Privacy policy

Naluri is serious about privacy, confidentiality and data security. Your personal data will never be shared with any third parties, except for parties as explicitly stipulated in this Privacy Policy and/or institutions mentioned under the prevailing laws and regulations.

If you enrol via an insurance company or employer, only aggregate data and engagement results will be shared.

Chats with health coaches are only accessible internally within the Naluri coaching team. The coaching team is bound by duties of confidentiality with respect to your personal data.

Naluri uses the latest internationally-recognised data security, encryption and storage systems to safeguard all data.

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 under most circumstances. 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, ‘Website’, ‘Naluri App’’ ), Naluri and each of our respective related corporations which currently include Naluri Hidup Sdn. Bhd. (Malaysia), PT Naluri Hidup Indonesia (Indonesia), Naluri Therapeutics Pte. Ltd. (Singapore) and Naluri Therapeutics Ltd. (Thailand) (hereinafter referred to as the “Company”, “we”, “our” or “us”) (whether or not controlled by us) have or will collect, record, hold, store, analyze, use, disclose, renew, display, transfer, process, and/or erase (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;
• Other information you voluntarily provide through free text input forms, multiple type questionnaires, chats or other means.
• 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”).
• Data shared via Google-based signups are members' names and email addresses. The purpose, collection and processing of it adhere to the purpose, collection and processing of Personal Data as stipulated here.

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:

• 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.
• HealthKit data synced through our API that will only be used in association with health, motion, and/ or fitness services provided by Naluri.

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 (“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.

We do not use, process or retain Personal Data to develop, improve, or train generalized Artificial Intelligence (AI) or Machine Learning (ML) models. Any AI or ML models we utilize are strictly used to enhance and improve the services provided directly to you, and do not involve the use, processing or retention of your Personal Data.

 

Disclosure

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 countries where Naluri operate, including Malaysia, Indonesia, Singapore and Thailand:

• 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; and/or
• our auditors, consultants, accountants, lawyers or other financial or professional advisers.

In addition, your personal information may also be disclosed under the following circumstances

• Under discretion, if it is decided that disclosure of information is necessary as there is a threat to your health, safety or life, or that of other individuals.

In the case of minors, under the Child Act (2001), Naluri is mandated to report individuals who are:

• suspected to be physically or emotionally injured as a result of ill-treatment;
• suspected to be subject to neglect or abandonment.

 

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 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 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 requests in circumstances as provided by the law.

However, Naluri has the right to deny access to personal information and data at the health coaches discretion:

• that access to this information will pose a serious threat to the life, health or safety of the individual involved or any other individual;
• the request for information is frivolous or vexatious; in which case the individual will be asked for a reason for the need to access this information.

 

Data Retention Policy

We will retain your Personal Data for only as long as necessary to serve the purposes set out in this Privacy Policy and Personal Information Collection Statement in compliance with all statutory and regulatory requirements, for as long as it is contractually, operationally, or legally necessary. When we no longer need the information or you have requested for deletion/erasure of your data, we will take reasonable steps to destroy or permanently anonymise your Personal Data if it is no longer needed for such purposes.

 

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.

 

Consent

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.

 

Contact

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 Privacy Policy or your Personal Data, we would be glad to hear from you. Please contact:

 

Email: hello@naluri.life

Tel: +60320117309

 

If you are resident in the European Economic Area, additional amendments may be applicable to you governed by European Union General Data Protection Regulation (“GDPR”), hence we declare the following:

 

GDPR and PDP Law Compliance Statement

We respect and comply with the GDPR and PDP Law

Key ways we comply with these regulations are:

Consent

We explain what you’re consenting to clearly and without ‘legalese’, and ask that you explicitly consent to contact from us.

Breach Notification

In the event of a breach, we will notify affected users within 72 hours of first having become aware of the breach.

Right to Access

Users can request confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. Further, we shall provide a copy of the personal data, free of charge, in an electronic format.

Right to be Forgotten

Once we have compared your (the subjects') rights to "the public interest in the availability of the data", we may delete your personal data where you have requested this.

Data Portability

We allow you to receive the personal data concerning you, which we will provide in a 'commonly used and machine readable format' and you have the right to transmit that data to ‘controller’.

Cookies

Cookies are small text files placed in your browser’s storage. They help us collect standard Internet log information and visitor behavior information. When you visit our websites or user our products, we may collect information from you automatically through cookies or similar technology

For further information, click here.

 

How do we use cookies?

We use cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website
• Protect our website from malicious activities such as automated registrations and bots
• Aggregate anonymous data to help us generate reports of usage such as geographic area, device type, and browser type.

 

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Aggregation – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for security purposes. We may also share online data collected through aggregation cookies with other GDPR compliant sub-processors.
• Marketing Cookies – We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

 

How to manage cookies?

You can set your browser to not accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

 

Where do we store your data?

In Short: We may transfer, store, and process your information in countries other than your own. Our compute resources are located in Malaysia, but we may utilise Hybrid Cloud solutions in other regions as well. We will however take all necessary measures to protect your personal information in accordance with this privacy policy by combining Reasonable Safeguards, Adequate Data Protection Laws, and Explicit Consent.

 

Privacy by Design

We implement appropriate technical and organisational measures, in an effective way, in order to meet the requirements of this Regulation and protect the rights of data subjects'. We hold and process only the data absolutely necessary for the completion of our duties (data minimisation), as well as limiting the access to personal data to those needing to act out the processing.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

Should you have any questions about the processing of data or this privacy policy, you should contact our support using hello@naluri.life

Should you wish to report a complaint or if you feel that our company has not addressed your concern in a satisfactory manner, you may contact our Data Protection Officer In written using addressed mail.

 

Ahmad Shah Hafizan Hamidin

Naluri Hidup Sdn. Bhd.

22, Persiaran Damansara Endah, Bukit Damansara,

50490 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur.

 

In the case you need additional assistance as a result of concern in regards to our DPO decision, you have a legal right to contact European Data Protection Board in your country of residence. For more information about Member Organisations please click here.

 

Privacy Policy of Other Websites or Companies

Our website contains links to other websites or could provide service to third party websites. Our privacy policy applies only to our website, so if you click on a link to another website - or use the service through a third-party provider, you should read and agree with their privacy policy.

 

Naluri’s Terms of Use

If you have read our Privacy Policy, understand your privacy rights and agree to proceed with Naluri’s services, please refer to our Terms of Use.