Privacy Policy

At Glimmers Inc. ("Glimmers", "we", "our", or "us"), protecting children's privacy and personal information is a core responsibility.

This Privacy Policy explains how we collect, use, store, share, protect, and process information when parents, guardians, children, schools, educators, or other authorized users access and use the Glimmers platform, including our mobile applications, websites, educational programs, AI-powered features, events, Olympiads, parent dashboards, and related services (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

For children, parental consent may be required before information is collected or processed.

Glimmers is built on the following privacy principles:

• Child safety comes first.
• We collect only information necessary to operate the Services.
• We do not sell children's personal information.
• We do not use children's information for targeted advertising.
• Parents maintain control over their child's participation.
• Users have rights regarding their information.
• Privacy and safety must work together.
• Information is protected using reasonable technical and organizational safeguards.

3.1 Parent Information

We may collect:

• Name
• Email address
• Mobile number
• Parent account credentials
• Payment information
• Parent preferences
• Consent records
• Communication preferences

3.2 Child Information

Depending on the Services used, we may collect:

• First name or nickname
• Age or age range
• Avatar selections
• Learning preferences
• Program participation information
• Educational activity information

We seek to minimize collection of personal information from children.

3.3 User-Generated Content

We may collect content created within the platform, including:

• Journal entries
• Joy Capsules
• Reflections
• Creative submissions
• Artwork
• Images
• Videos
• Messages
• Comments
• Community participation content

3.4 AI Interaction Data

When users interact with Lumiri or other AI-powered features, we may collect:

• Questions submitted
• Responses generated
• Reflection activities
• Safety signals
• Usage patterns

AI interaction data may be reviewed for quality, safety, moderation, and product improvement purposes.

3.5 Community Activity Data

We may collect information relating to:

• Joy Circle participation
• Reports submitted
• Moderation actions
• Community interactions
• Block and mute actions

3.6 Technical Information

We may automatically collect:

• Device type
• Operating system
• Browser information
• IP address
• Session information
• Crash logs
• App performance information
• Analytics data

3.7 Payment Information

For subscriptions, events, or programs, payment processing may involve:

• Billing information
• Transaction identifiers
• Payment status
• Subscription records

Payment card information is generally processed by third-party payment providers and is not stored by Glimmers unless required for operational purposes.

We process information for the following purposes:

Platform Operations

• Creating and managing accounts
• Delivering Services
• Maintaining platform functionality
• Providing customer support

Child Safety

• Moderation
• Risk detection
• Safety reviews
• Parent notifications
• Escalation processes

Educational Experiences

• Personalizing activities
• Tracking participation
• Delivering learning experiences
• Supporting Olympiads and programs

AI Features

• Providing Lumiri functionality
• Improving AI performance
• Detecting harmful interactions
• Supporting safety systems

Communications

• Account notifications
• Program updates
• Safety alerts
• Service announcements

Legal Compliance

• Maintaining consent records
• Responding to legal obligations
• Handling disputes
• Fraud prevention

Where required by applicable law, Glimmers processes information based on:

• Parental consent
• Performance of services
• Compliance with legal obligations
• Protection of vital interests
• Legitimate interests related to safety, platform integrity, and service improvement

Where consent is required, parents may withdraw consent subject to applicable legal and operational requirements.

Because Glimmers is designed for children:

• Parent or guardian consent may be required before account activation.
• Parents may review information associated with their child.
• Parents may request correction or deletion of information.
• Parents may withdraw consent.

Children are encouraged not to share personal contact information, passwords, addresses, or other sensitive details within the platform.

Glimmers uses AI-powered tools including Lumiri.

AI systems may:

• Generate responses.
• Recommend activities.
• Support reflection.
• Assist moderation systems.

AI interactions may be reviewed to:

• Improve quality.
• Enhance safety.
• Investigate reported concerns.
• Monitor compliance with platform rules.

AI systems do not provide therapy, diagnosis, treatment, or emergency assistance.

To help protect users, we may use:

• Automated moderation systems
• AI-assisted moderation
• Human reviewers
• Community reports

Content may be reviewed where:

• Safety concerns arise
• Harmful behavior is suspected
• Abuse is reported
• Platform rules may have been violated

Where necessary, parents may be notified regarding significant safety concerns.

We may share information with:

Service Providers

Companies that help us operate the Services, including:

• Cloud hosting providers
• Payment processors
• Analytics providers
• Customer support tools
• Security providers

These providers may only process information according to our instructions.

Parents and Guardians

Parents may receive information relating to:

• Account activity
• Safety alerts
• Participation summaries
• Parent Dashboard insights

Schools and Educational Partners

Where participation occurs through approved educational programs, limited information may be shared to support program administration.

Glimmers does not share journal content, private reflections, or emotional content with schools unless specifically authorized or legally required.

Legal Authorities

We may disclose information where required by:

• Law
• Court orders
• Regulatory requests
• Child protection obligations
• Safety emergencies

Glimmers does not:

• Sell children's personal information.
• Use children's information for targeted advertising.
• Permit behavioral advertising directed at children.
• Build advertising profiles based on child activity.

We retain information only as long as reasonably necessary to:

• Operate the Services.
• Fulfill legal obligations.
• Resolve disputes.
• Maintain safety records.
• Conduct audits.
• Prevent fraud.

Specific retention periods may vary based on data category and legal requirements.

Additional details are available in the Data Retention & Deletion Policy.

Glimmers implements reasonable safeguards designed to protect information, including:

• Access controls
• Encryption technologies
• Monitoring systems
• Security reviews
• Authentication mechanisms

No system can guarantee absolute security.

Users are responsible for maintaining account credential security.

Depending on applicable law, parents and authorized users may have the right to:

• Access information.
• Correct inaccurate information.
• Request deletion.
• Withdraw consent.
• Request data export.
• Object to certain processing activities.
• Submit complaints.

Requests may require identity verification before processing.

Information may be processed and stored in locations where Glimmers or its service providers operate.

Where required, we implement safeguards intended to protect transferred information.

The Services may contain links or integrations with third-party services.

Glimmers is not responsible for the privacy practices of third-party services.

Users should review the privacy policies of those services separately.

We may update this Privacy Policy from time to time.

Where material changes occur, parents may be notified and additional consent may be requested where required.

The most current version will always be available through the Glimmers Trust & Safety Center.

Glimmers Inc.

• Support Email: [Insert Support Email]
• Privacy Requests: [Insert Privacy Email]
• Grievance Officer: [Insert Details]
• Registered Address: [Insert Address]

For privacy concerns, consent withdrawals, access requests, deletion requests, or questions about this Privacy Policy, please contact us using the information above.