Updated May 2026
This Children's Privacy Policy outlines our practices with respect to the personal data of children. We understand the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 16 or the equivalent age as specified by law in your jurisdiction ("Children" or "Child"). That is why Luminary ROLI Ltd ("we"/"us"/"ROLI") has implemented additional processes and protections to help keep Children's personal data safe.
We support the General Data Protection Regulation and the UK GDPR (together, the "GDPR"), APPI and are compliant with the Children's Online Privacy Protection Act ("COPPA"). Our goal is to minimize the information gathered from and disseminated about Children while permitting them active participation in the Platform. ROLI does not knowingly collect, use or share personal data from Children unless we obtain verifiable parental consent. This Children's Privacy Policy, and any verifiable parental consent obtained under it, apply both to a Child's use of the ROLI Learn app and to a Child's use of ROLI websites (including roli.com) accessed while signed in to a child account.
ROLI's LLM-based generative AI and related software, tools, services, documentation, content, functionalities and features that we make available (collectively, "AI Music Coach” are prohibited from use if you are prohibited from receiving our services or software under applicable laws and/or by minors under the age of 17 (or such greater age required in your country or territory, such as 18 years of age in Japan) – unless consent has been obtained from a parent or guardian. Where a parent or legal guardian has consented to a Child’s use of AI Music Coach, this Children’s Privacy Policy applies to the processing of that Child’s personal data through the AI Music Coach feature. In support of this policy, on all family plan subscriptions, it is only the admin user (Adult) who can elect to turn on the AI Music Coach feature for the other users (other adults as well as children) via the app’s settings. By default, the feature is only toggled on for the admin user and is toggled off for all other users on the plan.
Account set up:
Consistent with the requirements of the GDPR and exceeding the requirements of COPPA, in any instance where we ask for age and determine the user is below the age of 18 in Japan, or Children aged 16 or under anywhere else in the world, for certain ROLI services and products, we will obtain verifiable parental consent before the Child may use such ROLI products and services. In those cases, if a Child wants to register to create an account to use the Platform, we require the Child to submit the following information so we can obtain verifiable parental consent:
Direct Notice:
After we obtain such information, we will send the parent a direct notice. In the direct notice, we will explain what information we are collecting and how it may be disclosed, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent's contact information and any other information collected from the child in connection with that activity. If you believe your child is participating in an activity that collects personal data and you or another parent/guardian have NOT received an email providing notice seeking your consent, please feel free to contact us via our support page. We will not use parent emails provided for parental consent purposes to market to the parent unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact
Collection and use of Children's information for internal purposes:
ROLI only uses your Child's information for providing and improving our Platform, including;
ROLI does not share Children' s personal data with any third parties except to the extent it is required to share with our data processors under the duty of confidentiality in order to provide the Platform and for no other purposes, as permitted by law in order to comply with legal obligations or to protect the rights and safety of ROLI and its customers. ROLI takes all steps reasonably necessary to ensure that children's data is treated securely, with adequate protections when engaging processors on our behalf.
Where AI Music Coach has been enabled by a parent or legal guardian, voice recordings, natural language prompts, and other content submitted by the Child to the AI Music Coach feature, together with any output generated in response. Such content may be transmitted to a third party large language model provider for processing requirements essential to the feature.
Limited Users:
ROLI offers only a limited version of the Platform for certain ROLI products and services for children under the age of 18 who are located in Japan (where parent or guardian consent has been obtained), or children under the age of 16 who are located anywhere else in the world (collectively called "Limited Users"). This limited version of the Platform restricts certain features and options to ensure that ROLI does not collect any personal data from the Limited User other than as provided for in this paragraph. Except in the case of responding to a specific request to register or support ROLI products from a Limited User, as more fully described below, ROLI does not collect or store any personal data from such Limited Users, apart from a persistent identifier that is used only for support of the internal operations of the ROLI Platform. The persistent identifier is not used or disclosed to contact the Limited User, including through behavioral advertising; to amass a profile on the Limited User; or for any other purpose other than internal operations. Internal support operations include the following:
In the event a Limited User wants to register their ROLI products to use ROLI software or has a support query, then, upon request from the Limited User, ROLI may collect the Limited User's email address, and that Limited User's parent's or guardian's email address. ROLI will then send the parent or guardian notice and an opportunity to opt-out of the collection of the Limited User's email address. ROLI will only use the Limited User's email address in order to respond to their specific request to register ROLI products. The Limited User's email address will not be used for any other purpose and will not be disclosed or combined with other information. ROLI does not collect any other personal data from a Limited User except as described in this Privacy Policy. As a parent or guardian of a Limited User, you may opt-out of allowing ROLI to collect the Limited User's email address, which will opt them out of the service, by following the link in the notice you receive from ROLI, or otherwise by contacting ROLI through our support page.
ROLI does not share Limited Users' personal data with any third parties, except to the extent it is required to share with our data processors under the duty of confidentiality in order to provide the Platform, in order to comply with legal obligations or to protect the rights and safety of ROLI and its customers. ROLI takes all steps reasonably necessary to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf.
If you are a parent or guardian of a Limited User and become aware that your child has provided personal data to us other than as provided in this privacy policy, or otherwise want to opt-out of ROLI's limited use of your child's email address, please contact us via our support page.
C. Use of ROLI websites while signed in. Where a child account is used to access a ROLI website, including roli.com, while signed in, we identify the session as a child account session. On those sessions we do not operate advertising or analytics tracking technologies, including the third-party pixels and tags described in our Cookie Policy. Only technologies strictly necessary to operate the website securely, such as sign-in and security functions, are used. This treatment applies regardless of the cookie preferences selected on the website.
Questions, comments and requests regarding this privacy policy are welcomed and should be sent via our support page.
If you are a customer in Japan, additional information required under the Act on Specified Commercial Transactions (特定商取引に関する法律) is available in our ASCT Notation, which can be accessed here.