Privacy Policy
Welcome to the Privacy Policy of Lyza Education Pte. Ltd. (trading as LumoLearn)
Last updated: 31 July 2026
Lyza Education Pte. Ltd. (“us”, “we”, or “our”), trading as LumoLearn, operates the https://lumolearn.ai website and related web applications, APIs, and services (collectively, the “Service” or “Platform”).
This privacy policy sets out the basis on which Lyza Education Pte. Ltd. may collect, use, disclose, or otherwise process personal data of our customers and users in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”). This policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes.
Please also refer to our Terms and Conditions.
Personal Data
1. As used in this policy: “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. References to “you” include parents or guardians acting on behalf of a child, organisation administrators, teachers, and other authorised users of the Platform.
2. Depending on the nature of your interaction with us and the features your organisation enables, examples of personal data which we may collect include:
- Identity and contact details — name, preferred name, email address, telephone number, country, gender, date of birth, school, parent/guardian name, and profile image;
- Account and organisation data — login credentials (managed via our authentication provider), organisation membership, roles (for example owner, admin, teacher, student, or service/kiosk role), and employment-related fields such as employment start date and leave entitlements where leave management is used;
- Registration and student records — class registration details, food allergies, notes, attendance, evaluations, certificates, feedback responses, learning progress, and classroom photos or videos uploaded by authorised organisation users;
- Calendar and scheduling data — calendar event titles, descriptions, participants, and schedule information; if you connect Google Calendar, your linked Google account email and encrypted OAuth tokens, plus (where you enable availability sync) busy/free time intervals without Google event titles or descriptions;
- Payment and billing data — invoice and payment records, customer name/email/phone for billing, payment method type (for example PayNow or card), and payment gateway references. Card and PayNow transactions are processed by our payment provider; we do not store full card numbers on our systems;
- Communications — emails we send or receive in connection with the Service, WhatsApp messages (where an organisation enables WhatsApp integrations), and support or feedback content;
- AI companion and classroom features (for example Lumo Day and related mini-apps) — conversation transcripts, mood or topic signals, session summaries, reward/progress data, voice audio processed for speech-to-text, and (where face recognition/attendance is enabled) face enrolment images and biometric face templates;
- AI and coding tools — chat or assistant messages, uploaded knowledge-base materials, coding projects, and (where used) on-device machine-learning training images;
- Device and usage data — IP address and technical logs generated when you use the Service, cookie and similar identifiers, and marketing attribution parameters (for example UTM parameters and advertising click identifiers) where collected on registration or marketing flows; and
- Other information you choose to provide, or that your organisation’s authorised users upload in connection with the Service.
Purposes for Collection, Use and Disclosure
3. We generally do not collect your personal data unless:
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after: (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes; or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Where an education centre, school, or other organisation (“Organisation Customer”) creates accounts or uploads student, parent, or staff data to the Platform, that Organisation Customer is responsible for ensuring it has a lawful basis (including any required parental or guardian consent) to provide that personal data to us for processing on its behalf.
4. We may collect and use your personal data for any or all of the following purposes:
- (a) performing obligations in the course of or in connection with our provision of the Platform and related goods and/or services requested by you or your Organisation Customer — including class and lead registration, student progress and feedback, curriculum and coding tools, calendaring and leave management, invoicing and payments, announcements, and organisation administration;
- (b) verifying your identity and managing authentication, invitations, password resets, and role-based access controls;
- (c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- (d) managing your relationship with us and with Organisation Customers on the Platform;
- (e) processing payment or credit transactions and maintaining invoice/payment records;
- (f) operating optional features your organisation or you enable, such as AI assistants, Lumo Day companion sessions and parent reports, face-recognition attendance, Google Calendar sync, Zoom-linked online classrooms, and WhatsApp communications;
- (g) sending you service and, where permitted, marketing information about our goods or services, including events, initiatives, and promotions;
- (h) improving, securing, and analysing our Service (including troubleshooting, audit logging, cost/usage metering, and product development);
- (i) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- (j) any other purposes for which you have provided the information;
- (k) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- (l) any other incidental business purposes related to or in connection with the above.
5. We may disclose your personal data:
- (a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
- (b) to Organisation Customers and their authorised users (for example teachers and administrators) according to the roles and permissions configured for your organisation;
- (c) to partner organisations where a registration or class is shared under a partnership arrangement configured on the Platform; and
- (d) to third-party service providers, agents, and other organisations we have engaged to perform any of the functions listed in clause 4 above for us — including cloud hosting and infrastructure, authentication, email delivery, payment processing, AI/speech processing, face recognition, messaging, video conferencing, and calendar providers as described in clause 5A.
5A. Our Service relies on specialised subprocessors. Depending on enabled features, these may include:
- Amazon Web Services (AWS) — hosting, databases, file storage, authentication (Cognito), email (SES), and face recognition (Rekognition). Our primary Platform infrastructure is operated in the Asia Pacific (Singapore) region (ap-southeast-1);
- OpenAI — generative AI features, embeddings/knowledge bases, Lumo Day analysis and parent-report generation, and realtime speech-to-text where enabled;
- HitPay — PayNow and card payment processing;
- Google — Google Calendar integration (optional; OAuth-connected accounts) and certain static asset hosting;
- Meta — WhatsApp Business messaging where an organisation enables it, and advertising/attribution pixels or conversion APIs on marketing or registration flows where used;
- Zoom — online classroom integrations where an organisation connects Zoom; and
- other vendors reasonably required to operate, secure, or improve the Service.
6. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Children’s Personal Data
6A. The Platform is used by education providers and may process personal data of children (including students under 18) when an Organisation Customer enrols them or enables classroom features. We process such data as a service provider to the Organisation Customer for the purposes in clause 4. Organisation Customers must obtain any required parental or guardian consents before providing children’s personal data to us.
6B. Where face recognition or Lumo Day (or similar) features are enabled, this may include biometric face templates derived from enrolment photos, audio processed for transcription, conversation content, and AI-generated summaries or parent reports. Organisation administrators control enablement and enrolment for their centres. Face enrolment records may be deleted by authorised organisation users through the Platform’s face-enrolment management features.
Tracking & Cookies Data
7. We use cookies and similar tracking technologies to operate the Service, maintain authenticated sessions, remember preferences, and (where used) measure marketing performance. Cookies are small data files which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies used may include beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
8. Examples include authentication session cookies/tokens managed by our identity provider, preference storage (for example language), short-lived marketing attribution parameters stored in local storage, and third-party advertising cookies (for example Meta Pixel) on pages where marketing measurement is enabled. You can configure your browser to refuse all cookies or to alert you when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service (in particular, signed-in features).
Withdrawing Your Consent
9. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the details provided below. If your data is held because an Organisation Customer uses the Platform, you may also contact that organisation; we may need to coordinate with them to process your request.
10. Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
11. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 9 above.
12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Access to and Correction of Personal Data
13. If you wish to make: (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Account holders may also update certain profile fields directly in the Service where that functionality is available.
14. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Protection of Personal Data
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures. These include encrypted transport (HTTPS), cloud access controls and role-based permissions within the Platform, encryption of certain sensitive credentials (for example Google Calendar OAuth tokens), restricted disclosure of personal data internally and to authorised third-party service providers on a need-to-know basis, and security reviews of our information systems.
16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
17. We generally rely on personal data provided by you (or your authorised representative, including Organisation Customers). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by updating your account where available, or by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. Certain Platform records are retained for defined periods — for example organisation audit logs (approximately 180 days), selected Lumo Day session and message data (approximately 12 months), short-lived reward transaction records (approximately 3 months), and usage/cost metering records (daily summaries for approximately 90 days; monthly summaries for approximately 36 months). Other account, organisation, student, billing, and durable Lumo Day memory/profile data may be retained for the life of the relevant organisation relationship unless deleted earlier.
19. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes. Organisation user accounts may be deactivated rather than immediately erased; certain integrations (for example Google Calendar) can be disconnected by the user, which stops syncing and removes related integration records as described in-product.
Transfers of Personal Data Outside of Singapore
20. Our primary Platform infrastructure is hosted in Singapore (AWS Asia Pacific — Singapore). However, some features require transfer of personal data to countries outside Singapore — for example to OpenAI, Google, Meta, HitPay, or Zoom — when you or your Organisation Customer use the relevant integrations. Where we transfer personal data outside Singapore, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA, including through appropriate contractual and organisational measures with our service providers, and we will obtain consent where required.
Data Protection Officer
21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Address: 545 Orchard Road, #16-07A Far East Shopping Centre, Singapore 238882
Email: contactus@lumolearn.ai
Contact Number: +65 9358 6695
Effect of Notice and Changes to Notice
22. This Notice applies in conjunction with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.