Nupo Ventures Pte. Ltd. and our affiliates worldwide (collectively, “Nupo,” “we,” “us,” “our”) understand the importance of privacy to you. This Privacy Statement summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.
It is Nupo’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.
This Privacy Statement applies to all websites and mobile applications (“apps”) operated by or on behalf of Nupo. It also applies to personal information Nupo may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than an Nupo website or app, for example, in person, by telephone, or at a trade show or training; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).
However, different Nupo websites, apps, products, and services have different purposes and features. If additional or different disclosures are required for a specific Nupo website, app, product, or service, then we provide those disclosures (“Specific Privacy Statements”) separately on, or with, the relevant website, app, product, or service. Each such specific privacy disclosure, policy, or statement supplements and amends this Privacy Statement.
General Principles of Nupo’s Collection, Use and Disclosure of Personal Information
In this Privacy Statement, “personal data” or “personal information” shall mean any information about an individual who can be identified from that information or from that information combined with other information to which we are likely to have access, including without limitation, information such as name, address, telephone number, email address, identification numbers, location data, and online identifiers.
Additionally, “process” or “processing” means any operation which is performed upon personal information, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, acquisition, holding, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
To the extent required by applicable law, wherever Nupo collects personal information, Nupo will:
- provide notice to you about our data practices;
- collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate, and not excessive for the purposes for which it is collected;
- process your personal information in a manner consistent with the purposes for which it was collected or to which you consented;
- take reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up to date; and
- take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Nupo.
You have choices about the personal information you provide to Nupo. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for an Nupo website, app, or product.
Personal Information Nupo Collects
Nupo collects the following types of personal information –
Information You Provide:
- contact information, such as your name, company name, job title, address, email address, and phone number;
- additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, marital status, details of dependents, employment history, professional associations and registration numbers, information about how you use our products, and demographic information;
- comments, questions, opinions, requests and orders or sales you may make; and
- as applicable to our farmers and suppliers, information such as the geolocation of farms or businesses, product yields and related analytical information regarding farms or businesses such as inventories and farming methods, financial data such as financing information, pricing, wages, and farmer/supplier identification information such as photographs, signatures, and certificates verifying identity and education.
Information from Business Partners and other Third Parties:
- Nupo collects personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, email address, phone number, education, purchase and sale information.
- Nupo also obtains personal information from other third-party sources, including publicly and commercially available sources.
Information Automatically Gathered from Your Device:
- Nupo collects technical information about your device, such as device and advertising identifiers, browser type, pages you view and the general manner while navigating the site, location data, Internet Protocol (“IP”) address, operating system, date and time of your visit and certain server logs for system administration purposes. Nupo collects this information automatically from your device and web browser through cookies and similar technologies.
Cookies and Similar Technologies
A "cookie" is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences and personalising your online experience.
Certain jurisdictions require that your consent is provided before the use of certain cookies when you visit Nupo websites. If you access an Nupo website from one of these jurisdictions, you will be presented with information regarding your options via a cookie consent banner, including the option to accept or reject such cookies. You will be able to change such settings on the cookie consent banner.
There are certain cookies which are strictly necessary for the function and performance of our website which cannot be rejected.
How Nupo Uses Your Personal Information
Nupo uses your personal information to:
Develop and manage our relationships with you and our Business Partners. This includes: (i) delivering services or carrying out transactions that you have requested; (ii) providing information about Nupo products, services, transactions, and advertisements, that may be of interest to you; (iii) providing you a more consistent experience in interacting with Nupo, including by learning more about you and how you use and interact with Nupo websites, apps, products, and services; (iv) planning, managing, and performing under our contractual relationships with you; (v) providing after- sales support to you; and (vi) in the case of farmers, providing farm-management plans and enhancing farming capabilities.
Provide Traceability in the Supply Chain. Nupo is committed to empowering our customers and producers by providing traceability in the supply chain. Traceability allows for socially and environmentally responsible sourcing in the supply chain of our products. Accordingly, we use farmer and supplier personal information to enhance traceability and strengthen our partnerships with our farmers, suppliers, and buyers while improving our traceability-focused websites and apps and empowering our Business Partners and affiliates to make informed and responsible sourcing decisions.
Foster Careers. You may submit your resume and other information to apply for a job with us either through our sites or via email to an official Nupo email address. We use the information you submit solely for the purposes of considering applications and recruitment (and for purposes of our administration or management if you commence work for us), and not to market to you.
Communicate with you. This includes: (i) informing you of Nupo products, services, events and promotional activities that you requested or may be of interest to you; (ii) providing information about relevant Nupo products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
Provide and improve our websites, apps, products, and services. This includes: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new websites, apps, products and services.
Address legal issues. This includes: (i) complying with our obligations to retain certain business records for defined retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Nupo websites, apps, products or services; and (v) protecting Nupo’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
Manage office visitors. If you visit an Nupo office, we may collect personal information about you, including, but not limited to, your title, name, address, phone number, email address, business or company affiliation, government identification (driver’s license, passport), and other details you provide. We process this information for a variety of purposes, including to generally manage your visit, to verify your identity, to provide access to our facilities and systems, for security and other safety purposes, to communicate with you regarding your visit, to provide information we believe may be of interest to you, including regarding our services, for purposes disclosed at the time a visitor provides Personal Information or otherwise with consent.
Process with your consent. We also use your personal information for other uses consistent with the context in which the information was collected or with your consent. Where you provide us with the personal data of any other individual, you confirm that you have notified the individual of the purposes to which you are providing Nupo with that third party's personal data and you have obtained the person's consent or that you are legally authorised to consent on their behalf to providing Nupo with that person's personal data.
In certain jurisdictions, consent is the primary ground on which personal data may be processed by an organisation. In those jurisdictions, processing personal data in connection with the performance of a contract or legitimate purposes is not recognised as an accepted ground on which personal data may be processed. Accordingly, if you are a resident in such a jurisdiction, you agree that consent will be the ground on which Nupo will process your personal data instead of performance of a contract or legitimate purposes.
Note that we can anonymise or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.
When We Share Your Personal Information
We will not disclose your personal information except under a lawful and measured basis as follows:
- With other Nupo entities. We share your personal information with other Nupo entities, including those in different countries. When we do so, these other Nupo entities will use your information in a manner consistent with this Privacy Statement, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
- Support services. We also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
- Business partners. In some cases, we will share your personal information with third parties who partner with us to provide products and services to our customers, such as distributors in our commercial operations or even with non-governmental organisations who share in our commitment to traceability and sustainability when it comes to farmer and sourcing data. If we do so, we require these third parties to use that information in a manner consistent with this Privacy Statement, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
- Legal obligations. We will also share your personal information with third parties when we have a good faith and belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of Nupo websites, apps, products or services; (iii) to protect Nupo’s rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
- Sale of business. In the event that our business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
- With permission/at your request. We will also share your information with your permission or at your request.
- Anonymously. We share anonymised or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
Your personal information may be stored and processed in any country where Nupo has offices or Data Centres, hosted services or in which we engage external service providers. Your personal information may be transferred to countries outside your country of residence, including to Singapore or the United Kingdom, which may have different data protection and data processing laws and obligations than those in your country in which your personal data was collected. Any such transfer by Nupo shall take place only in accordance with all applicable data protection legislation, but please be aware that the laws and practices relating to the protection of personal information are likely to be different, and in some cases may be weaker than those within your home jurisdiction. Regardless, in all events, we shall apply the provisions of this Privacy Statement to your personal information wherever it is located.
Security of Your Personal Information
Nupo maintains reasonable safeguards to protect the confidentiality, security, and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorised disclosure, we cannot guarantee the security of information provided over the internet and will not be responsible for breaches of security beyond our reasonable control.
Retention of Your Personal Information
There are legal requirements for which we keep some types of data for specific periods of time. Nupo will retain your personal information in accordance with applicable data protection legislation but in any case, for no longer than is strictly necessary for the purposes for which the data was collected. How long we keep your personal information will vary and will depend on the purpose and use of information collected.
We do not collect and process the personal data of children under the relevant minimum age under applicable local legal requirements except for specific services and upon the consent of the holder of parental responsibility.
Links to Other Websites
We have links to other apps, plugins, or websites that are not owned or controlled by Nupo. We are not responsible for the security or privacy of any information collected by such apps or websites. You should exercise caution and review the privacy statements applicable to the third-party websites and services you use. The use of online tracking mechanism by those third-party websites and services is subject to those third parties' own privacy policies, and not this Privacy Statement.
Requests & Clarifications
If you need any clarifications or have any requests with regards to personal information, we hold about you, please direct your queries to our Data Privacy team at email@example.com
GDPR: Additional Information
Where GDPR/UK GDPR is applicable and you are in the EU/UK, and/or where the data controller is an Nupo company established in the EU/UK, then:
Legal Basis for Processing
We will not process personal data without having a lawful reason to do so. We process your personal data where necessary for the performance of a contract to which you are a party, or when it is necessary for compliance with a legal obligation or where required, with your prior consent. We also process your personal data for Nupo’s legitimate interests except where such interests are overridden by your interests or fundamental rights and freedoms. Specifically, the legal bases for the various ways we process your personal information (listed and explained above in the section, “How Nupo uses your personal information”) are as follows:
How Nupo uses Your Personal Information
Develop and manage our relationships with you and our Business Partners
Legitimate interest, and when a contractual relationship exists, in order to fulfil our contractual obligations to you
Provide Traceability in the Supply Chain
Communicate with you regarding services you are party to
Provide and improve our websites, apps, products, and services
Address legal issues
Manage office visitors
Marketing communications and analytics
The law gives you certain rights in respect of the information we collect from you. Among these rights, you have the right to ask us for a copy of your personal data, to verify, correct, or restrict (stop any active) processing of your personal data.
In addition, you can object to the processing of your personal data in some circumstances (namely, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
You have choices about the personal information you provide Nupo. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a particular feature for an Nupo website, app, or product.
If you want to exercise or inquire as to any of these above-mentioned rights, you can email us at the address below.
In your email, clearly state your request and specify the Nupo website or app your request refers to and we will direct your request to the appropriate data controller. If you have unresolved concerns, you have the right to complain to an appropriate data protection authority where you live, work or where you believe a breach may have occurred.
The data controller for your information will be Nupo Ventures Pte. Ltd. and the relevant affiliated entity in your country, as applicable.
We generally act as the data controller for personal data. However, in certain circumstances, Business Partners may engage us to provide them with certain processing services related to personal data. In such instances, the Business Partner’s collection and use of your personal data is governed by its own privacy policies and we rely on their legal representations that we are authorised to process personal data in the manner they propose or demonstrate.
As explained above, we will share your personal information for certain specified purposes. Where your personal information is transferred outside the EEA to an Nupo Ventures affiliate or an entity in a country that is not subject to an adequacy decision by the EU Commission, your personal data will be protected by EU Commission approved cross-border safeguards including standard contractual clauses for cross-border data transfer.
Changes to this Privacy Statement
Where we add new features and functionality to our products and services, we reserve the right to update this Privacy Statement from time to time without notice to you by posting the updates on our website or apps. Any updates will become effective immediately after posting and will apply to all information collected about you, or where required, upon your consent. You are free to decide whether to accept a modified version of this Privacy Statement. If you do not agree to the amendments, you must cease further use of all our websites or apps.