Luma R1 & LumaRead2
Privacy Policy
Committed to Data Minimization and Privacy by Design.
No Student Tracking
We do not collect names, IDs, phone numbers, or build user profiles.
Local Processing
All OCR and voice data is processed offline on the device. No cloud transmission.
Strictly Educational
FERPA & COPPA compliant architecture designed specifically for schools.
1. Introduction & Scope
Lusem Tech Solutions, Inc. (“we,” “us,” or “our”) provides the LumaRead2 application, delivered exclusively as the operating interface for the Luma R1 assistive device.
This Privacy Policy governs the use of the LumaRead2 software and the associated Luma R1 hardware. We are committed to a philosophy of Data Minimization and Privacy by Design. Our technology is architected to operate securely as an offline-first tool, ensuring that student data remains physically isolated on the device.
2. No Collection of Student Personal Information
LumaRead2 is designed to function without requiring, collecting, or transmitting Student Personal Information in the ordinary course of providing its service.
Student Personal Information refers to information that identifies or could reasonably be used to identify an individual student (e.g., name, ID, email) or their educational records.
This is distinguished from Technical Device Data (e.g., battery status, crash reports), which is used solely for maintaining the device and cannot identify an individual student.
- No User Accounts: We do not require account creation, login credentials, or email addresses.
- Volatile Session Memory: User-generated content is permanently erased from active memory when the screen is cleared or session restarts.
3. Student Data Privacy (FERPA & COPPA)
FERPA Compliance
We act only in accordance with a written contractual agreement with a given school or district. We do not access, maintain, or transmit “Education Records.” All student-generated data remains under the direct physical control of the School and the User on the local device.
COPPA Compliance
Architecture Prevention: We have architected the application to lack the capability to request personal information.
No Behavioral Profiling: We do not build user profiles, track behavior for advertising, or sell any Student Personal Information.
4. Data Separation
AUser Content
What: Document images, OCR text, audio readouts.
Handling: Processed exclusively on-device using offline libraries.
BSystem Health Data
What: Crash reports, battery health, stability logs.
Handling: Securely transmitted via Google Crashlytics/AMAPI for fleet maintenance.
5. Device & Hardware Management
The Luma R1 is a Dedicated Device (Kiosk). We utilize the Android Management API (AMAPI) to provision and maintain the fleet.
Restriction of Powers
We are legally and contractually prohibited from using administrative tools to:
- View the device screen remotely (Screen Casting).
- Track precise physical location (GPS is disabled).
- Access the camera or microphone remotely.
- Monitor student activity.
App Permissions
- Camera: Used solely for local OCR. No video feed recorded.
- Microphone: Used solely for voice commands. Audio never uploaded.
6. Third-Party Data Processors
| Service | Purpose | Data Scope |
|---|---|---|
| Google Play Services | App Delivery & Security | Device Identifiers, IP Address |
| Firebase Crashlytics | Bug Reporting | Stack traces, device model, OS version |
| Android Management API | Device Updates | Battery, Storage, App version |
7. & 8. Changes & Security
We may update this policy to reflect technical changes. If we make material changes, we will notify obligated parties. We implement reasonable security procedures; in the event of a compromise, we will notify affected schools within Tennessee statutory timelines.
Questions about privacy?
Our Privacy Officer is available to answer your questions.