LUMIVO PRIVACY POLICY

Effective Date: August 17, 2026
Lumivo Global Pte. Ltd. (“Lumivo”, “we”, “us”, or “our”) respects your privacy and is committed to handling personal information responsibly.
This Privacy Policy explains how Lumivo collects, uses, discloses, stores, and protects personal information when you access or use lumivolife.com, our digital services, and related products and services (collectively, the “Services”).
The Services may be made available to users in Malaysia, the United States, the United Kingdom, Australia, and other jurisdictions.
This Privacy Policy is intended to apply across jurisdictions while preserving any rights and protections that cannot lawfully be excluded under the laws applicable to you.
By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.
If you do not agree with this Privacy Policy, you should not use the Services.

1. WHO WE ARE
The Services are operated by:
Lumivo Global Pte. Ltd.
Lumivo operates a digital platform through which users may discover and purchase selected local deals, experiences, products, services, and digital vouchers offered by participating merchants and service providers.
Lumivo may work with independent merchants, service providers, payment processors, technology providers, and other third-party service providers in connection with the Services.
Unless expressly stated otherwise, participating merchants and service providers are independent businesses and are not employees, agents, or representatives of Lumivo.

2. INFORMATION WE COLLECT
The information we collect depends on how you interact with the Services.
We may collect the following categories of information.

2.1 Information You Provide
You may provide personal information when you:
· create or use an account; 
· place an order; 
· purchase or receive a digital voucher; 
· contact us; 
· request customer support; 
· communicate with us; 
· participate in promotions; 
· submit feedback or reviews; 
· subscribe to marketing communications; or 
· otherwise voluntarily provide information. 
This information may include:
· name; 
· email address; 
· telephone number; 
· account information; 
· billing information; 
· order information; 
· voucher information; 
· transaction information; 
· communications with us; 
· customer service records; and 
· other information you voluntarily provide. 
You should provide information that is accurate and reasonably necessary for the relevant purpose.

2.2 Payment Information
When you make a purchase, payment information may be processed by third-party payment processors or financial service providers.
Depending on the payment method used, such information may include:
· payment card information; 
· payment account information; 
· billing information; 
· transaction identifiers; 
· payment status; 
· fraud-prevention information; and 
· verification information. 
Where payment processing is performed by a third-party provider, that provider may independently process payment information in accordance with its own privacy policy and applicable terms.
Lumivo does not intentionally store complete payment card numbers or payment security codes unless necessary and permitted for the operation of the Services.

2.3 Information Collected Automatically
When you access or use the Services, certain technical information may be collected automatically.
This may include:
· IP address; 
· browser type; 
· operating system; 
· device type; 
· device identifiers; 
· language preferences; 
· approximate location information derived from technical information; 
· referring and exit pages; 
· pages viewed; 
· access times; 
· search activity; 
· interactions with the Services; 
· transaction-related technical information; and 
· other technical or usage information. 
We may use this information for security, fraud prevention, analytics, troubleshooting, performance monitoring, and service improvement.

3. COOKIES AND SIMILAR TECHNOLOGIES
Lumivo may use cookies, pixels, tags, local storage, and similar technologies to operate and improve the Services.
These technologies may be used for purposes including:
· enabling website functionality; 
· maintaining sessions; 
· remembering preferences; 
· improving website performance; 
· understanding how the Services are used; 
· measuring marketing effectiveness; 
· preventing fraud and abuse; and 
· providing relevant communications or advertising where permitted by law. 
Some technologies may be provided or operated by third-party service providers.
You may be able to control or disable certain cookies through your browser or device settings.
Disabling certain technologies may affect the functionality of the Services.
Where applicable law requires consent for non-essential cookies or similar technologies, Lumivo will obtain such consent in accordance with applicable requirements.

4. HOW WE USE PERSONAL INFORMATION
We may use personal information for the following purposes.

4.1 Providing and Operating the Services
We may use personal information to:
· create and maintain accounts; 
· process orders; 
· process payments through applicable providers; 
· issue digital vouchers; 
· deliver vouchers and transaction information; 
· facilitate voucher redemption; 
· provide customer support; 
· communicate regarding transactions; 
· maintain transaction records; 
· operate and maintain the Services; and 
· provide services requested by users. 

4.2 Transactional and Service Communications
We may send communications relating to:
· orders; 
· payments; 
· vouchers; 
· redemption; 
· refunds; 
· account activity; 
· security; 
· customer support; 
· changes to the Services; and 
· other matters necessary to provide or administer the Services. 
These communications are generally necessary for the operation of the Services and are not ordinary marketing communications.

4.3 Marketing
Where permitted by applicable law, we may use personal information to send promotional communications relating to:
· Lumivo offers; 
· participating merchants; 
· promotions; 
· new services; 
· new locations; 
· products; and 
· other Lumivo-related offerings. 
You may opt out of marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us.
Opting out of marketing communications will not prevent us from sending necessary transactional, security, or service-related communications.

4.4 Security and Fraud Prevention
We may process personal information to:
· detect and prevent fraud; 
· detect unauthorized transactions; 
· protect user accounts; 
· prevent abuse; 
· investigate suspicious activity; 
· maintain platform security; 
· enforce our policies; and 
· protect Lumivo, users, merchants, service providers, and other parties. 

4.5 Analytics and Service Improvement
We may use information to understand how users interact with the Services and to improve:
· website functionality; 
· user experience; 
· search functionality; 
· offers; 
· performance; 
· security; 
· products and services; and 
· business operations. 
Where reasonably possible, information used for analytics and improvement may be aggregated or otherwise de-identified.

4.6 Legal and Regulatory Purposes
We may process personal information where reasonably necessary to:
· comply with applicable law; 
· comply with legal or regulatory obligations; 
· respond to lawful requests; 
· comply with court orders or legal processes; 
· establish, exercise, or defend legal claims; 
· enforce agreements and policies; or 
· protect the rights, property, or safety of Lumivo, users, merchants, or others. 

5. LEGAL BASES FOR PROCESSING
Where applicable law requires a legal basis for processing personal information, Lumivo may rely on one or more lawful bases, including:
· performance of a contract; 
· taking steps at your request before entering into a contract; 
· compliance with a legal obligation; 
· legitimate interests; 
· consent; or 
· another lawful basis permitted by applicable law. 
Our legitimate interests may include operating and improving the Services, maintaining security, preventing fraud, administering customer relationships, enforcing our agreements, and protecting our business and users.
Where we rely on consent, you may withdraw consent where permitted by applicable law.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. HOW WE DISCLOSE PERSONAL INFORMATION
Lumivo does not sell personal information for monetary consideration.
We may disclose personal information where reasonably necessary to provide, operate, secure, or improve the Services, or where otherwise permitted or required by applicable law.
Recipients may include the following categories.

6.1 Participating Merchants and Service Providers
Where necessary to provide or redeem a purchased voucher, product, or service, we may provide participating merchants or service providers with relevant information, which may include:
· voucher information; 
· order information; 
· redemption information; 
· customer name or contact information where reasonably necessary; and 
· information reasonably required to verify or fulfill a transaction. 
Participating merchants and service providers may process personal information in accordance with their own privacy practices and applicable law.

6.2 Payment and Financial Service Providers
We may disclose information to payment processors and financial service providers for purposes including:
· processing payments; 
· verifying transactions; 
· preventing fraud; 
· processing refunds; 
· handling payment disputes; 
· transaction monitoring; and 
· complying with applicable financial or legal requirements. 

6.3 Technology and Service Providers
We may use third-party providers supporting functions such as:
· website hosting; 
· cloud infrastructure; 
· database services; 
· email delivery; 
· communications; 
· customer support; 
· analytics; 
· fraud detection; 
· security; 
· payment processing; 
· technical support; and 
· other services necessary to operate the Services. 
Such providers may process personal information on our behalf or as otherwise permitted by applicable law.

6.4 Professional Advisers
We may disclose personal information where reasonably necessary to:
· lawyers; 
· accountants; 
· auditors; 
· insurers; 
· consultants; and 
· other professional advisers. 

6.5 Legal and Regulatory Authorities
We may disclose personal information where required or permitted by law, including in response to:
· court orders; 
· subpoenas or similar legal processes; 
· government requests; 
· regulatory requirements; or 
· other lawful processes. 

6.6 Business Transfers
If Lumivo is involved in a merger, acquisition, restructuring, financing, sale of assets, insolvency, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

7. INTERNATIONAL DATA TRANSFERS
Lumivo operates and provides Services across multiple jurisdictions.
Personal information may therefore be stored, accessed, or processed in Singapore and in other countries where Lumivo or its service providers operate.
Those countries may have data protection laws that differ from the laws of your country or region.
Where applicable law requires safeguards for international transfers, Lumivo will implement appropriate safeguards or rely on another legally recognized transfer mechanism.
Depending on the applicable jurisdiction, such safeguards may include:
· contractual protections; 
· recognized transfer mechanisms; 
· adequacy decisions; 
· consent where legally permitted; or 
· other legally recognized safeguards. 
For users in jurisdictions that impose specific requirements on cross-border transfers, Lumivo will comply with those requirements to the extent applicable.

8. DATA RETENTION
Lumivo retains personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by applicable law.
Retention periods may depend on:
· the nature of the information; 
· the purpose for which it was collected; 
· the nature of the relationship with the user; 
· legal and regulatory requirements; 
· accounting and transaction requirements; 
· dispute resolution; and 
· fraud prevention and security requirements. 
When personal information is no longer required, Lumivo may delete, anonymize, or securely dispose of it, subject to applicable legal and regulatory requirements.

9. DATA SECURITY
Lumivo takes reasonable administrative, technical, and organizational measures designed to protect personal information against:
· unauthorized access; 
· unauthorized disclosure; 
· misuse; 
· alteration; 
· loss; and 
· destruction. 
However, no electronic transmission or storage system can be guaranteed to be completely secure.
Accordingly, Lumivo cannot guarantee absolute security of personal information.
You are responsible for maintaining the confidentiality of your account credentials and should contact us promptly if you believe your account or personal information has been compromised.

10. YOUR PRIVACY RIGHTS
Depending on your location and applicable law, you may have rights concerning your personal information, including rights to:
· request access to personal information; 
· request correction of inaccurate or incomplete information; 
· request deletion of personal information; 
· request restriction of certain processing; 
· object to certain processing; 
· withdraw consent where processing is based on consent; 
· request portability of certain information; 
· opt out of certain marketing communications; 
· object to certain forms of profiling or automated decision-making where applicable; and 
· lodge a complaint with a relevant privacy or data protection authority. 
These rights are subject to applicable legal limitations and exceptions.
To exercise a privacy right, contact us using the information in Section 24.
We may take reasonable steps to verify your identity before processing certain requests.

11. UNITED KINGDOM USERS
If you are located in the United Kingdom, applicable UK data protection laws, including the UK General Data Protection Regulation and the Data Protection Act 2018, may apply to the processing of your personal information.
Subject to applicable law, you may have rights including:
· access; 
· rectification; 
· erasure; 
· restriction of processing; 
· objection to processing; 
· data portability; 
· withdrawal of consent; and 
· rights relating to certain automated decision-making. 
Where applicable, you may lodge a complaint with the Information Commissioner's Office (ICO) or another competent supervisory authority.
Nothing in this Privacy Policy is intended to limit any right that cannot lawfully be excluded or restricted under UK law.

12. EUROPEAN ECONOMIC AREA AND OTHER JURISDICTIONS
If you access or use the Services from a jurisdiction where additional data protection laws apply, including the European Economic Area, you may have additional rights under applicable law.
Lumivo will comply with mandatory requirements applicable to the processing of personal information in the relevant jurisdiction.
Nothing in this Privacy Policy is intended to restrict or exclude rights that cannot legally be restricted or excluded.

13. UNITED STATES USERS
Privacy laws vary among U.S. states.
Depending on your state of residence and applicable law, you may have rights relating to your personal information, including rights to:
· know or access personal information; 
· request correction; 
· request deletion; 
· obtain information concerning categories of personal information collected or disclosed; 
· opt out of certain targeted advertising or similar activities where applicable; 
· opt out of certain sales or sharing activities where applicable; 
· appeal certain privacy decisions where required by applicable law; and 
· exercise other rights provided by applicable state privacy laws. 
Lumivo does not sell personal information for monetary consideration.
Where applicable law provides additional rights, Lumivo will process applicable requests in accordance with the requirements of that law.
We may take reasonable steps to verify your identity before completing certain requests.
Lumivo will not discriminate against you for exercising privacy rights where prohibited by applicable law.

14. CALIFORNIA RESIDENTS
If you are a California resident and the California Consumer Privacy Act, as amended (“CCPA”), applies to Lumivo's processing of your personal information, you may have additional rights under California law.
Depending on applicable requirements, these may include:
· the right to know; 
· the right to access; 
· the right to correct; 
· the right to delete; 
· the right to opt out of the sale or sharing of personal information where applicable; 
· the right to limit certain uses and disclosures of sensitive personal information where applicable; and 
· the right not to receive discriminatory treatment for exercising applicable privacy rights. 
Lumivo does not sell personal information for monetary consideration.
If you wish to exercise applicable California privacy rights, please contact us using the information in Section 24.
We may take reasonable steps to verify your identity before processing a request.
Where permitted by applicable law, you may use an authorized agent to submit a request on your behalf.

15. AUSTRALIAN USERS
If you are located in Australia, the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) may apply to Lumivo's handling of your personal information.
Subject to applicable law, you may have rights to:
· request access to personal information we hold about you; 
· request correction of inaccurate, incomplete, or outdated information; 
· make a privacy complaint; and 
· exercise other rights available under applicable Australian privacy law. 
If you believe Lumivo has mishandled your personal information, please contact us first so that we can investigate and seek to resolve the matter.
Where required by applicable law, Lumivo will provide information regarding how complaints are handled.
You may also have the right to contact the Office of the Australian Information Commissioner (OAIC).
Personal information may be disclosed to overseas recipients, including service providers located in Singapore and other jurisdictions in which our service providers operate. Where required by Australian law, Lumivo will take reasonable steps and otherwise comply with applicable requirements concerning overseas disclosures.

16. MALAYSIA USERS
If you are located in Malaysia, the Personal Data Protection Act 2010 (PDPA) and other applicable Malaysian privacy and data protection requirements may apply to Lumivo's processing of your personal data.
Subject to applicable law, you may have rights relating to:
· access to personal data; 
· correction of personal data; 
· information concerning the purposes for which personal data is processed; 
· withdrawal of consent in appropriate circumstances; and 
· other rights provided under applicable Malaysian law. 
Lumivo will take reasonable measures regarding the collection, use, disclosure, retention, and protection of personal data in accordance with applicable Malaysian requirements.
Where applicable law provides additional rights or requirements, those requirements will apply to the extent required by law.

17. CHILDREN'S PRIVACY
The Services are not directed to children who are not legally permitted to use online purchasing or account services in their jurisdiction.
We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.
If you believe that a child has provided personal information to Lumivo in circumstances where such collection is not permitted, please contact us.
If we become aware that we have collected personal information from a child where collection is not permitted, we will take reasonable steps to delete the information as required by applicable law.

18. THIRD-PARTY WEBSITES AND SERVICES
The Services may contain links to third-party websites, applications, merchants, payment providers, or other services.
Third parties may maintain their own privacy policies and terms.
Lumivo does not control and is not responsible for the privacy practices, security, or content of third-party services that we do not operate.
You should review the applicable privacy policies of third parties before providing them with personal information.

19. MARKETING COMMUNICATIONS
Where permitted by applicable law, Lumivo may send promotional communications by email or other permitted communication channels.
You may opt out of marketing communications by:
· using the unsubscribe mechanism included in the communication; or 
· contacting us at privacy@lumivolife.com. 
Even after you opt out of marketing communications, Lumivo may continue to send communications necessary to:
· complete transactions; 
· provide purchased vouchers; 
· provide customer support; 
· maintain account security; 
· administer the Services; or 
· comply with legal obligations. 

20. AUTOMATED DECISION-MAKING AND PROFILING
Lumivo may use automated tools or algorithms for purposes including:
· fraud detection; 
· security; 
· transaction monitoring; 
· analytics; 
· personalization; 
· recommendations; and 
· service improvement. 
Where applicable law provides rights concerning automated decision-making or profiling, you may have additional rights.
Lumivo does not intend to make decisions producing legal or similarly significant effects solely through automated processing except where permitted by applicable law and appropriate safeguards are in place.

21. DO NOT TRACK
Some browsers and devices may transmit “Do Not Track” or similar signals.
Because there is no universally applicable standard governing all such signals and technologies, Lumivo may not respond to every browser-based Do Not Track signal.
Where applicable law requires Lumivo to recognize a particular privacy preference signal, Lumivo will comply with applicable legal requirements.

22. DATA BREACHES AND SECURITY INCIDENTS
If Lumivo becomes aware of a security incident involving personal information, we will assess the incident and take reasonable measures to:
· contain the incident; 
· investigate the circumstances; 
· reduce potential harm; 
· remediate the incident where appropriate; and 
· comply with applicable legal requirements. 
Where notification is required by applicable law, Lumivo will notify affected individuals, regulators, or other parties as required.

23. CHANGES TO THIS PRIVACY POLICY
Lumivo may update this Privacy Policy from time to time to reflect:
· changes to the Services; 
· changes to our business operations; 
· changes in technology; 
· changes in applicable law; or 
· changes to our privacy practices. 
When we update this Privacy Policy, we will publish the revised version on lumivolife.com and update the Effective Date above.
Where required by applicable law, we may provide additional notice or obtain consent before material changes take effect.
Your continued use of the Services after the effective date of an updated Privacy Policy constitutes acknowledgment of the updated Privacy Policy to the extent permitted by applicable law.

24. CONTACT US
If you have questions about this Privacy Policy, wish to exercise applicable privacy rights, or wish to make a privacy-related complaint, please contact:
Lumivo Global Pte. Ltd.
Privacy Email: privacy@lumivolife.com
Website: https://lumivolife.com
When submitting a privacy request, please provide sufficient information for us to understand and process your request.
We may request additional information to verify your identity where reasonably necessary and permitted by applicable law.

25. APPLICABLE LEGAL REQUIREMENTS
This Privacy Policy is intended to operate across multiple jurisdictions.
Nothing in this Privacy Policy is intended to:
· exclude rights that cannot legally be excluded; 
· limit mandatory protections available under applicable privacy laws; 
· prevent you from exercising statutory rights available in your jurisdiction; or 
· override any mandatory legal requirement applicable to the processing of your personal information. 
Where a mandatory requirement of applicable law conflicts with this Privacy Policy, the mandatory legal requirement will prevail to the extent of the conflict.

© 2026 Lumivo Global Pte. Ltd. All rights reserved.
        