1. Introduction
Lusem Tech Solutions, Inc. ("Lusem," "we," "us," or "our") provides the LumaRead2 application for use with the Luma R1 assistive device. This Privacy Policy describes how Lusem handles information in connection with the LumaRead2 software, the Luma R1 assistive device, and related support, maintenance, and software update services. This Privacy Policy forms part of Lusem's overall privacy and security program and may be supplemented by contractual commitments made to educational institutions or other customers.
Lusem is committed to the principles of data minimization and privacy by design. The Luma R1 platform is architected as an offline-first system intended to minimize the collection, transmission, and retention of information while providing its intended educational and accessibility functionality. The categories of information processed by the platform and Lusem's information handling practices are described in the sections that follow.
2. No Collection of Student Personal Information
LumaRead2 is architected to provide its educational functionality without requiring user accounts or collecting or transmitting Student Personal Information during the ordinary operation of the platform.
Student Personal Information means information that identifies, or could reasonably be used to identify, an individual student or the student's Education Records (as that term is generally understood under the FERPA), including, without limitation, names, student identification numbers, email addresses, school-assigned identifiers, demographic information, communications, and the contents of a student's academic work. LumaRead2 is architected so that its ordinary operation does not require or collect this information.
User-Generated Content means images, text, OCR results, dictated input, voice commands, and other content processed by LumaRead2 during an active user session. User-Generated Content is processed on the Luma R1 device and, during ordinary operation, is not transmitted to Lusem. Upon session termination, LumaRead2 is architected to clear, deallocate, or otherwise render User-Generated Content inaccessible as part of its normal application memory lifecycle. Certain user-created information that is intended to persist across user sessions, such as user-configured schedules, alarms, focus reminders, accessibility preferences, or similar configuration settings, may be stored locally on the Luma R1 device. This information remains on the device during ordinary operation, is not transmitted to Lusem, and may be removed through device reset, application data clearing, or authorized support or maintenance procedures.
Device Inventory Information means limited information maintained by Lusem to identify, provision, support, and maintain authorized Luma R1 devices, including device serial numbers, MAC addresses, operating system version information, and similar device-identification information. Device Inventory Information is maintained separately from Student Personal Information and User-Generated Content and is not associated by Lusem with individual student identities or Education Records.
Network Update Metadata means limited technical information generated when a Luma R1 device checks for or downloads authorized software or security updates. This information may include an IP address, request timestamps, requested update files or URLs, and similar network or request metadata generated during standard internet communications. Network Update Metadata is used solely to deliver software updates, maintain the security and integrity of the update infrastructure, diagnose update-related issues, and protect system reliability. Lusem does not use Network Update Metadata to identify, profile, monitor, or track individual students.
Consistent with this architecture:
- No User Accounts. LumaRead2 does not require account creation, login credentials, or email addresses.
- No Student Tracking. LumaRead2 does not require users to provide, or collect, student names or other personal identifiers during ordinary operation.
- Local Processing. Except as expressly described in this Privacy Policy, User-Generated Content is processed on the Luma R1 device and is not transmitted to Lusem during the ordinary operation of the platform.
3. Privacy in Educational Environments
LumaRead2 is designed primarily for educational environments, including K–12 schools and institutions of higher education. It may also be deployed in other accessibility-focused environments consistent with its intended use. When deployed in educational settings, Lusem is committed to operating the platform in a manner consistent with applicable student privacy laws and its contractual obligations to educational institutions.
FERPA (Family Educational Rights and Privacy Act)
Lusem provides the Luma R1 platform and LumaRead2 software pursuant to agreements with educational institutions. Consistent with the platform architecture described in this Privacy Policy, Lusem does not intentionally access, maintain, or disclose student Education Records in connection with providing the platform.
During ordinary operation, User-Generated Content remains on the local device and is not transmitted to Lusem.
COPPA (Children's Online Privacy Protection Act)
LumaRead2 is architected so that its ordinary educational functionality does not require users to create accounts or provide Student Personal Information. Accordingly, Lusem does not create user profiles, engage in behavioral advertising, sell Student Personal Information, or use Student Personal Information for targeted advertising or marketing.
Inadvertent Receipt of Student Personal Information
Although the platform is architected to minimize the collection and transmission of Student Personal Information, Lusem may inadvertently receive such information in limited circumstances, such as customer support requests or other communications initiated by an educational institution.
If Lusem inadvertently receives Student Personal Information or Education Records, Lusem will:
- use such information solely as necessary to provide the contracted educational services or as otherwise authorized by the applicable educational institution or required by law;
- not disclose or redisclose Student Personal Information or Education Records except as authorized by the educational institution or required by applicable law;
- not sell Student Personal Information or use it for advertising, marketing, or behavioral profiling;
- maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the information received; and
- delete or return such information upon request by the educational institution, unless retention is required by applicable law or reasonably necessary to establish, exercise, or defend legal claims.
4. Managed Device Configuration and Application Permissions
Managed Device Configuration
The Luma R1 is provided as a dedicated-purpose assistive device configured to operate in a managed kiosk environment. Devices are provisioned using Lusem's custom device-management software and local configuration process to support the platform's intended educational functionality.
The Luma R1 stores and enforces its management configuration locally on the device and is not dependent upon continuous communication with a cloud-based remote device management service during ordinary operation. The platform does not utilize a cloud-based remote administration console to observe user activity, retrieve User-Generated Content, or collect device telemetry during ordinary operation.
When a device checks for authorized software or security updates, only the limited Network Update Metadata described in this Privacy Policy is generated.
Because the Luma R1 does not depend on continuous cloud-based device management, Lusem generally cannot remotely locate, observe, lock, or wipe an offline device. If a device is returned to Lusem, connected through an authorized support or maintenance process, or otherwise becomes technically capable of receiving an authorized administrative action, Lusem may take reasonable steps to protect the integrity of the platform or remove locally stored information.
Application Permissions
LumaRead2 requests only those device permissions necessary to provide its intended educational functionality.
- Camera. Used solely for local OCR processing.
- Microphone. Used solely for local voice commands and dictation.
- Bluetooth Permissions. Required to discover, pair, and communicate with supported Bluetooth accessibility devices. These permissions are not used to determine, collect, or transmit location information.
5. Infrastructure Service Providers
Lusem utilizes third-party infrastructure service providers to host its website and support the secure delivery of authorized software updates for the Luma R1 platform.
When a Luma R1 device checks for or downloads authorized software or security updates, these providers process only the limited Network Update Metadata described in this Privacy Policy. That information is processed solely to deliver software updates, maintain the availability and security of the update infrastructure, protect the integrity of the platform, and troubleshoot update-related issues.
Software update requests are used only to request or receive authorized software updates and are not used to transmit Student Personal Information or Education Records.
6. Changes to This Policy
Lusem may update this Privacy Policy from time to time to reflect changes in applicable law, the functionality of the Luma R1 platform or LumaRead2 software, security practices, or other operational or technical developments.
If Lusem makes a material change to this Privacy Policy that affects how Student Personal Information or other information is handled, Lusem will provide notice to affected educational institutions or other contractually entitled parties through their designated administrative or contractual contact. Where appropriate, Lusem may also provide notice through the device interface, administrative communications, or other reasonable means.
The "Last Updated" date at the beginning of this Privacy Policy indicates when the most recent revisions became effective.
This Privacy Policy describes the current operation of the Luma R1 platform and LumaRead2 software. If future features materially change the categories of information processed or the manner in which information is handled, Lusem will update this Privacy Policy before those changes become effective.
7. Security
Lusem implements and maintains reasonable administrative, technical, and physical safeguards appropriate to the size of the organization and the nature of the information processed to protect the confidentiality, integrity, and availability of the information described in this Privacy Policy. These safeguards are reviewed periodically as part of Lusem's ongoing security practices.
If Lusem becomes aware of a security incident involving Student Personal Information that requires notification under applicable law or contractual obligation, Lusem will provide notice to affected educational institutions or other required parties without unreasonable delay and in accordance with applicable law and contractual requirements.
8. Contact Information
Questions regarding this Privacy Policy or Luma R1 privacy and security practices may be directed to:
Lusem Tech Solutions, Inc.
Privacy Officer