Privacy Notice — Mili-Maus Family Space
This notice explains how your personal data and your children's data are handled when you use the Mili-Maus family space, whether through the website at app.milimaus.luxxow.com or the Mili-Maus mobile app.
Please read this notice before using the family space. A separate notice on www.mili-maus.lu covers the public website and the visit-enquiry form.
This notice is available in French, English and Portuguese. If the language versions differ, the French version prevails.
1. Who Is Responsible for Your Data
1.1 Controller. Mélanie Afonso, independent homework-support provider, 1 Rue Joseph Müller, L-3651 Kayl, Luxembourg. Email: info@mili-maus.lu. Phone: +352 691 588 314.
1.2 What "controller" means. Mélanie decides what personal data is collected and why. She is responsible under data-protection law for the processing described in this notice.
1.3 Processor and app publisher. The Mili-Maus platform is designed, built and operated by Luxxow S.à r.l.-S, RCS Luxembourg B311306, VAT LU37778165, 12 rue Treeschheck, 3321 Berchem, Luxembourg. Luxxow hosts the service, maintains the software and publishes the mobile app on the Apple App Store on Mélanie's behalf, under a data processing agreement. Luxxow processes your data only on Mélanie's instructions and does not use it for its own purposes.
2. What Data We Process and Why
The tables below list each category of personal data, the purpose, the legal basis under the General Data Protection Regulation (GDPR) and how long we keep it.
2.1 Parent / Guardian Account
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| First name, email address, password (stored only as a secure hash) | Create and secure your account | Art. 6(1)(b) — necessary to perform the service agreement | Duration of the service relationship, then deleted within 1 year of your last child's final session |
| Preferred language | Display the app in your language | Art. 6(1)(b) | Same as account |
| Notification preferences (opt-outs) | Respect your communication choices | Art. 6(1)(b) | Same as account |
| Session token (stored as a hash on the server; stored in your device's secure storage or as a secure cookie) | Keep you signed in | Art. 6(1)(b) | 7 days, then automatically expires |
2.2 Family Profile
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Family name | Identify your family in the system | Art. 6(1)(b) | Duration of the service relationship plus 1 year |
| Address, postcode, city, country, contact email, contact phone (all optional) | Contact your family and, if applicable, issue invoices | Art. 6(1)(b) | Same as family profile |
| Guardian permissions (which children and communications each guardian may see) | Ensure each guardian sees only what they are authorised to see | Art. 6(1)(b) | Same as family profile |
Your family profile is visible only to the provider (Mélanie and her staff). Other families cannot see it.
2.3 Children's Data
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| First name, last name | Identify the child in sessions and communications | Art. 6(1)(b) — necessary to perform the homework-support service agreed with the parent/guardian | Duration of the service relationship plus 1 year |
| Date of birth (optional, entered by the provider) | Age-appropriate session management | Art. 6(1)(b) | Same; date of birth is not visible to parents in the app |
| Active or archived status | Track whether the child currently attends | Art. 6(1)(b) | Same; archiving retains the record |
| Session schedule, bookings, attendance status (confirmed, requested, absent, cancelled) | Manage regular sessions, extra-place requests and attendance | Art. 6(1)(b) | Same |
Important points about children's data:
- Children never create accounts or sign in. All children's data is entered by the provider.
- No photographs, school details, health information, allergy information or free-text notes about children are collected or stored.
- Absences are recorded as a status only. No reason for the absence is stored.
- The legal basis is the service contract with you, the parent or guardian. Because children do not use the service directly (they have no accounts), parental consent under GDPR Article 8 is not required.
2.4 Communications
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Shared family conversation messages (up to 2,000 characters each) and read receipts | Communication between the provider and all guardians in the family | Art. 6(1)(b) | Duration of the service relationship plus 1 year |
| Private conversation messages (up to 2,000 characters each) between the provider and one guardian | Confidential communication | Art. 6(1)(b) | Same |
| Announcements by the provider (up to 4 languages) | Service updates sent to all or selected families | Art. 6(1)(b) | Same |
| Meeting requests with a message (up to 500 characters) | Schedule meetings between a guardian and the provider | Art. 6(1)(b) | Same |
| In-app notifications (recipient, child reference, type) | Alert you to relevant updates | Art. 6(1)(b) | Same |
Please do not include medical, health or other sensitive information in messages or meeting requests. The service is not designed to process this type of data. If you do include it, it will be stored as part of the message, but we have no obligation to process it and may ask you to provide it through other means.
2.5 Billing and Invoices
Billing features are available but may not be active for your account. When active:
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Payer assignment (which guardian pays for which child and their share) | Determine who receives invoices | Art. 6(1)(b) | Duration of the service relationship plus 10 years for invoicing records |
| Invoice recipient name and address | Issue invoices | Art. 6(1)(b) and Art. 6(1)(c) — legal obligation to maintain accounting records | 10 years from the end of the financial year in which the invoice was issued (Luxembourg accounting law) |
| Session details (minutes, amount), invoice lines, totals, issue date | Calculate and document charges | Art. 6(1)(b) and Art. 6(1)(c) | 10 years (same) |
| Payments, refunds and adjustments (recorded manually with a free-text reference) | Track payment status | Art. 6(1)(b) and Art. 6(1)(c) | 10 years (same) |
No bank account details, card numbers or payment-processor data are collected or stored. No invoices are sent by email; you view them in the app.
2.6 Audit History
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Actor, action and details for sensitive changes (child and family edits, archiving, invitations, account suspension, password resets, guardian-permission changes, booking changes, billing changes) | Security, accountability and dispute resolution | Art. 6(1)(f) — legitimate interest in maintaining the integrity and security of the service | 3 years |
Audit records may include a child's name before and after an edit. They do not record your IP address or device.
2.7 Device and Technical Data
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Push-notification token and platform (when push notifications are enabled) | Deliver notifications to your device | Art. 6(1)(b) | Until you sign out or the token expires |
| Web-server access logs (IP address, requested URL, date, browser type) | Operate and secure the service | Art. 6(1)(f) — legitimate interest in security and troubleshooting | 30 days |
Push-notification messages are always generic (for example, "new information in your Mili-Maus account"). They never contain children's names or message content.
3. Cookies and Device Storage
The family space uses only strictly necessary storage:
| Where | Name | What it does | Duration |
|---|---|---|---|
| Web app | mm_session (cookie) | Keeps you signed in (HttpOnly, Secure, SameSite=Strict) | 7 days |
| Web app | mm-language (local storage) | Remembers your chosen language | Until you clear it |
| Web app | Service-worker cache | Stores an offline page and the logo only; never personal data | Until updated |
| Mobile app | milimaus.session.v1 (secure storage) | Sign-in token | 7 days |
| Mobile app | milimaus.language (secure storage) | Chosen language | Until you remove the app |
No advertising, analytics or tracking cookies are used. No consent banner is required because all storage is strictly necessary for the service to function.
4. Who Receives Your Data
Your data is accessible to:
- Mélanie Afonso (and any staff she authorises), as the service provider.
- Luxxow S.à r.l.-S, as the platform operator and processor, under a data processing agreement. Luxxow's staff access data only for technical support, maintenance and security purposes.
- Sub-processors engaged by Luxxow to operate the service:
Provider Service Data involved Location Hostinger Server hosting (VPS), database, backups All data described in this notice Germany (EU) MXroute (QuickPacket infrastructure) Sending invitation, password-reset and notification emails Recipient email, name, links (no children's data or message content) United States (Ashburn, Virginia) Let's Encrypt TLS certificates for encrypted connections No personal data — When push notifications are activated:
Provider Service Data involved Location Expo (push relay) Routing notifications to Apple and Google Device token, generic notification text United States Apple Push Notification Service (APNs) Delivering notifications to iOS devices Device token, generic notification text United States Google Firebase Cloud Messaging (FCM) Delivering notifications to Android devices (when available) Device token, generic notification text United States - Your own device and calendar. If you add a booking to your personal calendar from the app, the child's first name appears in the calendar event title. That data then follows your calendar provider's own terms (for example, Apple iCloud or Google Calendar). This action is initiated by you; we do not send data to your calendar provider.
- No other recipients. We do not sell, rent or share your data with advertisers, analytics providers or any other third party.
5. International Data Transfers
Your data is hosted on servers in Germany (European Union). Some service providers are located in the United States, outside the European Economic Area:
- MXroute (United States). MXroute processes only outbound service emails (recipient email, name and links). No children's data or message content is sent through MXroute. The transfer is protected by Standard Contractual Clauses (SCCs) between Luxxow and MXroute, supplemented by the limitation of data to non-sensitive identifiers and the use of TLS encryption in transit.
- Expo, Apple APNs, Google FCM (United States, when push notifications are active). These US-based services process only device tokens and generic notification text — never children's names or message content. Apple and Google maintain certification under the EU-US Data Privacy Framework. Expo transfers are protected by Standard Contractual Clauses.
No children's names, message content or family details are transferred outside the EU.
6. Your Rights
Under the GDPR, you have the right to:
- Access your personal data and receive a copy of it.
- Rectify inaccurate data. You can change your language in the app. To correct your name, email or any other data, contact us.
- Erase your data ("right to be forgotten"). See section 7 below.
- Restrict processing in certain circumstances.
- Object to processing based on legitimate interest (audit logs and server logs).
- Data portability — receive data you provided to us in a structured, commonly used format.
- Withdraw consent at any time, where processing is based on consent. Currently, no processing in the family space relies on consent.
To exercise any of these rights, contact Mélanie Afonso at info@mili-maus.lu. We will respond within one month.
Complaint. You also have the right to lodge a complaint with the Commission nationale pour la protection des données (CNPD), 15 Boulevard du Jazz, L-4370 Belvaux, Luxembourg — www.cnpd.lu.
7. Account Deletion and Erasure
You may request deletion of your account and all associated personal data by contacting info@mili-maus.lu or by using the account-deletion feature in the app, when available.
When we delete your account:
- Your account, profile, messages, notifications, session data and your children's records (names, schedules, attendance, bookings) are permanently deleted.
- Invoices and financial records cannot be deleted before the end of the 10-year legal retention period required by Luxembourg accounting law. During this period, these records are retained in a form limited to what is legally required. After the retention period expires, they are deleted.
- Audit-log entries referencing your account or your children may be retained for up to 3 years for security and accountability purposes, after which they are deleted.
- Backups may contain a copy of your data for up to 30 days after deletion, after which the backup cycle overwrites it.
If your family includes other guardians, deletion of your account does not delete the family profile or children's records that other guardians still need. Only data specific to your account is removed.
8. Children's Rights
As a parent or guardian, you may exercise data-protection rights on behalf of your children. To request access to, correction of or deletion of your child's data, contact info@mili-maus.lu.
When a child's record is archived (because the child no longer attends), the data is retained for 1 year and then deleted, unless invoicing records must be kept longer (see section 2.5).
9. Security
We take the following measures to protect your data and your children's data:
- All connections use HTTPS encryption (TLS 1.2/1.3). Non-encrypted connections are refused.
- Passwords are hashed with a strong algorithm (scrypt) and are never stored in readable form.
- Session tokens and invitation links are stored only as hashes, are single-use (invitations) and expire automatically.
- Access controls enforce strict role-based and family-based permissions on the server. Each guardian sees only the children and communications they are authorised to access.
- The mobile app hides screen content when the app goes to the background, preventing previews in the app switcher.
- Sensitive administrative actions are recorded in an audit trail.
- Owner and staff accounts may use passkeys (WebAuthn) for additional sign-in security.
10. Changes to This Notice
If we make material changes to this notice, we will notify you through the app or by email before the changes take effect. The current version is always available at www.mili-maus.lu/privacy/.
11. Contact
For any question about this notice or about how your data is handled:
Mélanie Afonso1 Rue Joseph Müller, L-3651 Kayl, Luxembourg
info@mili-maus.lu
+352 691 588 314