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Privacy policy
What personal data we receive, why, how long we keep it, who we share it with and what rights you have.
Last updated: 14 September 2026
We wrote this policy in line with Ukraine’s Law “On Personal Data Protection” (No. 2297-VI). For people in the European Union we also follow the EU General Data Protection Regulation (GDPR).
1. Who is responsible for your data
Luminova Kids is a volunteer education project and is not registered as a legal entity. The controller of personal data is the project’s founder, Dinara Valtova (Lviv, Ukraine). For any question about your data, email luminova.kids@gmail.com.
2. In short
- No sign-up is needed to learn on the site. We collect no data about a child during lessons.
- Lesson progress is stored only in your browser and never reaches us.
- We only receive data when you give it to us: by filling in a form, writing to us or donating.
- We don’t sell data, show ads or use advertising trackers.
3. What data, why, and on what basis
| When | What data | Why | Legal basis | How long we keep it |
|---|---|---|---|---|
| You open the site | IP address, browser type, page address, time — in the technical logs of our host, Cloudflare | To run the site and protect it from attacks | Legitimate interest (site security) | Under Cloudflare’s rules. We don’t use these logs to identify visitors |
| A child does lessons | Marks for completed lessons and topics — in your browser’s storage (localStorage) | To show progress and stars | Necessary for the feature you are using | Until you delete them. Never sent to our servers |
| “Find a tutor” form | Your name; your child’s name; your child’s grade; a Telegram contact (phone number or username) | To match your child with a tutor and contact you | Your consent (Art. 11 of Law No. 2297-VI; Art. 6(1)(a) GDPR) | While your child is having lessons, plus 12 months after the last one. If no match was made — up to 6 months |
| “Become a volunteer” form | Email; first and last name; age; English level; how many students and which grade you want to teach; phone number for Telegram | To review your application, match a student, coordinate lessons and issue a certificate | Your consent; for ages 14–17, also a parent’s consent | While you volunteer, plus 3 years so we can confirm your certificate if asked. If the application isn’t accepted — up to 6 months |
| You write to us | Your name, contact details and message (email, Telegram, Instagram, Facebook) | To reply to you | Your consent; our legitimate interest in answering messages | Up to 12 months after the last message |
| You allow us to publish a review | The review text and a signature without a surname (e.g. “Mother of a student”) | To show the review on the site | Your written consent | Until you withdraw consent |
| You donate | Amount, date, and your name or comment if you add them. Only the bank sees card details | To receive the donation, refund a mistaken payment and report on spending | Carrying out your request; legitimate interest | As the bank requires; our own notes — up to 3 years |
The tutor request form is filled in by a parent or another legal guardian. We don’t accept requests from children without an adult. We don’t ask for or keep photos of children, health data or other special categories of data.
How we match. Form data goes into a private Google Sheet used by coordinators. A script in it suggests a tutor based on the child’s grade, but a coordinator always makes the final decision. We automatically email tutors to confirm their application and, after a match, send them the child’s name, grade and the parents’ contact. Coordinators get notifications about new applications in a private Telegram chat.
4. Who else sees the data
We don’t sell data or share it for advertising. Access is limited to the volunteer coordinators who need it for matching, and to the tutor assigned to a child, who receives the child’s name, grade and a contact for the parents.
We use the following services (they process data on our behalf or as separate controllers under their own policies):
- Google (Google Forms, Google Sheets, Gmail) — forms and email;
- Notion (Notion Labs, Inc.) — our internal database for coordinating matches;
- Telegram — contact with parents and volunteers, and notifications in a private coordinators’ chat;
- Instagram and Facebook (Meta) — if you message us there;
- Cloudflare — website hosting;
- monobank (JSC Universal Bank) — if you donate;
- Quizlet and other exercise services — only when you press a button to load them yourself (see the Cookie policy).
Online lessons take place on a video service agreed between the family and the tutor. We don’t record lessons and ask tutors not to.
We may disclose data only where the law requires it (for example, by court order).
5. International transfers
Google, Notion, Meta and Cloudflare may process data in the United States and other countries. These companies use the safeguards set out in their data processing terms (EU Standard Contractual Clauses and/or certification under the EU–U.S. Data Privacy Framework). By giving consent in a form, you also agree to such transfers (Art. 29 of Law No. 2297-VI).
6. How we protect data
- Only coordinators can open the forms and the database, using personal accounts with two-factor authentication.
- We never publish families’ contact details or forward them to group chats.
- A tutor receives only the data needed to organise lessons.
- When the retention period ends, we delete the data from the forms and the database.
7. Your rights
Under Art. 8 of Law No. 2297-VI (and, in the EU, Arts. 15–22 GDPR) you can:
- find out what data about you we process and get a copy;
- have inaccurate data corrected;
- have your data deleted;
- withdraw consent at any time — this doesn’t affect processing before the withdrawal;
- object to or restrict processing;
- complain to the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua (opens in a new tab)), or, if you are in the EU, to the data protection authority in your country, or to a court.
To use any of these rights, email luminova.kids@gmail.com. We reply within 30 days. To protect your data, we may ask you to confirm your identity.
8. Children
The site is made for children aged 6–10, but no data is needed to learn on it. Forms are filled in by adults. If you find out that a child has sent us their data without their parents knowing, tell us and we will delete it.
Volunteers aged 14–17 join only with their parents’ consent, as required by Ukraine’s Law “On Volunteer Activity”. We may ask for confirmation of this consent.
9. Cookies and browser storage
We don’t set any advertising or analytics cookies ourselves. What is stored in your browser is explained in the Cookie policy.
10. Changes
If we change this policy, we’ll update the date at the top of the page. We will announce significant changes — such as a new service or a new purpose — on the site in advance.