Privacy Policy

1. Who We Are

In this Privacy Policy, "Dylumio," "we," "us," and "our" mean the operator of the Dylumio Services. If a legal entity name is identified in a checkout page, invoice, order form, or similar notice, that entity is the operator and contracting party for the Services in your region.

2. Information We Collect

We collect information directly from parents or guardians, automatically through use of the Services, and from service providers that help us operate the Services.

The categories of information we may collect include:

• Parent account information, such as name, email address, login credentials, subscription status, and billing-related identifiers.
• Child profile information, such as first name, age, grade, selected interests, avatar seed, course placement, learning progress, badges, streaks, and friend connection data.
• Assessment and lesson data, such as answers, lesson attempts, error patterns, completions, fluency and decoding results, comprehension results, spelling results, and other learning performance data.
• Audio data, including child voice recordings submitted during the screener, lessons, and tutor sessions, and transcripts or timing information generated from those recordings.
• Technical and usage data, such as IP address, browser type, device information, session logs, page interactions, and diagnostic information.
• Customer support and communications data, such as emails, help requests, and feedback.

3. Children's Information and Parental Control

We provide Services intended to be used by parents or guardians for the benefit of children, including children under 13. We structure the Services so that parents control account creation, child profile creation, billing, settings, and deletion decisions.

Children do not create standalone accounts with us. We do not knowingly allow children to create independent login credentials for the Services.

Parents may review, update, or request deletion of their child's information, subject to applicable law and our ability to verify the request.

4. Audio Recordings and Voice Data

Audio recordings that contain a child's voice are sensitive and may constitute personal information under applicable law, including the Children's Online Privacy Protection Act (COPPA). We therefore treat child audio data with heightened care.

We collect audio recordings to operate core product features, including the reading screener, read-aloud exercises, virtual tutor sessions, and related speech-based learning features. We use these recordings to generate transcripts, evaluate reading performance, identify likely reading challenge areas, and deliver progress insights to parents.

Audio recordings are stored in private storage and are not intended to be publicly accessible. We generate limited-duration access links only as needed to process the recordings server-side.

We may use third-party service providers to process audio and produce transcripts or AI-assisted analysis. Those providers act on our behalf and are permitted to use the data only to provide services to us, subject to their own terms and applicable law.

Audio processing is not perfect. Transcription systems and speech models may misunderstand children's speech, regional accents, dysfluent speech, hesitations, or pronunciation differences. As a result, transcripts, fluency scores, error classifications, and AI-generated summaries may contain inaccuracies.

Voice recordings may also capture incidental background speech, sounds, or other information if recordings are made in a shared environment. Parents should supervise use and avoid including unnecessary sensitive information in recordings.

• Screener audio is intended to be retained for approximately 30 days, unless a longer period is required by law, to resolve abuse, fraud, security, or technical issues, or to complete a parent-requested review.
• Session audio is intended to be retained for approximately 90 days, unless a longer period is required for the reasons above.
• Transcripts, structured scoring outputs, and derived learning signals may be retained longer than the raw audio because they are part of the child's learning history and parent reporting.

5. How We Use Information

We use information to provide, maintain, secure, improve, and personalize the Services. Our uses include:

• Creating and administering parent accounts and child profiles.
• Running the screener and generating risk-indicator summaries, placement suggestions, and next-step recommendations.
• Delivering lessons, tutor sessions, progress tracking, friend features, weekly reports, and parent insights.
• Processing audio, generating transcripts, and evaluating reading-related performance.
• Providing billing, subscription management, receipts, and customer support.
• Monitoring performance, preventing fraud, troubleshooting issues, and maintaining security.
• Sending product, service, and transactional communications.
• Complying with legal obligations and enforcing our agreements.

6. How We Share Information

We do not sell children's personal information. We do not use child interest data or child voice data for behavioral advertising.

We may share information in the following circumstances:

• With service providers that help us host the Services, store data, process payments, send email, transcribe audio, provide AI features, monitor performance, or perform analytics.
• With payment processors and billing platforms to process subscriptions and manage billing.
• With analytics and infrastructure providers for parent-facing product analytics and operational insights, subject to our child-privacy controls.
• With other users only through privacy-limited social features expressly enabled in the product, such as first name, avatar, streak, and weekly lesson counts shown in Reading Friends. We do not expose one child's detailed reading scores, diagnoses, transcripts, or error patterns to other families.
• If required by law, subpoena, court order, government request, or where we believe disclosure is necessary to protect rights, safety, security, or investigate fraud or abuse.
• In connection with a merger, financing, acquisition, reorganization, sale of assets, or similar corporate transaction, subject to applicable confidentiality and legal obligations.

7. Child-Facing Analytics and Advertising Restrictions

We disable third-party analytics and session recording tools on child-facing learning routes to the extent implemented in our Services. We do not intentionally serve behavioral advertising based on child profile information, child usage data, or child interests.

Parents may still encounter limited operational or security-related logging necessary to run the Services, but not child-directed advertising profiles created by us from learning data.

8. Retention and Deletion

We retain personal information for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, and protect the security and integrity of the Services.

Parents may delete a child profile from within the Services. Deleting a child profile is intended to permanently remove the child profile and associated learning records from our active systems, subject to limited backup, legal, fraud-prevention, and security retention.

If a subscription is canceled or lapses, we may retain certain account and learning data for a limited period to permit reactivation, support, dispute resolution, or legal compliance before deletion or de-identification.

9. Security

We use administrative, technical, and organizational measures designed to protect personal information from unauthorized access, use, alteration, and disclosure. These measures include access controls, private storage configurations for sensitive files, and role-based access restrictions.

No method of transmission over the Internet, no speech-processing pipeline, and no method of electronic storage is completely secure. You use the Services and submit information, including child voice recordings, at your own risk.

10. Your Rights and Choices

Subject to applicable law, parents and guardians may have the right to access, correct, update, delete, or request export of certain personal information we maintain.

Parents may also request that we stop further collection or use of a child's information, subject to the limitations of the Services and our legal obligations.

To exercise rights related to your account or your child's information, contact us using the information below. We may request information necessary to verify your identity and authority before acting on a request.

11. State Privacy Rights

Depending on where you live, you may have additional rights regarding personal information, including rights to know, access, correct, delete, or limit certain uses of information. We do not sell children's personal information and do not knowingly share children's personal information for cross-context behavioral advertising.

If you are a resident of a state that provides additional privacy rights, you may contact us to exercise those rights. We will respond in accordance with applicable law.

12. International Users

The Services are intended primarily for users in the United States. If you access the Services from outside the United States, you understand that your information may be transferred to, stored in, and processed in the United States or other jurisdictions where our providers operate, which may have different data protection rules than your jurisdiction.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the Services, by email, or by updating the effective date above. Your continued use of the Services after the effective date of an updated Privacy Policy constitutes your acknowledgment of the updated Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise privacy rights for yourself or your child, contact us at support@dylumio.com.