Who the learner experience is for
Ulmio’s learner design covers ages 5–17. Parents manage child profiles; children use a family code, nickname and PIN rather than a separate email account. Creating a profile or PIN is not verifiable parental consent.
Information children may supply
Profiles and practice chats can include nicknames, grades, age bands, messages, titles and activity records. Children may type personal information into conversations even when it is discouraged. Generated content and safety metadata are distinct from information directly supplied by the family. Simulated practice is not the same as no data collection.
External processing and availability
Real child AI and child image generation remain disabled. Any future external child processing requires approved provider disclosures, verified data-handling arrangements and appropriate consent before activation. No provider-retention or training guarantee is made here.
Direct parental notice — preparation only
Before an eligible under-13 collection flow is activated, the parent must receive a direct notice identifying the operator and contacts, data collected, purposes, actual recipients, disclosures, retention and parental choices. This page does not itself deliver or record that notice.
The collection scope and recipient list must be final before consent is requested. Public contact details and a legally reviewed verification method remain pending.
Verifiable parental consent
The amended COPPA Rule requires legal assessment of notice, parental verification, third-party disclosures, security and retention. A checkbox, parent registration or child PIN is not treated as sufficient verification. Separately required disclosure consent must be evaluated for the actual arrangement, including applicable integral-service exceptions.
A proposed workflow is notice → approved verification → scoped consent record → permission enforcement. Withdrawal and material-change re-consent must also be implemented. These are pending requirements, not operational controls; this page activates nothing.
FTC final amended COPPA RuleSafety, parental visibility and limits
Age-aware restrictions, usage controls and screening support the learner experience. They are not continuous human supervision and cannot detect every harmful interaction. Parent access to conversations and creations follows applicable privacy protections; some sensitive disclosures have special handling.
Parental review, deletion and withdrawal
Parents may have rights to review applicable child information, request correction or deletion and withdraw consent. Identity and parental authority must be verified before disclosure. A complete consent withdrawal, request tracking and account closure process remains pending. Deletion cannot be promised as instant or permanent across provider and backup systems.
Visitor analytics
Lovable provides analytics for the published site. Its analytics uses no cookies, stores nothing on the visitor’s device, does not keep IP addresses and does not identify visitors.
It records pages visited, referral sources, country, browser, operating system, device type, time on page, page-load performance, errors and clicks on buttons and links. Clicks are identified by location, not their text. No additional custom product events were identified; application error reporting is included in errors.
There is currently no analytics consent banner. Clicks and the other listed analytics are recorded for every visitor. Page visits, time on page, page speed and errors are recorded without cookies and without identifying anyone. The editor preview is not counted. Detailed data is kept for 90 days; daily summaries for one year.
Lovable’s role
Lovable collects this data for us. Lovable’s privacy policy explains how it handles it. These statements do not mean Ulmio’s accounts and other services store nothing.
Lovable’s privacy policyCompany roles and responsible entity
Ulmio — Powered by UltriumAI. Ulmio is owned and operated by UltriumAI LLC. Hosting and operations: UltriumAI LLC. UltriumAI LLC is legally separate from Ultrium LLC; no division, brand, DBA or subsidiary relationship is asserted.
Owner-confirmed legal identity: UltriumAI LLC, Virginia Limited Liability Company, United States. Virginia Entity ID: 11865834. Updated business principal office and public operator mailing address, approved by the owner for these drafts: 9413 Hull Street Rd, Ste C2, North Chesterfield, VA 23236-1246, United States. Legal sufficiency for the intended disclosures remains subject to review; owner approval is not a regulatory determination. Public support email, privacy email and telephone remain pending. A postal address does not replace required email and telephone disclosures. Required contact disclosures and consent arrangements must be completed and reviewed before affected policies can become effective; the Children's Privacy Notice remains a draft and public-launch blocker.
Future subscription contracting company and payment recipient: UltriumAI LLC. Intended payment processor: Stripe. No new payment service is activated. External AI processors and infrastructure services are distinct from the legal operator and merchant. Policies remain drafts pending legally sufficient contact information, consent arrangements and legal review.