Last updated on 9 April 2019
(a) From that data; or
(b) From that data and other information to which Nugget has or is likely to have access. Personal data includes, among other things, personal information that you voluntarily provide on this Website and/or Mobile application, and on third-party websites, which may include your name; mailing address; e-mail addresses; telephone number(s); date of birth; gender; nationality; passport number; payment information and any other types of information that you choose to provide to us or that we may collect about you through your transactions with Nugget.
Consistent with the choice you make when providing personal information, Nugget may use your personal information to provide you with information, special offers, and promotions via various means including email.
In addition to personal data that you provide to us, we may collect certain information about you that is not generally or uniformly considered personal data and which we consider to be non-personal data. We collect this information to create a better user experience and to identify areas of improvement for our services. Such data may include information such as the type of Internet browser you are using, your IP address, the type of content you are reading, the type of products you are interested, how and when you arrive at our Websites and/or Mobile Application (i.e., through a search engine or a referring website), and other types of information.
Nugget will have read-only access via a 3rd party provider (SaltEdge Inc) to the following information relating to your banking account and transaction details. We use the financial transactions to deliver a service that provides you with an automated weekly budget to help you take control of your savings goals.
We will maintain strict confidentiality and will not sell, lease or distribute your data. Only trusted service providers involved in the operations of our business will have restricted access to the data to provide you with the service.
Nugget adopts a 3rd party aggregation solution in processing the users’ financial data. By using Nugget, you acknowledge and represent that you are the legal owner of the Provider Account Data and that you have the authority to appoint and do expressly appoint our affiliates or such 3rd party providers as your agent to access and retrieve Provider Account Data on your behalf. Failure to allow such disclosure, access to or use of your information may result in our inability to offer or continue to offer the services to you.
You further acknowledge that affiliates or such 3rd party providers do not review or analyse Provider Account Data and you agree that we are not responsible for its completeness or accuracy.
There are rigorous measures in place to ensure the following:
(a) Harden Database with firewalls and SSL encryption
(b) Data is encrypted during resting and during transmission.
(c) Anonymity of data. (ie. cannot be tied to any individual)
(d) Data is read only (ie. cannot be changed)
(e) Restrict access to user data and information by our staff on a need-to-know basis only.
(f) Logs to monitor access activities.
Cyber hygiene, best practices and cyber policies, standards and procedures are of paramount importance.
We have partnered a Crest certified Cyber Security organization to ensure we have a robust architecture to protect ourselves from cyber vulnerabilities.
Their security experts are equipped with the industry’s de-facto and best cyber security certifications (including CREST) to ensure that they are well equipped with up-to-date technical skill. The certifications include information assurance, security audit, offensive and defensive security.
The aforementioned security efforts do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not warrant that our servers or network will be immune from such attacks. We are not liable for any loss or damage arising from such risks.
We will retain your account information and data for as long as you use Nugget. If you decide to stop using Nugget, we will delete all such data within a reasonable time after the termination of the service, subject to retention for purposes of complying with applicable laws, resolving disputes, enforcing the terms of our agreement with you and protecting Nugget’s intellectual property rights.
Information collected about your use of this Website and Mobile Application may be combined with personal or other information about you from other online or offline sources. If you prefer that we do not collect information through cookies, about your use of this Website and Mobile Application, please delete and disable cookies for each browser, on each computer you use.
Most browsers are set to accept cookies by default. If you prefer, you can set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. If you use multiple browsers (e.g. AOL, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g. work and home), you need to set each browser on each device.
Nugget may disclose your personal and other information to our affiliates and to unaffiliated third parties if we believe in good faith that such disclosure is necessary:
(a) To comply with the law or in response to a subpoena, court order, government request, or other legal process;
(b) To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
(c) To protect the interests, rights, safety, or property of Nugget or others;
(d) To enforce any terms of service on this Website and Mobile Application;
(e) To provide you and other users with the services or products requested by you and/or the other users (including allowing a Nugget division to continue to serve you), and to perform other activities related to such services and products, including billing and collection;
(f) To provide you with special offers or promotions from Nugget that may be of interest to you; or
(g) To operate Nugget’s systems properly.
Any personal information you provide to Nugget is kept on secure servers. Nugget uses reasonable administrative, technical, personnel, and physical measures
(a) To safeguard personal users’ information against loss, theft, unauthorized use, disclosure, or modification; and
(b) To ensure the integrity of the users’ information. To help us protect your privacy, you should maintain the secrecy of the logon ID and password you may have set up in connection with your participation in this service.
Nugget may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.
Singapore Residents: If you are a Singapore resident, you will have more control over how your personal data is collected, used and disclosed. You also have rights of access and correction in relation to your personal data. This means that you may request any organisation which possesses your personal data to give you access to and amend your data as and when you find it necessary. The Do Not Call (DNC) Registry will also allow you to opt out of unsolicited marketing calls, messages and faxes. Your personal data is protected under The Personal Data Protection Act 2012 (PDPA).
European Specific Provisions: If you are subject to applicable data protection laws of the European Union, with effect from May 25, 2018, Nugget will process Personal Data in accordance with the GDPR requirements directly applicable to Nugget’s provision of its services to you.