Effective Date: 2026-07-29
Last Updated: 2026-07-29
Company: Fiatos LLC
Address: Fiatos LLC, 1500 N Grant St, Ste N, Denver, CO 80203
Privacy Contact: privacy@fiatos.ai
1. Introduction
This Privacy Policy describes how Lucid ("we," "us," or "our") collects, uses, and protects information when you or your child uses the Lucid adaptive e-reader application ("Lucid" or the "Service"). Lucid is an AI-powered adaptive e-reader designed for K-12 students that adjusts reading content in real time to match each student's reading level.
We are committed to protecting the privacy of children who use Lucid. We comply with the Children's Online Privacy Protection Act (COPPA), the Family Educational Rights and Privacy Act (FERPA), the Student Online Personal Protection Act (SOPIPA), and applicable state student privacy laws.
This policy is specific to the Lucid product. It is written in plain language so that parents, guardians, and school administrators can understand our data practices.
2. How Lucid Works — Two Contexts
Lucid operates in two contexts with different data controllers:
- Family (Consumer) Context. Parents create accounts and manage child reading profiles for home use. The parent is the account holder. Data collected in this context is governed by COPPA and this privacy policy. The parent is the controller of family-context data.
- School (Institutional) Context. Schools and districts deploy Lucid via Clever SSO for classroom reading. Data collected in this context is governed by FERPA, the applicable Data Privacy Agreement (DPA) between the school district and Lucid, and applicable state student privacy laws. The school or district is the controller of school-context data.
A single child may use Lucid in both contexts. Their reading profile is portable — no data is duplicated. Each reading event is tagged with a `data_source` label (`family`, `school`, or `anonymous`) so that ownership and governing law are always clear.
3. Information We Collect
3.1 Information We Collect
| Information | Purpose | Context |
|---|---|---|
| Parent email address | Account authentication via magic link; COPPA consent record | Family |
| Child display name | Profile identification (this is not the child's legal name) | Family and School |
| Child grade level | Reading level calibration | Family and School |
| Child birth month and year | Age verification for COPPA compliance | Family |
| Reading session data | Adaptive engine input and reading progress tracking | Family and School |
| Word-level performance statistics | Vocabulary mastery tracking and adaptive difficulty | Family and School |
| Book interaction data | Content recommendations and progress tracking | Family and School |
3.2 Information We Do NOT Collect
We do not collect the following information from children or parents:
- Child legal name (display name is sufficient)
- Child date of birth day (only month and year are collected)
- Child email address (children under 13 do not hold accounts)
- Device fingerprints or persistent device identifiers
- Location data (GPS or IP-based geolocation)
- Photos, videos, or images of children
- Biometric data (see Section 10 for future audio policy)
- Social graphs, friend lists, or contact lists
- Behavioral advertising profiles
4. How We Use Information
We use the information we collect solely to provide and improve the Lucid reading experience:
- Adaptive reading. Reading session data and word-level statistics power the adaptive engine that personalizes content difficulty for each child.
- Progress tracking. Parents and teachers can view reading progress and vocabulary growth.
- Account management. Parent email addresses are used for authentication and communication about the account.
- Service improvement. We may use de-identified, aggregated data from the family context only to improve Lucid. School-context data (tagged `data_source = school`) is excluded from all product improvement, ML training, and cross-tenant analytics by default. Any use of school-context data for product improvement requires explicit, per-DPA written authorization from the school district and is logged.
We never use information to:
- Display advertisements of any kind
- Create behavioral advertising profiles
- Target or serve advertising to children
- Sell data to third parties
- Share data with data brokers
- Build profiles for non-educational purposes
5. How We Share Information
We share personal information only with service providers ("sub-processors") that are necessary to operate Lucid:
| Sub-Processor | Purpose | Data Accessed |
|---|---|---|
| Email service (Resend or AWS SES) | Delivering magic-link authentication emails to parents | Parent email address only |
| Cloud database hosting (Cloud SQL / Supabase) | Database storage | All application data (encrypted at rest) |
| Hosting provider (Cloud Run / Vercel) | Application hosting | Transient request data |
| Clever (Clever Inc.) | SSO and roster sync for school context | Student display name, grade, classroom roster |
Confirm sub-processor DPA status with each provider before publication.
We do NOT share data with:
- Advertising networks
- Data brokers
- Social media platforms
- Any third party for non-educational commercial purposes
6. Parental Consent (COPPA Compliance)
Lucid is directed at children under 13. We obtain verifiable parental consent before collecting any child's personal information in the family context using the email-plus method approved by the FTC:
- The parent provides their email address during account creation.
- A magic link is sent to the parent's email. Clicking the link creates the parent's authenticated session.
- A 24-hour delayed follow-up confirmation email is sent to the same address, confirming that a child profile was created and providing instructions to opt out.
- If the parent does not confirm or opts out within 24 hours, the child profile data is deleted.
In the school context, consent is delegated to the school under the FERPA "school official" exception (34 CFR Section 99.31(a)(1)). The DPA between Lucid and the school district serves as the consent instrument.
7. Parental Rights
Parents have the following rights regarding their child's information:
- Review. View your child's reading progress, word statistics, and activity history through the parent dashboard.
- Correct. Edit your child's display name and grade level through the parent dashboard. For other corrections, contact us at privacy@fiatos.ai.
- Delete. Delete your child's profile from the parent dashboard. This removes all family-context data within 30 days. See Section 8 for details.
- Revoke consent. Deleting your child's profile revokes consent and removes all family-context data. School-context data is governed by the school's DPA and is not affected by parental consumer-consent revocation.
8. Data Retention and Deletion
| Data Category | Retention Period | Deletion Trigger |
|---|---|---|
| Raw reading events | 90 days from creation | Automatic expiration |
| Aggregated word statistics | Duration of subscription plus 1 year | Account deletion or subscription end plus 1 year |
| Parent account data (email) | Duration of account plus 30 days | Account deletion request |
| Child profile data | Duration of account plus 30 days | Account deletion request |
| Voice/audio data (future) | Processed and discarded within 24 hours | Automatic; never persisted without enhanced parental consent |
| School-context events | Per DPA terms (typically end of school year plus 60 days) | DPA expiration or district deletion request |
Confirm retention periods with legal counsel before publication.
Deletion by Context
- Family-context deletion. Removes all rows tagged `data_source = family` and the child's profile. School-context events are unaffected.
- School-context deletion. Upon written district request, removes rows tagged `data_source = school` scoped to the requesting district's classrooms within 30 days. The child's profile and family-context data are unaffected.
- Full account deletion. Upon parent request, removes all data across all contexts within 30 days.
9. Data Security
We protect information using the following technical safeguards:
- Encryption in transit. All communication between your device and Lucid is encrypted using TLS 1.2 or higher (HTTPS enforced).
- Encryption at rest. All data stored in our database is encrypted at rest using AES-256 encryption via our cloud database provider.
- Tenant isolation. Lucid uses a shared PostgreSQL database with row-level security (RLS) policies. Every data row carries a `tenant_id` that enforces isolation between school districts. A query scoped to one tenant cannot access another tenant's data.
- Data source isolation. Every reading event carries a `data_source` tag (`family`, `school`, or `anonymous`). School-context data is excluded from the default family/ML read path.
- Access controls. Role-based access control (RBAC) limits who can access what data. Teachers see only their classroom's school-context reading data.
- Authentication. Magic-link tokens are single-use, expire after 15 minutes, and are stored as SHA-256 hashes (never in plaintext).
10. Future Voice/Audio Data
Lucid does not currently capture voice or audio data. If oral reading fluency features are added in the future:
- Audio will be processed and discarded within 24 hours.
- Audio will never be stored or persisted without enhanced parental consent (beyond email-plus).
- This policy will be updated before any audio features are released.
We are disclosing this proactively, even though no audio features exist today, so that parents are informed about our plans and commitments.
11. Breach Notification
The following breach notification timelines are draft. Confirm with legal counsel before publication.
In the event of a data breach:
- Parents (COPPA). We will notify affected parents via email within 72 hours of a confirmed breach, describing the nature of the breach, the data affected, and remediation steps.
- Schools/Districts (FERPA). We will notify affected districts within 24 hours of a confirmed breach, per DPA terms.
- Regulators. We will notify the FTC and applicable state attorneys general as required by law. Colorado law (CRS Section 6-1-716) requires notification within 30 days.
12. Changes to This Policy
We will notify all account holders by email before making material changes to this privacy policy. Changes will not take effect until at least 30 days after notification. The "Last Updated" date at the top of this page will always reflect the most recent revision.
13. Contact Us
If you have questions about this privacy policy or our data practices, please contact us:
Privacy Contact: privacy@fiatos.ai
Company: Fiatos LLC
Address: Fiatos LLC, 1500 N Grant St, Ste N, Denver, CO 80203
Product Website: https://adaptive-e-reader.truittlabs.ai
Privacy Policy URL: https://adaptive-e-reader.truittlabs.ai/privacy
Terms of Service URL: https://adaptive-e-reader.truittlabs.ai/terms