- We are very serious about privacy, confidentiality and data security
- We do NOT share any of your data to third parties. If you enrol via an Insurance company or employer, we will only share with them your health results (e.g., weight, blood sugar), and your engagement (how often you use the app). We do NOT share what you discuss with coaches or your responses to our modules or journals.
- Your chats with health coaches are private. No one outside the chat groups read them. Coaches from other chat channels do not have access to chat messages in other channels. Coaches will compare notes with each other to coordinate the best support for you, in a separate coach-only message board.
- We invest in using the latest internationally-recognised data security and storage systems to safeguard your user login, encrypting messages you send to the server, and safeguarding your data on private servers.
We, at Naluri, are committed to the protection of your Personal Data and place the matter of protecting your privacy as our utmost priority. We are committed that you retain full control over your personal and health information. We will not disclose or use any of your information for any other purpose except those outlined below.
- Collection and Processing of Personal Data
We hereby inform you that we, Naluri Hidup Sdn Bhd (1222842-H). and each of our respective related corporations (hereinafter referred to as the “Company”, “we”, “our” or “us”) (whether or not controlled by us) have or will collect, record, hold, store, use, disclose and/or process (collectively referred to as “Process”) one, or all of the following categories of personal information about you:
- master data: name, gender, date of birth, citizenship, nationality;
- contact details: home address, correspondence address, billing address, home phone number and mobile number, e-mail address, work address, work number;
- compensation / payment details: bank account details, credit card details, banking information, credit records;
- verification details: information pertaining to the verification of identity, including identification type, NRIC No., and identification number;
- Health information, e.g. height, weight, family medical history, chronic disease history;
- Other information, e.g. resumes or CVs when applying for a job at the Company;
- data relating to online session: browser type and version, operating system, domain name; and
- any such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us. (collectively, “Personal Data”).
To the extent that you disclose to us any personal information above of any individual, we shall assume that you have obtained such individual’s consent for the disclosure as well as the Processing of the same in accordance with the terms of this notification (“Notification”).
- Sources of Information
Your Personal Data has and / or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
- information provided or submitted by you through among others, the use of our website, social media and phone applications;
- information gathered through promotional activities;
- cookies that your web browser store on your computer when you visit a website;
- as applicable, publicly available or publicly accessible information; and
- such other written or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.
As the accuracy of your Personal Data depends largely on the information you provide to us, kindly inform us as soon as practicable if there are any errors in your Personal Data or if there have been any changes to your Personal Data.
- Purpose of Processing Personal Data
We will Process the Personal Data that you have provided to us for the following purposes, including but not limited to (“Purpose”):
- To manage the delivery of notices, services or products to you;
- To manage and verify your account and identity; and complete transactions with you;
- To enable us to provide our services and perform our services to you;
- To notify you about benefits and changes to the services offered;
- To protect the safety and well-being of yourself and/ or other customers;
- To enable you to participate in promotions, offers and contests;
- To improve our service;
- To send you updates on products, news and event updates, rewards and promotions, special privileges and initiatives offered by the Company, where applicable;
- To maintain records required for security, claims or other legal purposes;
- To respond to any enquiries, complaints, comments or feedback that you submit to us;
- To comply with any regulatory, statutory or legal obligation imposed on us by any relevant authority;
- To develop, market and communicate to you in relation to products and services offered by the Company;
- To contact you for product or customer satisfaction surveys and market research;
- To conduct statistical analysis and run machine learning algorithms, and create a data pool so that we can better understand our customer profile and improve our services to you;
- To produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
- To third parties with whom we have contracted to provide services to us (such as analysis on our behalf) for any of the purposes described above. Where we disclose your personal data to third parties we shall ensure that such data is used only to provide services to us;
- For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.
- For the prevention of crime including but not limited to fraud, money-laundering, and bribery;
- For meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or any of our member companies; and / or
- In order to fulfil any purpose directly related to the above purposes.
Personal Data provided to us will, generally, be kept confidential but you hereby consent and authorise us to provide and / or disclose your Personal Data to the following categories of parties, who may be based/located inside or outside of Malaysia:
- any person to whom we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;
- pursuant to an order of a court of competent jurisdiction;
- any related and associated companies, affiliates and subsidiaries of Naluri Hidup, including those established in the future;
- where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the purposes laid out above;
- parties which participate in joint marketing schemes with us;
- any agent, contractor or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;
- any party or organisation who are bound by confidentiality agreements with us;
- any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;
- government agencies, statutory authorities and industry regulators;
- our auditors, consultants, accountants, lawyers or other financial or professional advisers; and / or
- our sub-contractors or third party service or product providers as may determine to be necessary or appropriate.
- Impact resulting from failure to supply and consent to the Processing of Personal Data
- Except for Personal Data which is Processed for direct marketing purposes as well as those set out in clause 1(e) above, it is obligatory for you to provide certain categories of Personal Data which we request from you for the said Purpose. Failure to supply and consent to the Processing of the Personal Data in relation to the Purpose will:
- result in us being unable to provide you with the information, notices, services and/or products requested; and
- affect the ability of the parties to enter into the necessary agreement in relation to the provision of our services to you.
- It is optional for you to provide the categories of Personal Data which we request from you for direct marketing purposes.
- Your Rights of Access and Correction
You have the right to, subject to payment of the prescribed fees where applicable (there is a maximum limit on fees Naluri can charge), request access to and/or correct your Personal Data and/or limit the Processing thereof. In this respect, you may:
- check whether we hold or use your Personal Data and request access to such data;
- request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
- withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.
Please note that depending on the information requested and where permitted by law, a nominal administrative fee may be charged. We will endeavour to provide the information back to you as soon as practicable; however we also reserve the right to validate all requests for the authenticity of the request. We may refuse to comply with data access request in circumstances as provided by the law.
- Job Applicants
Personal Data provided in connection with an application for employment will be used to determine your suitability for a position with the Company and, if applicable, your terms of employment or engagement. Your information may also be used to monitor our recruitment initiatives and equal opportunities policies.Your details may be disclosed to third parties to verify or obtain additional information including education institutions, current/previous employers and credit reference agencies. Credit reference agencies record these searches and you can contact us to find out which agencies we used. Unsuccessful applications may be retained to match your skills to future job opportunities.
By submitting your personal data, you consent to the use of that personal data as set out in this Policy. If we change our Policy, we will publish the amended version on this page and notify you of any changes. Continued use of the service will signify that you agree to any such changes.
- Notification of Changes
Please note that this Policy may be amended from time to time in accordance to applicable laws and regulations and such variations may be applicable to you. In the case of any changes, you will be notified, and the latest version of this Policy will be made available to all customers.
Naluri is committed to protecting your personal data and strives to provide a safe, secure user experience. If you have any questions (including your rights of access and correction), comments or suggestions regarding this Policy or your Personal Data, we would be glad to hear from you. Please contact:
Wan Mei, Marketing Executive
email: [email protected]