platform from the European Economic Area (EEA), United Kingdom (UK), or other regions with comprehensive data protection laws, the following additional rights and disclosures apply to you:

Legal Basis for Processing: We process personal data based on: (a) contractual necessity to provide our educational services; (b) legitimate interests in improving our Platform; and (c) consent, where applicable.

Your Rights

Subject to applicable law, you have the right to:

  • Access your personal data and receive a copy.
  • Rectify inaccurate or incomplete personal data.
  • Erasure ("Right to be Forgotten") of your personal data under certain circumstances.
  • Restrict processing of your personal data.
  • Data Portability: receive your data in a structured, commonly used format.
  • Object to processing based on legitimate interests.
  • Withdraw consent at any time, where processing is based on consent.

International Data Transfers: Your data may be transferred to and processed in countries outside the EEA/UK. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), to protect your data.

Contact for GDPR Inquiries: To exercise any of these rights, please contact us at the email address provided in the Contact Us section. Schools should direct requests through their designated administrator.

6Third-Party Service Providers

We utilize trusted third-party infrastructure to deliver our services. Data sent to these providers is encrypted and used solely to function the app.

ProviderPurposePrivacy Note
OpenAIAI Chat, Voice-to-Voice & AnalysisPowers text chat, voice-to-voice conversations (via Realtime API), and post-session analysis. Data sent to OpenAI is NOT used to train their models. Read more here: https://openai.com/enterprise-privacy/
StreamIOVoice Streaming TransportProvides the real-time streaming infrastructure for voice sessions. Audio is not archived by StreamIO.
Backblaze / MySQLData StorageEncrypted storage for student profiles and behavioral reports.
GoogleApp AnalyticsCrash reporting and performance monitoring (Non-PII).

7Data Retention & Deletion

  • AI Analysis Reports: After each AI conversation, a per-session analysis report is generated and retained. We also produce bi-weekly aggregate reports summarizing each student's SEL progress. These reports are available to teachers via the dashboard.
  • School Control: All student data is retained only for as long as the School keeps an active subscription.
  • Deletion: Upon termination of a School's agreement, or upon written request by the School, we will permanently delete all associated student data from our servers.

8Parental Rights

Because we rely on the School's consent:

  • Access & Correction: Parents wishing to review, correct, or delete their child's personal information must contact their School or Teacher directly.
  • Support: We will work with the School to fulfill these requests promptly.

9Security

We implement industry-standard security measures, including encryption in transit (SSL/TLS) and at rest, to protect student data. Access to student data is restricted to authorized school personnel (via the Dashboard) and essential Wisdom For Kids engineering staff for maintenance purposes.

10. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact our Privacy Officer:

privacy@wisdomforkids.app