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Effective date: June 1, 2020


This privacy policy (“Privacy Policy”) sets out the basis which NUGURU WELLNESS SOLUTIONS PTE. LTD. (UEN 202004163W) (“Nuguru”, “we”, “us” or “our”) may collect, use, process, disclose and/or transfer personal data (defined below).

This Privacy Policy applies to personal data of individuals (“you”, or “your”) in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, process, disclose and/or transfer personal data for our purposes.


The following definitions apply in this Privacy Policy unless inconsistent with the context or otherwise specified:

“Mobile App” means the mobile application(s) on which Nuguru offers its Services.
“Nuguru Group” means Nuguru, any of its parents, subsidiaries (as defined in the Singapore Companies Act, Cap. 50) and/or affiliates.
“personal data” includes any information that you provide to us, that we collect or that we are provided with by third parties and that identifies you, or from which you are identifiable, whether directly or indirectly;
“Platform” means the online curated marketplace and platform for Services operated by Nuguru, available via the Nuguru Website and the Nuguru Mobile App.
“Services” means collectively the provision of the Platform, the services, programs and products in the wellness category offered by Nuguru and its network of Wellness Professionals, any ancillary services and products to facilitate the foregoing and any other services which may be provided by Nuguru from time to time.
“Website” means and any of its related sites.
“Wellness Professional” means the wellness professionals who are engaged by Nuguru to provide various wellness services and programs to customers on the Platform.

Other terms used in this Privacy Policy shall have the meanings given to them in the in accordance with the Singapore Personal Data Protection Act (“PDPA”) (where the context so permits).


Depending on the nature of your transaction with us, the personal data which we may collect from you includes (but is not limited to) your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, location, financial information such as credit card numbers, debit card numbers or bank account information, and personal health information.

Such personal data may be collected from you or from persons authorised by you to disclose your personal data to us through the following means, which are not exhaustive:

  • creation of an account on our Platform;
  • indicating your interest to, purchasing, subscribing to and/or participating in a Service on our Platform;
  • use of our Platform, Mobile App, Website and Services;
  • signing up to receive updates from us and asking us to keep in touch with you or provide you with personalised content (such as targeted advertising);
  • any interaction with us and/or any Wellness Professional, including but not limited to any telephone exchange, email exchange, text exchange, chat applications and group communication channels; and
  • providing us with comments opinions and/or feedback about anything relating to Nuguru, the Services and/or the Platform.

Some data such as browsing behaviour will be collected automatically by our Website (for further details, please see our Cookies section below). We may also receive personal data regarding you from third parties and other sources that are publicly available, for example, when we and/or any Wellness Professional interact with you through social media.

The provision of certain personal data by you to us (such as your name, email address, contact information, credit card and such other information as may be indicated by Nuguru) will be compulsory or obligatory in order for Nuguru to provide the relevant Services for the identified purposes. Nuguru may not be able to provide the relevant Services for the identified purposes if you fail to supply the relevant personal data.

Where personal data of a minor is submitted by you, you confirm that you have authority to provide such data to us on behalf of that minor to enable us to process their personal data as described in this Privacy Policy.


We use personal data for relevant purposes where we have a legal basis to use your personal data without consent, and this Privacy Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you.

Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non-mandatory information), you consent to our use of that personal data as set out in this Privacy Policy. For example, we will only process your personal data for marketing purposes if we have your consent to do so.

We may collect, use, process, disclose and/or transfer your personal data for any or all of the following purposes:

  • performing obligations in the course of or in connection with our provision of the Services requested by you;
  • managing your relationship with us;
  • responding to, handling and processing queries, requests, applications, complaints and feedback from you;
  • carrying out reasonable business activities such as audits, risk management, business reporting, service quality control, statistical and trend analysis and other related or similar activities;
  • complying with any internal policies, applicable laws, regulations, codes of practice, guidelines or rules (including those related to fraud, anti-money laundering and anti-terrorism), or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • (if you have given us your consent and in line with your choices – you will have the opportunity to clearly set out whether you wish to receive marketing messages from us by ticking the relevant boxes) sending you marketing communications including newsletters, notifications about new merchant additions, merchant engagements or merchant offers, conducting product surveys, advertising of similar products and services and event invitations, and you have the right to unsubscribe from such marketing communications at any time;
  • enforcing or defending our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration or other legal process;
  • any other purposes for which you have provided your personal data; and
  • any other incidental business purposes related to or in connection with the above.

These purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

The personal data that you provide to us will not sold, traded, licensed, offered or otherwise used for commercial marketing purposes that are not related to Nuguru and/or the Services.


We may disclose and/or transfer your personal data both within and outside of Singapore for the purposes specified above and as permitted or required by applicable laws and regulations to the following entities:

  • any entity within the Nuguru Group;
  • any persons and entities involved in the provision of the Services to you, including relevant Wellness Professionals, credit card companies and processors and third-party payment providers;
  • any third-party service provider, agent, contractor or other organisation which we have engaged to carry out any of the purposes specified above;
  • Facebook, Google, Twitter, Instagram or any other social media provider (if you use your account with them to sign up / in with us), if applicable;
  • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • any third party involved in or in connection with potential or actual litigation, arbitration or other legal process with us;
  • any person or entity to whom we are under any obligation or otherwise required to make disclosure pursuant to legal process or legal or regulatory obligation or request, including disclosure to any relevant governmental and/or regulatory authorities, whether in Singapore or abroad;
  • your organisation or employer (where you are using our Services pursuant to your organisation’s or employer’s corporate benefit or similar scheme); and
  • any person to whom disclosure is reasonable considered by us to be necessary.

We will reasonably endeavour to ensure that any third party who receives your personal data from us shall handle such personal data in accordance with applicable laws and regulations.

Where we transfer your personal data to countries outside of Singapore, we will obtain your consent for such transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.


Cookies are files with small amount of data and may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

As with most websites, our website also uses cookies to collect information. Such cookies include:

  • strictly necessary cookies: such cookies are essential in order to enable you to navigate our website and use its features;
  • performance cookies: such cookies collect information on how visitors use our website and are used to improve our website;
  • functionality cookies: such cookies allow our website to remember choices that you make such as your account username and language and provide a personal experience; and
  • third party cookies: such cookies come with certain functions on our website for which we use third party suppliers such as Facebook Connect. in such case, we recommend that you consult the privacy policies of such third parties for information regarding their use of cookies.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website. By using our website without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device.

For more information on cookies generally and how to delete or reject them, you can visit


The Platform, Website and/or Mobile App may contain links to other third-party websites and microsites, whose privacy practices may differ from those of Nuguru. If you submit personal data to any of those sites, your personal data is not subject to this Privacy Policy.

We encourage you to review the privacy policy of any site you visit. By clicking on or activating such links and leaving the Platform, Website and/or Mobile App, Nuguru does not exercise control over any data or any information which you give to any other entity after leaving the Platform, Website and/or Mobile App. Any access to such other sites or pages is entirely at your risk.


The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing to our data protection officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the same manner.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.


We are committed to protecting your personal data and will use reasonable endeavours to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

In this respect, we have introduced appropriate administrative, physical and technical measures such as storing personal data on secured servers maintained in controlled facilities, using up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and we limit access to your personal data to authorised persons on a confidential and need-to-know basis.

In respect of your financial information, we use credit card processors that comply with strict industry standards and we implement techniques to allow payments to be processed in our systems without saving such financial information.


We generally rely on personal data provided by you or your authorised representative. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our data protection officer at the contact details provided below.


Subject to certain exceptions, you may request a copy of or correction to your Personal Data held by us by contacting our data protection officer at the contact details provided below.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Depending on the applicable local laws and regulations in your region, you may have additional rights with regard to your personal data such as the right of erasure, the right to data portability and the right to restrict and object to certain processing of your personal data.

We will use best endeavours to comply with your request to exercise the above-mentioned rights, to the extent required by applicable law. However, if you ask us to stop processing your personal data in certain ways or erase your personal data, and this type of processing or data is needed to facilitate your use of the Platform, Website Mobile App, and/or Services, you may not be able to use the Platform, Website Mobile App, and/or Services as you did before.


We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected as outlined in this Privacy Policy, for the purpose of satisfying our business (accounting and reporting) or legal requirements, but also to properly resolve disputes or to troubleshoot problems, or as required or permitted by applicable laws.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.


Should you have any questions regarding this Privacy Policy, or if you wish to make any request regarding your personal data, please contact our data protection officer by email at


We may amend, vary or modify this Privacy Policy in its sole discretion from time to time without any prior notice. The latest version in force is available on our website at

Your continued use of our Services after we update the Privacy Policy on our website will constitute your acknowledgment of the revisions and your consent to abide and be bound by the latest version of the Privacy Policy.


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