Child Safety Policy

1. Our Commitment to Child Safety

LumiOre LLP ("LumiOre") operates an AI-powered educational platform designed exclusively for students aged 6 to 16 in Singapore. The safety, dignity, and wellbeing of every child who uses the Platform are paramount to everything we do.

This Child Safety Policy sets out: the safeguards LumiOre has built into the Platform to protect children; the responsibilities of Parent/Guardians in supervising their child's use of the Platform; what LumiOre will and will not do in relation to children's data and online interactions; how to report a child safety concern to LumiOre; and how LumiOre responds to safety incidents.

This Policy should be read alongside LumiOre's Privacy Policy, Terms of Service, and Acceptable Use Policy. In the event of any inconsistency, this Child Safety Policy takes precedence in respect of matters relating to child safety and protection.

2. Age Eligibility and Parental Supervision

2.1 Age Range

The Platform is designed for students aged 6 to 16. LumiOre does not knowingly permit students outside this age range to access the Platform. If LumiOre becomes aware that a student outside the eligible age range has accessed the Platform, the account will be reviewed and may be suspended pending verification.

2.2 Under-13 Users: Enhanced Safeguards

Children under the age of 13 are subject to enhanced safeguards under this Policy and under Singapore's PDPA. For students under 13:

• Parental consent is mandatory and must be verifiable. LumiOre reserves the right to request supporting documentation.
• Data collection is limited to the strict minimum necessary to deliver the educational service.
• Access to the AI learning chat feature may be subject to additional restrictions and monitoring.
• Parents are strongly encouraged to supervise every session.

2.3 Parental Supervision Responsibility

While LumiOre has built safety measures into the Platform, no technology-based safeguard is a substitute for active parental supervision. LumiOre strongly encourages parents and guardians to: co-use the Platform with younger children (particularly those aged 6 to 9); review the Parent Dashboard regularly to monitor their child's sessions, progress, and chat logs; discuss the Platform's purpose with the Student and explain that the AI is a learning tool, not a general-purpose assistant; and ensure the Student understands they should not share personal information in the AI chat.

3. AI Learning Chat: Guardrails and Safety Measures

3.1 What the AI Chat Can Do

The AI learning chat is designed exclusively as an educational support feature. It can: answer questions related to the MOE curriculum for Mathematics and Science; explain concepts, methods, and worked examples aligned to the student's learning level; provide encouragement and guide the student through problem-solving steps; and respond to queries about practice questions generated on the Platform.

3.2 What the AI Chat Cannot Do

The following restrictions are enforced by technical guardrails built into the AI chat system:

• The AI chat will not engage in conversations outside the scope of MOE curriculum-aligned educational content.
• The AI chat will not generate content that is violent, sexual, discriminatory, hateful, or otherwise harmful or inappropriate for children.
• The AI chat will not facilitate communication between the Student and any other user or third party.
• The AI chat will not solicit, encourage, or accept the sharing of personal information by the Student (such as home address, school name beyond what is registered, or contact details).
• The AI chat will not provide medical, psychological, legal, or financial advice.
• The AI chat will not generate content designed to bypass its own educational guardrails.

3.3 Chat Log Access and Review

All AI learning chat sessions are logged. Parent/Guardians may access their child's chat logs at any time through the Parent Dashboard. LumiOre reserves the right to review chat logs for safety, quality assurance, and policy compliance purposes. Chat logs are retained in accordance with LumiOre's Privacy Policy.

3.4 Imperfect Guardrails

LumiOre takes all reasonable steps to implement and maintain effective safety guardrails. However, no AI system can guarantee that every output will be perfectly appropriate in every circumstance. Parent/Guardians are encouraged to review chat logs and report any content that appears inappropriate or concerning. LumiOre will investigate all reports promptly.

4. Content on the Platform

4.1 AI-Generated Educational Content

All AI-generated content on the Platform — including practice questions, explanations, tutorials, and feedback — is designed to be educational in nature and appropriate for students aged 6 to 16. Content is aligned to Singapore's MOE curriculum for Primary and Secondary levels.

4.2 No Advertising to Children

LumiOre does not display third-party advertising on the Platform. Children using the Platform will not be exposed to commercial advertising, sponsored content, or marketing materials from third parties.

4.3 No Social or Peer-to-Peer Features

The Platform does not include social networking features, messaging between students, forums, or any feature that allows students to communicate with or view content submitted by other students. The Platform is a private, personalised learning environment for each individual Student.

4.4 No Sale or Marketing Use of Children's Data

LumiOre will not use any Student's Personal Data or Learning Profile for marketing, advertising profiling, or commercial data sales. Student data is used solely to deliver the educational services described in the Terms of Service and Privacy Policy.

5. Prohibited Conduct Involving Children

The following conduct is strictly prohibited and will result in immediate account termination and, where appropriate, referral to relevant authorities:

• Attempting to use the Platform to contact, locate, or communicate with a child other than the registered Student.
• Uploading or attempting to upload content that is sexually explicit, abusive, exploitative, or harmful to children.
• Attempting to extract, harvest, or misuse Personal Data of any Student through the Platform.
• Using the Platform in any way that constitutes grooming, harassment, exploitation, or abuse of a child.
• Misrepresenting identity, age, or relationship to a Student when registering an account.

LumiOre takes a zero-tolerance approach to any conduct that could endanger, exploit, or harm a child.

6. Reporting a Child Safety Concern

6.1 How to Report

If a Parent/Guardian, Student, or any person believes that a child safety concern has arisen in connection with the Platform — including inappropriate AI-generated content, a safety incident, or a suspected breach of this Policy — they should contact LumiOre immediately:

Please include as much detail as possible, including the nature of the concern, the date and time it occurred, and any screenshots or records you are able to provide.

6.2 LumiOre's Response to Safety Reports

Upon receiving a child safety report, LumiOre will:

• acknowledge receipt of the report within 1 business day;
• conduct an internal review of the reported content or incident within 2 business days;
• take immediate remedial action where the concern is substantiated, which may include removing or correcting AI-generated content, restricting access, or modifying Platform features;
• provide feedback to the reporting party on the outcome of the review, subject to any applicable legal or privacy constraints; and
• escalate serious concerns — including any matter involving potential harm to a child — to the relevant Singapore authorities, including the Singapore Police Force or the Ministry of Social and Family Development (MSF), as appropriate.

6.3 External Reporting

LumiOre encourages anyone who believes a child is in immediate danger to contact the relevant emergency services or authorities directly, and not to rely solely on LumiOre's internal reporting process:

• Singapore Police Force: 999 (emergency) or 1800-255-0000 (non-emergency)
• Ministry of Social and Family Development (MSF) Child Protection Service: 1800-777-0000
• National Anti-Violence and Sexual Harassment Helpline: 1800-777-0000

7. Data Safety for Children

LumiOre's approach to children's data is governed by the principles of data minimisation, purpose limitation, and security. In addition to the measures described in our Privacy Policy, LumiOre applies the following specific safeguards for children's data:

• Children's Personal Data is never used for advertising, marketing profiling, or sold to third parties.
• The Learning Profile generated for each Student is accessible only to the registered Parent/Guardian of that Student and to authorised LumiOre staff.
• Student data is stored with encryption at rest and in transit.
• Access to systems containing Student data is restricted to LumiOre staff with a legitimate operational need.
• LumiOre conducts regular reviews of data access logs to detect and respond to any unauthorised access.
• Parents may request full deletion of their child's data at any time by contacting support@lumiore.ai.

8. School Partnerships and Institutional Safety

Where a Student accesses the Platform through a school partnership arrangement, the following additional provisions apply:

• The school acts as an institutional data controller for the purposes of the partnership arrangement and must ensure that appropriate parental consents have been obtained before enrolling students.
• LumiOre will provide school administrators with access to student progress data only to the extent agreed in the institutional partnership agreement.
• Schools are responsible for supervising student use of the Platform in a school setting and for ensuring students comply with this Child Safety Policy.
• LumiOre will cooperate with school administrators in investigating and responding to any child safety concern arising in a school partnership context.

9. LumiOre's Commitment to Continuous Improvement

Child safety is not a static concern. LumiOre is committed to: regularly reviewing and updating this Child Safety Policy and the Platform's safety features; monitoring developments in Singapore's child safety legislation and best practice guidelines, including those issued by the PDPC and the Ministry of Social and Family Development; working with AI technology providers to implement the latest safety guardrails and content moderation capabilities; and training LumiOre staff on child safety awareness, data protection, and appropriate handling of safety reports.

10. Amendments to This Policy

LumiOre reserves the right to amend this Child Safety Policy at any time. Material changes will be communicated to Parent/Guardians via email at least 14 days before they take effect. Continued use of the Platform after the effective date constitutes acceptance of the amended Policy.