Privacy Policy

Last updated: November 11, 2026

1. Overview

1.1 We, Learmo Pte Ltd (hereinafter referred to as “we”, “our”, “us” or the “Company”), place great importance on the confidentiality, privacy and protection of your personal and transactional data. We handle all personal data provided to us in accordance with the standards prescribed under the Singapore Personal Data Protection Act 2012 (the “PDPA”) and the subsidiary legislation made thereunder.

1.2

BY USING THIS WEBSITE, YOU AGREE THAT THE COMPANY MAY COLLECT, USE, PROCESS, STORE AND/OR DISCLOSE YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DISAGREE WITH ALL OR ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE OR CONTINUE ANY FURTHER USE OF THIS WEBSITE.

2. Information We Collect

2.1 When you access our website https://www.learmo.com and all pages within the domain (the “Website”), the following types of information may be collected about you:

2.1.1 Contact Information

These relate to the following information about you, some or all of which may be collected when you register for an account with us or when you contact us or our representatives:

(a) Name
(b) Residential address
(c) Contact number
(d) Email address
(e) Profile picture

2.1.2 Access Information

These relate to information about your computer, tablet, mobile device or any other device that may be used to access the Website, as well as your access patterns, some or all of which may be collected when you use the Website:

(a) IP address
(b) Geographic location
(c) Operating system and browser type
(d) Device type
(e) Web traffic data
(f) Time spent on the Website
(g) Number of webpages within the Website viewed
(h) Access from third-party websites linking to our Website
(i) Advertising information, e.g. what advertisements were clicked and/or viewed

2.1.3 Submitted Information

These relate to information that you disclose to us in order for us to provide the Services on this Website, including information you provide when you:

(a) create or manage a Learmo account;
(b) create, upload, publish or manage courses, lessons, quizzes, articles, websites, media or other content;
(c) create or manage a Learning Hub or creator website;
(d) enroll in, purchase or access courses or other services offered through the platform;
(e) configure subscriptions, pricing, payment or business information;
(f) communicate with us, Creators, Students or other users through features made available on the Website; or
(g) submit information through forms, support requests, feedback, surveys, waitlists or other Website functionality;
(h) use artificial intelligence-powered or machine learning features, including prompts, instructions, information, content and other materials submitted to such features, and information generated or processed in connection with your use of those features;
(i) enroll in courses or use Learning Hubs, including Student enrollment records, course access information, learning activity and progress records; or
(j) request support or report a technical issue, including the information provided in related communications and support records.

Some Creator Content and other submitted materials may contain Personal Data, but not all Creator Content constitutes Personal Data. AI-generated outputs may be stored as content available to the relevant Creator. The original prompts submitted to generate those outputs are not stored as Creator Content; this does not exclude any technical or diagnostic records that may be generated in operating or securing the Services, subject to this Privacy Policy.

2.1.4 Third-Party Information

We may receive information about you from third parties with whom we work closely, including payment service providers, data analytics providers, advertising networks, social networking sites and other service providers. Such information may include, but is not limited to, the various categories of Contact Information and Access Information listed above.

2.1.5 Services

The services provided on this Website include:

(a) providing an online platform through which Creators can build, design, manage, publish and operate Learning Hubs, courses and related digital content and services;
(b) providing tools and functionality for content creation, course management, website creation, media hosting, marketing, enrollment, payment processing, analytics and other services made available by Learmo from time to time; and
(c) enabling Students to discover, purchase, enrol in, access and use courses, learning materials and other services offered by Creators through Learmo.

Collectively, these are referred to as the “Services.”

3. Our Protection and Use of Personal Data

3.1 Insofar as the information collected allows you to be identified directly, or indirectly when combined with other information, it will be deemed “Personal Data.”

3.2 We will collect, use, process, store and/or disclose your Personal Data for the following purposes, where necessary or applicable:

(a) To verify your identity;
(b) To provide, administer and facilitate the Services available through the Website;
(c) To carry out profiling and maintain a database for the purposes of providing the Services on the Website;
(d) To enable your device and/or software to access the Website;
(e) For the smooth administration and improvement of the Website, including troubleshooting, site analysis, testing, research, statistical and survey purposes and to obtain feedback so as to enable us to improve the operation of the Website and offer you a better user experience;
(f) For audit, customer service, administrative support, market research and business development purposes;
(g) To contact or notify you about matters relating to your user account, your subscription, and updates and/or developments to the Website, the Website Terms of Use and this Privacy Policy;
(h) To respond to any queries, requests or reports which you may have submitted;
(i) To recommend and/or display content and advertisements on the Website that may be of interest to you;
(j) To comply with requirements under any applicable law or requests from any competent authority, including but not limited to relevant governmental authorities, law enforcement agencies and regulatory bodies;
(k) To facilitate any payment processes;
(l) Where required in any civil or criminal suit or for the protection and/or enforcement of our legal rights and obligations;
(m) In the event we sell or buy any business or assets, where necessary for the purposes of the sale or purchase; and/or
(n) To enable any third parties to perform any of the above where necessary and/or applicable, including but not limited to law enforcement agencies, regulatory bodies, our business partners, affiliates, suppliers and sub-contractors;
(o) To provide, operate, support and improve artificial intelligence-powered or machine learning features made available through the Services, including processing prompts, instructions, content and other information submitted by users for the purpose of generating, modifying, organizing or enhancing content requested by the user; and
(p) To administer Student enrollment, provide course access, maintain learning-progress and activity records, facilitate Creator–Student course operations, and provide related technical support.

Where Personal Data is contained in Creator materials, Student enrollment and progress records, support communications, or AI inputs and outputs, Learmo processes such Personal Data for the requested functionality and related service delivery, security, troubleshooting, support, quality assurance and lawful compliance purposes, as applicable. These operational purposes do not independently authorize the use of private Creator Content, Student Personal Data, AI prompts or AI outputs as datasets for training or fine-tuning AI models.

If we intend to use your Personal Data for any purpose not listed above, we will notify you of this purpose and obtain your consent, unless otherwise prescribed by any applicable law.

3.3 Artificial Intelligence Processing and Model Training

Learmo currently provides its AI-powered content generation features using a self-hosted Qwen artificial intelligence model operated within infrastructure controlled by Learmo. Inputs submitted to these features are processed to generate the requested outputs and are not sent to external AI model providers for generation.

AI-generated outputs may be stored and made available to the relevant Creator as part of the Services, including for the creation, editing and management of courses, lessons, quizzes, articles and other supported content. Original prompts are not stored as Creator Content.

Learmo does not use private Creator Content, Student Personal Data, non-public AI prompts or AI-generated outputs as training datasets or to train or fine-tune its AI models. Generating requested outputs and performing necessary technical processing, security, support and diagnostics are distinct from model training.

This statement does not mean that Learmo makes a blanket representation that AI-related technical logs, diagnostic records or other operational data are never created or retained. Where such information contains Personal Data, its handling is subject to this Privacy Policy and applicable law.

3.4 We will retain your Personal Data for the length of time required to fulfil the purposes for which the Personal Data was collected, save where continued retention is necessary for us to comply with our other legal obligations or to meet our business requirements.

3.5 In respect of the transfer of data to third parties, we will endeavour to ensure that your Personal Data is transferred to recipients who are legally bound to uphold strong data protection standards and to comply with applicable data protection laws and this Privacy Policy.

3.6 The Website may contain links to third-party websites which are not subject to this Privacy Policy. We are not responsible for their collection and use of personal information, or their data security and integrity practices and procedures.

3.7 Creator and Learmo Responsibilities for Student Personal Data

Creators may collect and use information about Students through their Learning Hubs, including information associated with enrollment, course purchases, access and learning activity. Creators are responsible for providing appropriate privacy notices and handling Personal Data in connection with their independent courses, customer relationships and other activities, as required by applicable law.

Learmo processes Student Personal Data to provide and operate the Services. Depending on the particular processing activity and its purpose, Learmo may process such information for its own purposes or on behalf of the relevant Creator. The parties' respective data protection responsibilities depend on the actual activity and applicable law; Learmo is not necessarily acting solely as a data processor for all Student information.

Students may contact Learmo at support@learmo.com about Personal Data held or processed through the platform. Requests concerning a Creator's independent course or customer activities may also need to be directed to that Creator. Learmo will assess requests within its applicable legal responsibilities and current operational capabilities. A dedicated Student Personal Data deletion request workflow has not yet been established; this clause does not promise automatic or immediate deletion.

4. Payment Processing

4.1 During the current Beta phase, payment transactions supported through Learmo are processed using Stripe, through the payment methods made available at the applicable checkout. Payment information you provide for a transaction may be transmitted directly to Stripe for processing in accordance with Stripe's applicable terms and privacy practices. PayPal and other payment processors are not currently supported through the Beta Services.

4.2 At all times, payment card data handled directly by the applicable payment service provider is stored and processed by that service provider in accordance with its own security, privacy and regulatory obligations. Learmo does not represent that it independently stores complete payment card details processed directly by such provider.

4.3 Additional payment methods or payment service providers may be made available through the Services from time to time. Where applicable, the relevant provider's terms, privacy policy and processing practices will apply to payment information processed by that provider.

5. Retention

5.1 Retention Purposes and Categories

We may retain Personal Data for as long as reasonably necessary for the purposes for which it was collected or processed, or as required or permitted by applicable law. Retention needs and criteria may differ depending on the category of information, including Creator and Student account records, course enrollment and learning-progress records, payment and financial records, support communications, security and technical records, AI-related operational information, and backup or recovery copies.

Learmo has not yet adopted a comprehensive, formally documented retention schedule specifying a fixed period for each category. Accordingly, this Privacy Policy does not promise a particular retention duration for every category of Personal Data.

5.2 Deletion Requests and End of Retention

You may submit a request concerning deletion of Personal Data by contacting support@learmo.com. Learmo will assess the request in light of applicable legal obligations, the purposes for which the information is still required, legitimate retention needs, and relevant technical and operational limitations.

Where Personal Data is no longer reasonably necessary for an applicable purpose and retention is not otherwise required or permitted, Learmo will cease retaining it or take appropriate steps to delete or de-identify it, subject to applicable law and technical constraints.

Closing an account or submitting a deletion request does not necessarily result in immediate deletion of all associated information from active systems, service providers, caches or backups. No fixed deletion completion period is promised by this Policy.

6. Service Providers Used

6.1 We may use external service providers to support the operation and delivery of the Services, including hosting and cloud infrastructure, storage and data processing, video hosting and content delivery, payment processing, communications and email delivery, analytics, security, customer support and other technical or operational services. The categories of providers involved depend on the functionality used.

Where such providers process Personal Data on our behalf, Learmo requires processing for the relevant service purposes subject to applicable contractual, confidentiality, security and data protection obligations. Learmo's AI content-generation model is currently self-hosted as described in Clause 3.3; this does not mean that the Services operate without external infrastructure or other service providers.

6.2 Where Personal Data is transferred outside Singapore or the jurisdiction in which it was collected, we will take steps required under applicable law to ensure that such Personal Data continues to receive a standard of protection that is at least comparable to that provided under the relevant data protection law, including the PDPA where applicable.

6.3 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 such as up-to-date security protections, encryption where appropriate, access controls and other safeguards to secure the storage and transmission of Personal Data by us, and to limit disclosure of Personal Data internally and to authorised third-party service providers and agents on a need-to-know basis.

6.4 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 regularly review and enhance our information security measures.

7. Your Rights in Respect of Your Personal Data

7.1 You may contact us at support@learmo.com in relation to your Personal Data, including to:

(a) Correct or update your Personal Data;
(b) Reasonably request access to your Personal Data. Do note that you may face reasonable charges for our provision of the Personal Data;
(c) Request information relating to our use or disclosure of your Personal Data;
(d) Request that we stop processing your Personal Data for certain purposes, where applicable;
(e) Request deletion of Personal Data where we no longer have legally permissible grounds to use or retain it, subject to the assessment and limitations described in Clauses 3.7 and 5.2; or
(f) Make a report about any actual or potential breach of security in relation to your Personal Data.

Do note that we may not be obliged to comply with your requests under certain conditions as prescribed by applicable law. In such an event, we will notify you accordingly of the basis for not acceding to your request.

8. Data Protection and Security

8.1 We will put appropriate technical and administrative security measures in place to help ensure that your information is protected against unauthorised or accidental access, use, alteration or loss.

8.2 Our employees and authorised personnel who deal with Personal Data are required to handle and protect Personal Data appropriately and in accordance with applicable policies and legal requirements.

9. Variation

9.1 We reserve the right to change this Privacy Policy from time to time at our sole and absolute discretion. The most updated Privacy Policy will be made available promptly on the Website.

It is your responsibility to keep yourself updated and aware of the latest version of this Privacy Policy. If any change is unacceptable to you, you should immediately cease all further use of the Website.

If you continue using the Website after the changes take effect, you will be deemed to have accepted the changes.