General Privacy Statement

When you engage with Lumivara directly—by enquiry, onboarding, or service participation—you may provide the following categories of information:

• Contact details: name, professional email address, telephone number.
• Professional profile: job title, organisation, reporting lines and role responsibilities used to tailor coaching interventions.
• Assessment and intake data: psychometric results, 360 feedback responses, development objectives and session notes with your consent.
• Billing information necessary for invoicing and payment processing, such as billing name and payment method data processed by our payment partners.
• Communications content platform with coaches and administrative staff for scheduling, progress updates, and service delivery.
• Any additional information you provide when requesting proposals, submitting feedback, or participating in workshops.

We also collect technical and usage information automatically when you interact with our website and digital tools to operate the service and improve user experience.

• Device and browser information, including IP address and browser type, collected for security and analytics.
• Usage data such as pages visited, session duration and feature interactions to help enhance platform functionality.
• Location data in approximate form (city, country) inferred from IP address for regional service optimisation.
• Cookie and tracking identifiers used to remember preferences and maintain authenticated sessions.
• Technical logs related to errors, performance and service availability for troubleshooting and maintenance.
• Device identifiers and analytics identifiers when using mobile or web-based coaching tools.

We process personal data for clearly defined operational purposes tied to the provision and improvement of coaching and mentoring services:

• To deliver and manage coaching and mentoring engagements, including scheduling, session preparation and post-session follow-up.
• To perform assessments, produce development plans and measure progress against agreed leadership outcomes.
• To process billing and payments, manage contracts and administer client accounts.
• To provide client support, respond to enquiries and coordinate logistics with authorised representatives.
• To analyse service usage, evaluate effectiveness and improve the quality of our programmes using aggregated, pseudonymised data where possible.
• To comply with legal obligations, professional standards and internal policies governing confidentiality and recordkeeping.
• To communicate updates about services, changes to terms or privacy policies where such communications are necessary for the contractual relationship or lawful basis.
• To facilitate corporate administration, risk management and reporting within Lumivara and its authorised service partners.

Lumivara uses cookies and similar technologies on xrovira.biz to ensure the website functions correctly and to collect analytics that help improve our services.

We use session cookies for user authentication, persistent cookies to remember preferences, and performance/analytics cookies to gather anonymised usage data.

Categories include strictly necessary cookies for site operation, functional cookies for preferences, and analytics cookies for performance insights.

You can manage cookie preferences through your browser settings or the cookie control tool on our website. Blocking certain cookies may affect site functionality.

Read our full cookie policy

We share personal data only when necessary for legitimate operational reasons and with trusted partners subject to confidentiality and security obligations.

• Service providers: payroll, payment processors, secure cloud hosting and analytics platforms engaged to support Lumivara operations.
• Professional partners: certified assessors and accredited coaching partners providing specialist diagnostics under approved data handling arrangements.
• Organisational clients: where employers procure coaching for participants, limited participant data is shared as required for programme administration.
• Legal and regulatory bodies: when disclosure is necessary to meet legal duties or respond to lawful requests.
• Corporate transactions: in the event of a merger, sale or reorganisation, necessary personal data may be transferred to a successor entity subject to privacy safeguards.
• Third-party analytics and marketing platforms where you have consented to communications or tracking for service-related updates.

Retention periods are determined by the nature of the data and the purpose for which it was collected, taking into account legal, regulatory and professional obligations.

Client account records, engagement agreements and related documents are retained for the duration of the professional relationship and for a reasonable period thereafter to meet administrative and compliance requirements.

Communications and session notes are retained for a period consistent with professional recordkeeping practices and then securely archived or deleted unless retention is required by law or agreed with the client.

Technical logs and analytics data are retained in aggregated or anonymised form where possible; raw logs are kept only as long as necessary for security and operational purposes.

On request and subject to legal or contractual constraints, we will delete or anonymise personal data that is no longer necessary for the purposes for which it was collected.

Lumivara implements multiple layers of security controls to protect personal data, including organisational policies, technical measures and restricted access protocols. Security is reviewed regularly and aligned with recognised standards to mitigate risks associated with handling sensitive client information.

• Encryption in transit and at rest for sensitive data stored on secure cloud platforms.
• Role-based access controls, multi-factor authentication and strict internal confidentiality agreements for staff and partners.
• Regular security assessments, monitoring, logging and incident response procedures to detect and address potential issues promptly.

Although Lumivara is established and operates in Singapore, we recognize the importance of international data protection standards. To the extent applicable, we align our practices with the EU General Data Protection Regulation for individuals located in the European Economic Area. This section explains how GDPR principles influence our handling of personal data and the rights available to data subjects.

GDPR-related provisions in this policy apply to individuals subject to the GDPR. Where differences exist between statutory requirements and our procedures, we will apply the higher standard where required by law and notify affected individuals of material differences in data handling practice.

• Right of access: You may request confirmation of processing and a copy of personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data when legal grounds for processing no longer apply.
• Right to restriction and objection: You may request restriction of processing or object to processing for specific purposes, including profiling and direct marketing.

If you believe Lumivara has processed your personal data in a way that conflicts with GDPR, you may lodge a complaint with your local supervisory authority. We also invite you to contact us first to seek an internal resolution using the contact details below.

We may use contact details to send information about Lumivara services, events, and publications that are relevant to executive leadership coaching and business mentoring. Marketing communications are based on consent or legitimate interest, depending on context and local law.

You may opt out of marketing communications at any time by following the unsubscribe link in any message or by contacting us at [email protected]. We will process opt-out requests promptly and update your preferences.

Our services are geared to adult professionals. We do not knowingly collect personal data from children under the age of 18. If we become aware that we have collected personal data of a child without appropriate consent, we will take steps to delete such data promptly.

Our website may contain links to third-party sites and resources. Lumivara is not responsible for the privacy practices or content of external websites. We recommend reviewing the privacy policy of any third party before providing personal data.

We periodically review and may update this privacy notice to reflect changes in our practices or legal requirements. Material changes will be communicated via our website at xrovira.biz and, where appropriate, by direct notification to affected individuals.