PRIVACY & POLICIES

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Welcome to the website and/or app of Nauggets Pte Limited (Nauggets). By accessing this website or app, you agree to its terms of use including our legal disclaimer and our privacy policy (Terms of Use). Nauggets Pte Limited UEN 202141030Z retains the right to amend these Terms of Use at its sole discretion and without notice.

This Privacy Policy applies to how we collect, hold, use and disclose Personal Information and provides information on how we deal with your Personal Information as customers, visitors to our website and in relation to the use of our products or services. The application of this Privacy Policy is conditional on your acceptance of the terms of this Privacy Policy

We will comply with this Privacy Policy in respect of information provided to us by persons under the age of 18 years, those persons must obtain the consent of a parent or guardian prior to using our website and/or app and the parent or guardian will be responsible for appropriately supervising the person’s use of our website.

If you would like any further information, or have any queries, problems or complaints relating to these Terms of Use, please contact our Privacy Officer by dhruva@nauggets.com

Scope

This Privacy Policy applies to all Nauggets customers, Nauggets employees, independent contractors, Board members, peers and agents. It also applies to third party suppliers and contractors who provide services to Nauggets.

No advice

The information posted on this website is provided for general information purposes only. Although Nauggets attempts to ensure that information is current and accurate, we cannot guarantee its accuracy or currency. Please seek appropriate professional advice before you act or rely on any of this website's content.

Intellectual Property

Use of the information posted on this website for commercial purposes is prohibited without the prior written consent of Nauggets. Any copying or reproduction of this website or any part of it is prohibited (except to the extent permitted by law) except with the prior written consent of Nauggets.

Links

Where links from this website to other websites are provided, Nauggets makes no representations about the accuracy of information contained on those websites and is not liable for the content of those websites.

Jurisdiction and Limitation

This website and its use are governed by the laws of Singapore. Nauggets disclaims any responsibility to the maximum extent permitted by law for any loss suffered in connection with the use of the information posted on this website or the transmission of any computer virus by us.

Privacy

Nauggets and its related entities understand the importance of privacy. Nauggets has adopted this Privacy Policy as it recognises the right of our customers and others to keep their personal information private. In this policy, personal information means information or opinions about an individual whose identity is apparent or can reasonably be ascertained from the information. Nauggets may amend its Privacy Policy from time to time by posting the amended version on this website. We suggest that you visit this website regularly to keep up to date with any changes.

User Information

During the course of dealing with you, Nauggets may collect basic personal information about you, such as your name, position, company, address, phone number and email address. We may also collect other specific information from you relating to the services or advice you wish to obtain. Where practicable, the purpose for which we collect personal information and the consequences of not providing it will be made clear at the time of collection. Users can generally visit this website without revealing who they are or other personal information. Nauggets will not collect any personal information about visitors to the website except when they knowingly provide it. If you provide us with personal information through this website we may log your usage of the site.

How we use your information

Nauggets will use the personal information we collect for the purpose disclosed at the time of collection or otherwise as set out in this Privacy Policy. We will not use your personal information for any other purpose without first seeking your consent, unless authorised or required by law.

Access to your information

You can access the personal information that Nauggets holds about you by contacting the Nauggets Privacy Officer as set out above. We will provide you with a copy of your personal information unless we are legally authorised to refuse your request. We may charge a reasonable amount for providing access. If you wish to change personal information that is out of date or inaccurate at any time please contact us. After notice from you, we will take reasonable steps to correct any of your information which is inaccurate, incomplete or out of date. If you wish to have your personal information deleted please let us know and we will delete that information wherever practicable. We may refuse your request to access, amend or delete your personal information in certain circumstances. If we do refuse your request, we will provide you with a reason for our decision and, in the case of amendment, we will note with your personal information that you have disputed its accuracy.

Security of information

Nauggets will take reasonable steps to keep secure any personal information which it holds and to keep this information accurate and up to date. Personal information is stored in a secure server or secure files. The Internet is not always a secure method of transmitting information. Accordingly, Nauggets cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorised access or use of that information.

Collecting Personal Information

We collect Personal Information to provide services to our customers and to maintain and grow our customer base. Sensitive Information may be collected where you have given express consent for us to do so and the information is reasonably necessary for us to provide our services, functions or activities or otherwise as required or authorised under law or for the establishment, exercise or defence of a legal claim.

The types of Personal Information we collect and store may include the following:

  • your name;
  • current address;
  • telephone number;
  • email addresses;
  • other forms of identification, i.e. driver's license, passport;
  • your member login details to Naugget’s website, i.e. log in credentials;
  • purchase records
  • correspondence; and
  • other information you may provide.

If we are unable to collect Personal Information we reasonably require, we may not be able to provide you with our products or services.

We collect Personal Information directly from you in a number of ways, including, but not limited to, by email, over the telephone, through written correspondence, on-line by use of tracking software, through our website (i.e. subscriptions to our newsletter, member login and registration, and online purchase) and product and service offerings.

If we receive personal information about you that we did not ask for, from someone other than you, and we determine that we could have collected this information from you had we asked for it, we will notify you, as soon as practicable, that we have collected your personal information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

We will not collect any sensitive information from you, revealing your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability. Exceptions to this include:

  • where you have given express consent for us to do so and the information is reasonably necessary for us to provide our services to you or otherwise carry out our functions or activities
  • the use of this information is required or authorised under Singapore law or a court or tribunal order; or
  • when the information is necessary for the establishment, exercise or defence of a legal claim.

We will not collect personal information unless the information is reasonably necessary for, or directly related to, one or more of our functions or activities. If we are unable to collect personal information we reasonably require, we may not be able to do business with you or the organisation with which you are connected.

To the extent you provide us with any personal information about another individual, you warrant that you are authorised to provide us with that information for use in accordance with this Privacy Policy.

Storage and Security

We hold Personal Information in several ways, including in electronic databases, email contact lists, and in paper files held in secured drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. Our policy is to take responsible steps to:

  • make sure that the Personal Information that we collect, use and disclose is accurate, up to date and complete (and in the case of use and disclosure) relevant; and
  • protect the information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

The steps we take to secure the Personal Information we hold include security (such as encryption, firewalls, anti-virus software, login and password protection), secure office access, personnel security, and training and workplace policies.

Personal information about an individual held by us can only be transferred to someone in a foreign country in certain circumstances including, if there is a similarly stringent privacy protection regime binding that foreign country or if the individual consents to the transfer, or if it is in the individual’s interest.

If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information, please contact our Privacy Officer.

If we no longer need your Personal Information, and unless required to be retained by law, we will take reasonable steps to destroy or de-identify your Personal Information.

Notwithstanding the reasonable steps we will take to secure your Personal Information, breaches may occur. We have established procedures in place to investigate whether a data breach has occurred and if notification or other action is required under Privacy Law requirements.

Websites, Applications and Cookies

Personal Information provided to our Online Shop is encoded using Transport Layer Security technology, a powerful encryption protocol that protects data as it travels over the Internet. Our policy is to ensure that all transactions processed by us meet industry security standards to ensure payment details are protected.

Like many companies, we use 'cookie' technology on our website. 'Cookies' are small text files stored on your computer that websites can use to improve the customer experience, for example by: recognising repeat users, storing registration data, and keeping and facilitating the user's online preferences and use of the websites. Most browsers are set to accept cookies. If you prefer not to receive them, you can adjust your browser to reject cookies, or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our websites (such as preventing members from logging on and making purchases).

Our websites contain links to other webpages. We are not responsible for the privacy policy and contents of such webpages nor their policies regarding the collection, storage, use and disclosure of your Personal Information. We recommend you refer to the relevant webpages and encourage you to always read the applicable privacy statement or policy of the linked site.

Use and Disclosure of Information

The Personal Information we collect is for purposes including how to process your requests and transactions, to provide you with high quality service, to tell you about products we think will be of interest to you, to customise your experience on our site, and to understand your needs so that we may provide you with the most suitable products. We may send this information via post, telephone or any form of electronic communication. We may also use any email address or other Personal Information you provide to us for this purpose.

To help us carry out these activities and functions, on occasion, we may disclose Personal Information to other persons including:

  • organisations that we engage to conduct research or analyse data;
  • our professional advisors (i.e. auditors and lawyers); and
  • government and regulatory authorities (as required or authorised by law).

At any time, you can opt out of receiving marketing material by contacting our Privacy Officer. You agree and acknowledge that if you opt out of receiving marketing material, we will still send you essential information that we are legally required to send you relating to the services we provide. You agree and acknowledge also that removal from our distribution lists may take several business days after the date of your request to be removed.

We take reasonable steps to ensure that any third parties we use are bound by privacy obligations in relation to your Personal and Sensitive Information. In the event of a security incident involving unauthorised access, use or disclosure of Personal Information involving a third party with whom we have shared Personal Information, we will work cooperatively with them to protect the Personal Information that we have shared with them.

Access, Accuracy & Correction - Information

You have the right to request access to your Personal Information that we hold. You also have the right to request its correction if it is inaccurate, incomplete or out of date and we will take reasonable steps to give access to the information in the manner requested and correct it within a reasonable period of time and no longer than 30 days from receipt of your request, subject to any exemptions allowed under the Privacy Law. In these circumstances please contact our Privacy Officer.

Adoption, Use or Disclosure of Government-related Identifiers

Nauggets does not adopt, use or disclose a government related identifier related to an individual except:

  • Where required by law or other legal requirements;
  • Where reasonably necessary to verify the identity of the individual; or
  • Where reasonably necessary to fulfil obligations to an agency or a State or Territory authority.

Quality of personal information

Nauggets takes reasonable steps to ensure that the Personal Information it collects is accurate, up-to-date and complete. Quality measures in place supporting these requirements include:

  • Internal practices, procedures and systems to audit, monitor, identify and correct poor- quality or inaccurate personal information;
  • Systems and procedures that ensure personal information is collected and recorded in a consistent format, from a primary information source, where possible;
  • Timely updating of new personal information is promptly added to relevant existing records;
  • Reminding individuals to update their personal information at critical service delivery points, such as when engaging with the individual; and
  • Contacting individuals to verify the quality of personal information where appropriate, including when it is about to used or disclosed, particularly if there has been a lengthy period since collection.

Cross-border disclosure

We may enter into arrangements with other related entities or third parties outside of Singapore to store, access or use personal information in order to provide services to us (including, but not limited to, data processing and analysis). In these circumstances, we will undertake reasonable steps to ensure that the third parties do not breach the APPs, including by requiring that the third party has information security measures and information handling practices in place that are of an acceptable standard and approved by us.

Your Consent & Variation

By use of our website or where express consent is obtained in relation to our products and services, you consent to the collection, storage, use and disclosure of your Personal Information in accordance with this Privacy Policy and as otherwise permitted under Privacy Law.

We may at any time vary the terms of this Privacy Policy to reflect changes, including to privacy legislation, technological changes, company policy and customer feedback. You should check this Privacy Policy regularly so that you are aware of any variations made. You will be deemed to have consented to such variations by your continued use of our website or other products and services that are subject to this Privacy Policy following such changes being made.

Definitions

Personal Information means any information or an opinion about you for which you can be identified or reasonably identified:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not