1. Who Is Collecting Your Data
LumiOre LLP ("LumiOre") is the data controller responsible for Personal Data collected through the LumiOre AI Learning Platform ("the Platform"). LumiOre is registered in Singapore and operates in compliance with the Personal Data Protection Act 2012 (PDPA), as amended by the Personal Data Protection (Amendment) Act 2020.
| Registered Address | LumiOre LLP, 60 Paya Lebar Road, #07-54, Paya Lebar Square, Singapore 409051 |
|---|---|
| Data Protection Contact | support@lumiore.ai |
| PDPC Registration | [PDPC Reference: XXXXXXXX] |
2. What Personal Data We Collect at Registration
When a Parent/Guardian registers an account on behalf of a Student, LumiOre collects:
| From the Parent/Guardian | Full name, email address, contact number, password (encrypted) |
|---|---|
| From the Student (via Parent) | First name, date of birth or age, school name, year level, subjects enrolled |
| Payment data | Processed by our third-party payment gateway. LumiOre does not store full card details. |
3. What Personal Data We Collect During Use
As the Student uses the Platform, we collect and generate:
| Uploaded papers | Images or PDFs of test papers, worksheets, and past papers, which may contain the Student's name, class, answers, and working. |
|---|---|
| Learning Profile | AI-generated analysis of the Student's knowledge gaps, habit patterns, and learning persona. |
| Practice data | Answers to practice questions, session scores, and completion records. |
| AI chat logs | Records of conversations between the Student and the AI learning chat. Visible to Parent/Guardians via the Parent Dashboard. |
| Technical data | IP address, browser type, device type, session identifiers, and usage logs. |
4. Why We Collect This Data
LumiOre collects Personal Data only for the following purposes:
- To provide the AI-powered learning and analysis services described in the Terms of Service.
- To build and maintain the Student's personalised Learning Profile.
- To generate targeted practice questions and adaptive teaching content.
- To operate the Parent Dashboard and provide progress reports.
- To process Subscription payments and manage accounts.
- To communicate with Parent/Guardians about the Platform.
- To ensure the safety and security of the Platform.
- To comply with our legal obligations under Singapore law.
LumiOre will not use your Personal Data for advertising, marketing profiling, or sale to third parties.
5. Who We Share Your Data With
| AI service provider | Student inputs are processed by our AI technology partner to generate responses. This partner is contractually prohibited from using Student data for its own purposes. |
|---|---|
| Payment processor | Payment data is shared with our third-party payment gateway for billing and refund processing. |
| School administrators | Progress data may be shared with authorised school administrators under a school partnership arrangement, with your prior consent. |
| Regulatory authorities | Data may be disclosed to the PDPC or other authorities where required by law. |
| Business successors | In the event of a merger or acquisition, data may be transferred to a successor entity with prior notice. |
6. Cross-Border Data Transfers
Your Personal Data may be processed on servers located outside Singapore, including in the United States, where our AI service provider is headquartered. LumiOre ensures that all cross-border transfers comply with the PDPA's data transfer obligations and that recipient organisations provide a comparable level of data protection.
7. How Long We Keep Your Data
LumiOre retains Personal Data for the following periods: account and registration data — duration of the active Subscription and 1 year following account closure, then deleted; Student Learning Profile and usage data — duration of the active Subscription and 1 year following account closure, then anonymised or deleted; Uploaded Content (paper images and PDFs) — duration of the active Subscription only, securely deleted upon Subscription expiry or cancellation; AI chat logs — duration of the active Subscription and 1 year following account closure, then deleted; payment records — 7 years from the date of transaction as required by Singapore's accounting and tax laws. You may request deletion of your data by contacting support@lumiore.ai.
8. Your Rights Under the PDPA
As a data subject (or Parent/Guardian acting on behalf of a minor), you have the right to:
- Access the Personal Data LumiOre holds about you or your child.
- Correct any inaccurate or incomplete Personal Data.
- Withdraw consent to data processing at any time (note: this may affect your ability to use the Platform).
- Request data portability in a machine-readable format (PDPA 2020 amendment).
- Lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.
To exercise any of these rights, please contact support@lumiore.ai. LumiOre will respond within 30 days.
9. Consent for Minors
In accordance with Section 26 of the PDPA, consent for the collection, use, and disclosure of a Student's Personal Data is obtained from the Parent/Guardian, not the minor Student. LumiOre will not treat a minor's independent consent as a valid basis for processing their Personal Data.
For students under the age of 13, LumiOre applies enhanced data minimisation practices and may request documentation to verify the identity of the consenting Parent/Guardian.
10. How to Contact Us
For all data protection queries, access requests, corrections, or complaints:
| support@lumiore.ai | |
| Post | LumiOre LLP, 60 Paya Lebar Road, #07-54, Paya Lebar Square, Singapore 409051 |
| PDPC (Singapore regulator) | www.pdpc.gov.sg | 1800-CALL-PDPC (1800-2255-7372) |
This Notice should be read alongside LumiOre's full Privacy Policy, which is available on the Platform. In the event of any inconsistency, the full Privacy Policy prevails.