Jinglo Privacy Policy

Effective 2026-10-18.

1. Who is responsible. Jinglo, a Lumen Labs product, is operated by Lumen Labs, an individual, located at Ciudad de Guatemala, Guatemala. For any privacy matter, write to privacidad@lumen-labs.co.

2. What we collect.

• From the buyer: email, country, language, the phone number to call (if the product is a call), and the amount and status of the payment. Your card details are received only by Polar or Recurrente; we never see or store them.
• From the child (children's products): their first name, the optional details the adult enters, and their voice during the call. We do not ask for a surname, school, address or photos of the child in call products.
• From the person who answers a call: if they are not the buyer, their voice during the call only if they press 1 to continue. Before they press 1 we do not record or keep what they say.
• From someone using a practice pass (insurance, citizenship, DOT): email, study progress and, if the practice is by voice, their voice.
• From visiting the site: usage events without a name, voice or phone number (for example, "checkout opened").
• Consent record: the text accepted, its version, the time, the IP address and the payment identifier, so we can prove your authorization.

3. Why we use it. To create, perform and deliver the product you bought, handle support and refunds, prevent fraud and prove your consent. We use the data for no other purpose.

4. What we do not do. We do not sell data. We do not run advertising directed at the child or using their data. We do not train artificial intelligence models with our customers' names, voices, photos or text, and we require the same of the providers we use for this service. We do not create voiceprints. We do not use the phone number for marketing or for any call other than the one you scheduled. No one on the call will ask you for information or sell you anything.

5. Who receives the data to provide the service. See the provider table. All act on our behalf and only for the service, except Polar and Recurrente, which process the payment under their own policies.

6. How long we keep it. See the retention table. Summary: recordings, transcripts, the child's information, the phone number and optional details, 30 days. Uploaded photos, 7 days. The consent record, 4 years. The content-free delivery log, 13 months. The opt-out list (a hash of the number), for as long as needed so we do not call you again.

7. Your rights and how to delete. You can ask us to access your data or your child's, correct it, download it, restrict its use, object to it or delete it, by writing to privacidad@lumen-labs.co or using the link in your receipt. We delete the data in section 6 that has a retention of 30 days or less, including copies at our providers, within 7 days of your request. We answer other requests within 30 days. If you answered a call and did not buy it, you can also ask us to delete your recording. If we need to confirm who you are, we will ask by email to the purchase address, never by phone.

8. Children. Our children's products are always bought and authorized by a parent or guardian. We do not offer accounts to children, we do not ask them for data outside the call, and we do not show them advertising. A parent or guardian can review, delete or tell us to stop using their child's information at any time. We verify that the buyer is an adult through a real card charge.

9. International transfers. Our providers may process data in the United States and other countries. When you are in the European Union, the United Kingdom or Mexico, we process data with the safeguards the applicable law requires.

10. Security. Data travels encrypted, access is limited and recordings are stored with automatic deletion. No system is perfect; if a breach affects you, we will tell you without delay.

11. Analytics and advertising. We measure usage with PostHog without advertising cookies and without identifying people; no name, voice or phone number is sent to PostHog at checkout. If you came from an ad and you allow it (in Spain and the UK only if you press "Accept"; in Mexico unless you press "No, thanks" on the page notice), we measure that ad's result with the Meta Pixel (Facebook and Instagram): Meta receives that you visited the page, started or completed a purchase, your browser identifier and, only on purchase, a hashed version of your email and the amount; never the child's name, age or voice, or your phone number. You can change your choice at any time with the "Advertising preferences" link at the bottom of the page. Where the law requires your permission, no advertising script is loaded without it.

12. Changes. If we change this policy in a way that affects children's data, we will email you first and will not apply the change to existing orders without your permission.

13. Contact. Lumen Labs · Ciudad de Guatemala, Guatemala · privacidad@lumen-labs.co

Providers

Ubicación y garantías de cada proveedor:.

Regla técnica: PostHog nunca recibe nombre del niño, voz, teléfono ni correo. Si el evento lo necesita, se usa un identificador de pedido aleatorio.

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Calls from Santa

Recogemos el primer nombre del niño, los datos opcionales (edad, una afición, un logro, y el nombre de un hermano o mascota si la persona adulta lo escribe), el número a llamar y su voz durante la llamada. La llamada dura 2 a 5 minutos, se graba solo después de que un adulto pulsa 1, y se entrega al comprador por enlace de descarga. Retención: 30 días. Reyes Magos y Papá Noel son personajes folclóricos; no representan a ninguna persona real.

Retention