Privacy Policy

Last updated April 1, 2021

This Privacy Policy (“Privacy Policy”) describes the practices of Nuguru Wellness Solutions Pte. Ltd. (UEN 202004163W) (hereinafter “Nuguru”, “we”, “us” or “our”) as they pertain to information collected through our website at www.nuguru.com (“website”). This Privacy Policy does not apply to the websites, mobile applications, or other services operated by Nuguru’s portfolio companies, unless this Privacy Policy is posted on any of those websites. If you are located in the European Economic Area (“EEA”) or United Kingdom, Nuguru is the data controller with respect to the processing of your personal data pursuant to GDPR.

Please read this Privacy Policy carefully to understand our information practices with respect to our website. If you do not consent to the terms of this Privacy Policy, please do not access this website or provide us with any of your personal data.

We may change this Privacy Policy from time to time, and any modifications will be effective immediately upon posting, unless indicated otherwise.

Information We Collect
We collect information in multiple ways, including when you provide information directly to us and when we passively collect information from or about you, such as from your browser or device. We may combine all of the information we collect from or about you from these various sources.

Information You Provide to Us
We collect any information that you provide to us, including, but not limited to, when you (1) sign up for our newsletter; (2) email us; (3) provide feedback in online surveys; or (6) submit other content and suggestions. Such information may include:

  • Full name;

  • Contact information (e.g., email address, phone number);

  • Employment information (e.g., company name, your role or title, assistant name and contact information);

  • Professional bio and photo;

  • Content you submit in connection with a Partnership application;

  • Survey responses; and

  • Any other information you choose to include when you contact us.

On occasion, we may ask for additional information to enable us to provide you with access to and use of certain other information, materials and services.

Information We Collect from Affiliates and Non-Affiliated Third Parties
We may collect or receive information about you from affiliates, non-affiliated third parties and other sources, including publicly available websites and resources. We may add this information to the information we have already collected from you through our website in order to enhance and improve the services we provide, or use such information for our and/or our affiliates’, subsidiaries’ and portfolio companies’ business and operational purposes.

Information We Collect from Social Media and Other Content Platforms
In some cases, you may be able to access our website via social media or other third-party platforms (such as a log-in feature on LinkedIn, Facebook, Google and Twitter). By using these services to connect with us or providing a link to your social media profile in a Partnership application, you may allow us to access information from your social media profile, such as name, gender, and profile picture, consistent with your privacy settings or as allowed by you on that service. If you do not wish to have this information shared, do not provide us with such links and do not use such third-party platforms to access our website. When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. Please note that your use of such third-party platforms is governed by those services’ privacy policies. We have no control of, and assume no liability for, the privacy practices of third-party services.

Information We Collect Through Automated Means
We also collect information through automated and technical means as you browse our website.

  • Usage Information. As you browse the website, we and our service providers (which are third party companies that work on our behalf to provide and enhance the website) use a variety of technologies, including cookies and similar tools, to assist in collecting information about how you interact with it. For example, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type, domain name and settings, referring / exit pages and URLs, how you interact with links on the website, pages and content viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the website and other such information.

  • Location Information. We collect and process general information about the location of the device from which you are accessing the website (e.g., approximate geographic location inferred from an IP address). If you do not want us to see or access your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.

  • Cookies and Other Tracking Technologies. We and our service providers may also collect data about your use of the website through Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website that enables us to: (a) recognize your computer; (b) understand the web pages of the website you have visited; (c) recognize repeat users; (d) facilitate the ongoing access to and use of a website; (e) allow the website to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising; (f) enhance your user experience by delivering content and advertisements specific to your inferred interests; (g) perform searches and analytics; and (h) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the website and associated advertising, and to access user cookies. We and our service providers may also include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we and our service providers adopt additional technologies, we may also gather additional information through other methods. You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). However, note that by blocking any or all cookies, you may not have access to certain features or offerings on the website.

How We Use Your Information
We may use the Personal Information we collect from and about you for the following business and commercial purposes:

  • For the purposes for which you provided it;

  • To maintain, provide, operate, and improve the website;

  • To send you information or other communications;

  • To identify you by your device(s) and to match your device(s) with other browsers or devices you use for the purpose of providing relevant and easier access to content and other operational purposes;

  • To enhance your experience on the website;

  • To prevent or address technical or security issues, including bug detection and fraudulent activity;

  • To engage in internal analytics, research, auditing, and reporting;

  • To support our and our affiliates’, subsidiaries’, and portfolio companies’ recruiting efforts;

  • To connect with vendors and service providers who assist in our business operations;

  • To comply with the law and protect the safety, rights, property, or security of the website and the general public;

  • To enforce the legal terms that govern your use of the website; and

  • Other purposes for which we notify you.

Please note that we may combine information that we collect from or about you (including automatically collected information) with information we obtain about you from our affiliates, subsidiaries, and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.

We may aggregate and/or de-identify information collected through the website. We may use aggregate or de-identified information for any purpose, including without limitation for research and analytics, and may also share such data with any third parties, including partners, affiliates, subsidiaries, portfolio companies, services providers, and others.

Our Legal Bases for Using Your Information
The legal bases for using your information as set out in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract with you;

  • Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to operate and secure our website; comply with legal requirements and defend our legal rights);

  • Where we have your consent, in accordance with applicable legal requirements, to use your information for a particular purpose; and

  • Where we use your information to comply with applicable legal obligations.

How We Share and Disclose Your Information
We may disclose and/or share your information as described below and elsewhere in this Privacy Policy, including with:

  • Third Parties Designated by You. If you direct us to share information with a third-party partner or other entity or as necessary to provide you with a service you request, then we may share your personal information.

  • Affiliates and Subsidiaries.

  • Business Partners.

  • Service Providers. We may provide access to or share your information with select entities that use the information only to perform services on our behalf.

  • Business Transactions. We may disclose your personal information in connection with the evaluation of or entering into a corporate transaction where all or a portion of our business or assets (including any associated lists containing your personal information) change ownership, are sold, or are transferred.

  • Third Parties for Legal Purposes. We may disclose your personal information in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served; (iii) to protect or defend the rights or property of Nuguru or users of the website; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any associated Terms and Conditions.

Information Retention
We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Website Analytics
We may use third-party web analytics services on our website to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here: https://tools.google.com/dlpage/gaoptout.

Do-Not-Track Disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes. However, we do not currently recognize or respond to browser-initiated DNT signals.

Additional Information for Residents Outside of Singapore
Nuguru is a Singapore company, but operates globally. As such, we may store your information in Singapore, and transfer your information to service providers and other parties (as described in “How We Share and Disclose Your Information” above) located outside your country of residence, including Singapore. Data privacy laws vary from country to country and may not be equivalent to, or as protective as, the laws in your home country. We take steps to ensure that reasonable safeguards are in place to provide an appropriate level of protection for your information, in accordance with applicable law. These measures include data transfer agreements. By providing us with your information, you acknowledge any such transfer, storage or use.

Local legal requirements, such as those in the EEA, may afford you additional rights. Your local laws (such as those in the EU) may permit you to request that we:

  • provide access to and/or a copy of certain information we hold about you;

  • prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling);

  • update information that is out of date or incorrect;

  • delete certain information that we are holding about you;

  • restrict the way that we process and disclose certain of your information; and

  • revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period required under applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances such as if we need to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at questions@nuguru.com.

Changes to Our Privacy Policy
We may change this Privacy Policy to reflect changes in the law, our information practices or the features of the website. We will indicate at the top of the Privacy Policy the date of the most recent update. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the website, you are confirming that you have read and understood the latest version of this Privacy Policy.

Governing Law
This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore.

Contact Us
If you have any questions about this Privacy Policy or Nuguru’s practices, please contact us at hello@nuguru.com.