Privacy notice

This section clarifies terms used throughout the policy to help you understand the scope of processing activities.

We collect information to deliver platform features, manage accounts, bill customers and continuously improve our educational and career services. We limit collection to data elements that are necessary for those purposes and keep records only for as long as required for operational, legal and compliance reasons.

Lumiora collects and processes the personal and professional information you provide to enable career development services for prospective oil and gas managers. This includes profile details, qualifications, employment history, assessments, and communication preferences submitted via odioras.biz. Effective date: 01-02-2026. Processing is limited to purposes necessary for program delivery, coaching, competency mapping, certification tracking and compliance with regulatory obligations in Singapore. We apply technical, administrative and organizational safeguards calibrated to industry standards to protect your data. Retention periods are determined by the nature of the information, contractual requirements and applicable law; inactive accounts and associated records are reviewed and disposed of according to documented data lifecycle rules. You have rights of access, correction, restriction, portability and objection; to exercise these or to request deletion, contact our data protection team at Lumiora, 45 Ann Siang Road, Singapore, 069719 or by phone +6583388168, quoting Business ID S2807394A. For detailed procedures and the lawful bases for specific processing activities, consult the full privacy policy available on odioras.biz/privacy. We strive for clarity and accountability in handling your data and maintain records demonstrating compliance with relevant Singapore data protection standards.

• Registration details: full name, email address, password (stored hashed), professional title and employer.
• Profile and career information: CV/resume, certifications, training history, sector experience, skills assessments and development goals.
• Communications: messages you send to support or instructors, forum posts, feedback and survey responses.
• Transactional data: billing name, billing address and payment transaction identifiers processed via third-party payment providers.
• Application and recruitment materials: cover letters, interview notes and recruiter correspondence when you use job-matching features.
• Consent and preferences: marketing preferences, newsletter subscriptions and explicit consents given for optional processing.

When you use our services we automatically collect technical and usage data to operate the platform securely and to analyze performance.

• Device and browser information: device type, operating system, browser version and unique device identifiers.
• Usage and activity: pages visited, features used, timestamps and interaction logs to help improve course delivery and platform stability.
• Network data: IP address, approximate geolocation derived from IP, and ISP information for security, fraud prevention and localization.
• Cookies and similar technologies stored on your device to remember preferences and enable authentication.
• Performance and error logs collected for debugging and monitoring service health.
• Analytics metrics collected by third-party analytics services under our configuration to monitor aggregate usage patterns.

We may receive personal data about you from third parties where necessary for service delivery, recruitment partnerships or compliance checks.

• Payment processors and invoicing platforms providing transaction confirmations and limited billing details.
• Analytics and infrastructure providers (e.g., hosting, content delivery) that process aggregated and pseudonymized usage data.
• Recruitment partners and company clients who submit candidate profiles or job requirements for placement services.

We process personal data only for clearly defined purposes that support our platform and the professional development of users in the oil and gas sector.

• To provide and operate platform features, learning content, assessments and job-matching functionality.
• To manage registration, authenticate users and maintain account records.
• To process payments, billing and refunds through authorized payment service providers.
• To communicate with users about their accounts, courses, events and service updates.
• To analyze platform usage and performance to improve content, course design and user experience.
• To comply with legal obligations, respond to lawful requests from authorities and exercise or defend legal claims.
• To protect the security and integrity of our services, including fraud prevention and incident response.
• To provide optional marketing communications where you have consented or where permitted by applicable law.

Depending on the jurisdiction and the nature of the processing, we rely on one or more lawful bases to process personal data. Below are the primary legal bases we reference when applicable.

• Performance of a contract: processing necessary to deliver the services you have requested, such as account management and course access.
• Legal obligation: processing necessary to comply with applicable laws, regulations or court orders.
• Consent: where you have provided clear consent for specific uses such as marketing communications or optional analytics.
• Legitimate interests: processing necessary for our legitimate business purposes, such as fraud prevention, direct platform improvement and safeguarding users, balanced against your privacy rights.

We limit data sharing to third parties that provide services on our behalf, to partners that support career placement and to legal recipients as required by law. All processors are required to implement appropriate safeguards.

• Service providers: hosting, email delivery, learning management systems, analytics and CRM providers that process data pursuant to our instructions.
• Payment and billing partners that receive limited billing information to complete transactions.
• Corporate clients and recruitment partners when you apply for a role or opt into job-matching services.
• Legal and compliance recipients: courts, regulators and law enforcement in response to lawful requests.
• Prospective buyers or advisers in the event of a corporate transaction, where a confidentiality obligation will apply.
• Aggregated or anonymized data shared for research or industry benchmarking where individuals cannot be identified.

Protecting personal data is a priority. We apply a combination of administrative, technical and physical controls to reduce the risk of unauthorized access, disclosure, alteration or destruction. Controls are regularly reviewed and updated to reflect changes in technology and risk.

• Encryption: data is encrypted in transit using TLS and, where appropriate, at rest using industry-standard encryption.
• Access controls: role-based access, least-privilege principles and multi-factor authentication for administrative access.
• Monitoring and audits: logging, automated intrusion detection, periodic security assessments and vulnerability management.

Subject to local law, you have rights regarding your personal data. We provide mechanisms to exercise those rights and will respond to requests within applicable statutory timeframes.

• Right of access: request confirmation of whether we process your personal data and obtain a copy of that data.
• Right to rectification: request correction of inaccurate or incomplete personal data.
• Right to erasure: request deletion of personal data where retention is no longer necessary or where consent has been withdrawn and no other legal basis applies.
• Right to restriction: request limitation of processing in certain circumstances pending verification of a request.
• Right to data portability: request a machine-readable copy of data you provided to Lumiora in structured format where applicable.
• Right to object: object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on consent you may withdraw that consent at any time without affecting processing based on prior consent.
• Right to lodge a complaint with a supervisory authority if you consider your rights under applicable law have been infringed.

• Right of access: you may request a copy of personal data we hold about you and information about processing purposes.
• Right to rectification: you may request correction of inaccurate or incomplete personal data.
• Right to erasure and restriction: subject to legal and contractual obligations, you may request deletion or restriction of processing of personal data.
• Right to data portability and objection: where applicable, you may request transfer of data in a structured format and object to certain types of processing.

If you believe your rights under GDPR have not been respected, you may contact Lumiora's privacy team and, if unresolved, file a complaint with the relevant supervisory authority in your country of residence. For EU residents, this is typically the national data protection authority.

Lumiora's services are intended for professionals and individuals seeking career development in the oil and gas sector. We do not knowingly collect or maintain personal data from persons under 16 without verified parental or guardian consent. If you believe we have collected data from a minor, contact us and we will take appropriate steps to remove the data where required by law.

odioras.biz may provide links to third-party sites and partners for resources or integrations. These sites have separate privacy practices and Lumiora is not responsible for their content or compliance. Review each third party's privacy policy before sharing personal data.

We periodically review and may update our privacy practices. Material changes will be communicated via odioras.biz or by email to active account holders. Continued use of our services after a change indicates acceptance of the updated policy, where permitted by applicable law.