Privacy Policy

Lumivest ("we", "us", "our") is committed to protecting the personal data of individuals who engage with our programmes, website, and services. This Privacy Policy explains how we collect, use, disclose, and protect personal data in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore.

By using our website or participating in our programmes, you acknowledge that you have read and understood this policy. For questions, contact us at [email protected].

1. Who We Are

Data Controller: Lumivest Pte. Ltd.
Address: 1 Raffles Place, #28-06, One Raffles Place Tower 2, Singapore 048616
Email: [email protected]
Phone: +65 6294 8173

2. Personal Data We Collect

We may collect the following categories of personal data:

• Contact information: Name, email address, phone number
• Enquiry details: Information you provide when submitting a contact form or making an enquiry
• Programme participation data: Workbook responses, reflection notes, and information shared during sessions (held in strict confidence)
• Technical data: IP address, browser type, device identifiers, pages visited, and session duration (collected via cookies and analytics tools)
• Communication records: Emails and messages exchanged with our team

3. How We Collect Personal Data

• Directly from you via our website contact form, email, or telephone
• Through programme enrolment and participation
• Automatically through cookies and analytics when you visit our website (subject to your cookie consent)
• From referrals made by other participants or professional contacts (with your awareness)

4. Legal Basis and Purpose of Processing

We process personal data under the following legal bases:

• Consent: For marketing communications and optional cookie tracking. You may withdraw consent at any time.
• Contractual necessity: To deliver programmes you have enrolled in and manage associated communications.
• Legitimate interests: To improve our services, understand how our website is used, and maintain appropriate records.
• Legal compliance: Where required by Singapore law or regulatory obligations.

Specific purposes include: responding to enquiries, delivering and improving educational programmes, processing payments, sending relevant programme updates, and complying with applicable legal requirements.

5. Data Retention

We retain personal data only for as long as necessary:

• Contact enquiry data: up to 12 months from the date of enquiry if no programme is undertaken
• Programme participation records: up to 3 years after programme completion for quality assurance and follow-up access
• Financial and transactional records: 7 years in accordance with Singapore accounting and tax requirements
• Website analytics data: up to 26 months (anonymised where possible)

6. Data Sharing and Third Parties

We do not sell, rent, or trade personal data. We may share data with:

• Service providers: Including email platforms, payment processors, and website hosting services, under strict data processing agreements
• Analytics providers: Such as Google Analytics (anonymised and aggregated where possible)
• Legal or regulatory bodies: Where required by Singapore law

We do not share personal data with financial product providers or third-party advertisers.

7. Data Protection Measures

We implement reasonable technical and organisational security measures to protect personal data, including:

• Encrypted transmission (HTTPS) for all website communications
• Access controls limiting data access to authorised personnel only
• Regular review of data handling practices and third-party service agreements
• Confidentiality obligations for all staff and facilitators

In the unlikely event of a data breach that poses a significant harm risk, we will notify affected individuals and the Personal Data Protection Commission (PDPC) in accordance with the PDPA's mandatory breach notification requirements.

8. Cookies

We use cookies to improve your experience on our website. These include essential cookies (required for basic functionality) and optional analytics cookies (used to understand how visitors navigate the site). You may manage your cookie preferences at any time via our Cookie Policy page.

9. Your Rights Under the PDPA

As a data subject under Singapore's PDPA, you have the right to:

• Access personal data we hold about you
• Correct inaccurate or incomplete personal data
• Withdraw consent for data processing based on consent, at any time
• Request deletion of personal data where retention is no longer necessary (subject to legal obligations)
• Portability of personal data provided to us in a structured, commonly used format (where technically feasible)

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. If you are dissatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their respective policies.

11. Children's Privacy

Our programmes and website are intended for individuals aged 18 and above. We do not knowingly collect personal data from minors. If you believe a minor has submitted data to us, please contact us at [email protected] and we will promptly review and remove it.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be communicated via a notice on our website or by email to known contacts. Continued use of our services after an update constitutes acceptance of the revised policy.

13. Contact

For any questions, corrections, or requests regarding this policy or your personal data:

• Email: [email protected]
• Phone: +65 6294 8173
• Post: Lumivest Pte. Ltd., 1 Raffles Place, #28-06, One Raffles Place Tower 2, Singapore 048616