Privacy Policy

1. Introduction

LumiOre LLP ("LumiOre", "we", "us", or "our") is committed to protecting the privacy and Personal Data of all users, with particular care for the protection of children's data. This Privacy Policy applies to all products, services, and websites operated by LumiOre and sets out how we collect, use, disclose, retain, and protect Personal Data in accordance with the Personal Data Protection Act 2012 of Singapore (PDPA), as amended by the Personal Data Protection (Amendment) Act 2020.

We recognise that the Platform is used by children aged 6 to 16. We take our obligations in respect of children's data with the utmost seriousness and have designed our data practices with child privacy as a foundational principle.

2. Who We Are and How to Contact Us

LumiOre is the data controller for Personal Data collected through the Platform.

LumiOre has designated a Data Protection Officer (DPO) in accordance with the PDPA. All data protection queries, access requests, correction requests, and withdrawal of consent notices should be directed to support@lumiore.ai.

3. Categories of Personal Data We Collect

3.1 Parent/Guardian Registration Data

When a Parent/Guardian creates an account, we collect: full name; email address; contact telephone number; account password (stored in encrypted form).

3.2 Student Profile Data

To personalise the learning experience, we collect: Student's first name (or preferred name); date of birth or age range; school name and year/level (Primary or Secondary); subjects enrolled (Maths and/or Science).

3.3 Uploaded Content Data

When a Parent/Guardian uploads a test paper, worksheet, or past paper, the uploaded file may contain the Student's name, class, and school; the Student's handwritten or typed answers, working steps, and methods; marks, scores, and teacher comments (if marked); and examination or worksheet content owned by schools, publishers, or the Ministry of Education.

LumiOre processes Uploaded Content solely to provide the AI analysis and learning services. We do not use Uploaded Content to train AI models without obtaining separate, explicit parental consent.

3.4 Learning Profile and Usage Data

As the Student uses the Platform, we generate and collect: the Student's AI-generated Learning Profile (knowledge gaps, habit patterns, learning persona); practice question attempts and scores; session duration, features accessed, and frequency of use; AI learning chat logs (accessible to Parent/Guardians via the Parent Dashboard); Parent Dashboard interactions and report views.

3.5 Payment Data

Subscription payments are processed through a third-party payment gateway. LumiOre does not store full credit or debit card numbers. We retain transaction records (amount, date, plan) for accounting and legal compliance purposes.

3.6 Technical and Device Data

We automatically collect: IP address and approximate geographic location; browser type and version; operating system and device type; session identifiers; pages and features accessed, and time of access; cookie identifiers (see our Cookie Policy for full details).

3.7 Communications Data

We retain records of communications between you and LumiOre, including support emails, feedback submissions, and any reports made regarding AI-generated content.

4. How We Use Personal Data

LumiOre processes Personal Data only for the following purposes:

• Providing the Platform — delivering AI analysis, generating Learning Profiles, producing practice questions, operating the AI learning chat, and maintaining the Parent Dashboard.
• Account management — creating and managing user accounts, authenticating users, and processing Subscription registrations.
• Payment processing — billing Parent/Guardians for active Subscriptions and processing refunds.
• Personalisation — tailoring the learning experience to the Student's profile and adapting AI-generated content to their identified learning persona and needs.
• Communications — sending Subscription confirmations, renewal notices, product updates, and responding to support enquiries.
• Safety and security — detecting, preventing, and addressing fraud, security breaches, and misuse of the Platform.
• Service improvement — conducting anonymised analytics to understand Platform usage and improve features. No individual student data is used in identifiable form for this purpose.
• Legal compliance — fulfilling obligations under the PDPA, tax laws (including the Goods and Services Tax Act), and any other applicable Singapore legislation.

LumiOre will not use Personal Data for purposes beyond those listed above without obtaining your prior consent.

5. Consent and Legal Basis for Processing

5.1 Consent from Parent/Guardian

In accordance with Section 26 of the PDPA, LumiOre obtains consent for the collection, use, and disclosure of a Student's Personal Data from the Parent/Guardian, not from the minor Student. LumiOre will not treat a minor's consent as a valid basis for processing their Personal Data.

5.2 Children Under 13

For students under the age of 13, LumiOre applies enhanced data minimisation practices and requires verifiable parental consent. LumiOre may request documentation to confirm the identity and relationship of the consenting Parent/Guardian. The collection of data from children under 13 is limited to the minimum necessary to provide the educational services requested.

5.3 Withdrawal of Consent

A Parent/Guardian may withdraw consent for the processing of their child's Personal Data at any time by contacting support@lumiore.ai. Please note that withdrawal of consent may result in LumiOre being unable to continue providing the Services and may necessitate account closure. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5.4 Legitimate Interests

LumiOre may also process certain Personal Data on the basis of its legitimate business interests (such as fraud prevention and security), provided that such interests are not overridden by the rights and interests of the data subject.

6. Sharing and Disclosure of Personal Data

LumiOre does not sell, rent, or trade Personal Data. We disclose Personal Data only in the following limited circumstances:

6.1 AI Service Providers

LumiOre uses third-party AI technology to power the Platform's core features. Inputs submitted to the Platform are processed by the AI service provider to generate responses. LumiOre has contractual arrangements with its AI service providers that prohibit them from using Student data for their own purposes, including AI model training, without LumiOre's separate explicit consent.

6.2 Payment Processors

Payment data is shared with our third-party payment gateway solely for the purpose of processing Subscription transactions and refunds.

6.3 School Partnerships

Where a Student accesses the Platform through a school partnership arrangement, LumiOre may share the Student's progress data and Learning Profile with authorised school administrators, subject to the terms of the institutional agreement and in accordance with the consent provided at registration.

6.4 Legal Requirements

LumiOre may disclose Personal Data where required to do so by applicable law, regulation, court order, or enforceable request from a competent authority, including the Personal Data Protection Commission (PDPC) of Singapore.

6.5 Business Transfers

If LumiOre undergoes a merger, acquisition, restructuring, or sale of assets, Personal Data may be transferred to a successor entity. LumiOre will provide prior notice to affected users and ensure that the successor entity is bound by obligations no less protective than those in this Privacy Policy.

6.6 Default Visibility

By default, no Student information is visible to other users of the Platform. The Platform does not support user-to-user communication or data sharing between unrelated accounts. School partnership accounts may have visibility settings specific to the institutional arrangement.

7. AI Processing of Student Data

7.1 How AI Processes Student Data

When a Student interacts with the Platform, their inputs — including uploaded papers, practice answers, and chat messages — are transmitted to LumiOre's AI service provider to generate responses and analyses. This processing is necessary to deliver the personalised learning features of the Platform.

7.2 No Use for AI Training Without Consent

LumiOre implements safeguards to ensure that Student inputs and Personal Data are not used to train third-party AI models without separate, explicit, written parental consent. Parents who do not wish their child's data to be used in any capacity for AI improvement beyond the delivery of the Services should contact support@lumiore.ai.

7.3 AI Chat Logs

AI learning chat sessions are logged and retained as part of the Student's usage record. These logs are accessible to the Parent/Guardian via the Parent Dashboard and are subject to LumiOre's standard data retention practices as described in Section 9.

8. Cross-Border Data Transfers

LumiOre processes Personal Data primarily on servers located in Singapore. Some Personal Data — specifically data submitted for AI analysis — may be processed on servers located outside Singapore, including in the United States, where LumiOre's AI service provider is headquartered. LumiOre ensures that all cross-border data transfers comply with the PDPA's transfer limitation obligations, including by ensuring that recipient organisations provide a standard of data protection comparable to that required under Singapore law. Where required, LumiOre enters into appropriate data transfer agreements with overseas recipients.

9. Data Retention and Deletion

Parent/Guardians may request deletion of their child's Personal Data at any time by contacting support@lumiore.ai. LumiOre will action such requests within 30 days, subject to any legal retention obligations. Please note that deletion of data may result in loss of the Student's Learning Profile and progress history.

10. Your Rights Under the PDPA

As a data subject (or as a Parent/Guardian acting on behalf of a minor), you have the following rights under the PDPA:

• Right of Access — you may request a copy of the Personal Data that LumiOre holds about you or your child.
• Right to Correction — you may request that inaccurate or incomplete Personal Data be corrected.
• Right to Withdraw Consent — you may withdraw consent for processing at any time (see Section 5.3).
• Right to Data Portability — in accordance with the PDPA (Amendment) Act 2020, you may request that LumiOre transmit certain Personal Data to another organisation in a commonly used machine-readable format, where technically feasible.
• Right to Lodge a Complaint — if you believe LumiOre has not handled your Personal Data in accordance with the PDPA, you may lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

To exercise any of the above rights, please contact support@lumiore.ai. LumiOre will respond to requests within 30 days. We may request verification of identity before processing any request. We may decline requests that are manifestly unfounded, excessively repetitive, or that would adversely affect the rights of others.

11. Data Security

LumiOre implements appropriate technical and organisational security measures including: encryption of data in transit (TLS) and at rest; access controls and role-based permissions, limiting access to Personal Data to LumiOre staff who require it to perform their duties; multi-factor authentication for administrative system access; regular security reviews, vulnerability assessments, and penetration testing; and confidentiality obligations for all LumiOre employees, contractors, and agents with access to Personal Data.

LumiOre will notify affected users and the PDPC of any data breach that is likely to result in significant harm, in accordance with the mandatory data breach notification requirements under the PDPA.

12. Cookies

LumiOre uses cookies and similar tracking technologies on the Platform. For full details of the types of cookies we use, their purposes, and how to manage your cookie preferences, please refer to our Cookie Policy.

13. Third-Party Links

The Platform may contain links to third-party websites or services. LumiOre is not responsible for the privacy practices of such third parties. We encourage you to read the privacy policies of any third-party site you visit.

14. Changes to This Privacy Policy

LumiOre may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. Material changes will be communicated to Parent/Guardians via email at least 14 days before they take effect. We will not reduce your rights under this Privacy Policy without your explicit consent. Continued use of the Platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

15. Contact Us