Privacy Policy


Shuga Pte. Ltd. (“Shuga” or “we”, “our” or “us”) has adopted this Privacy Policy to inform you about how we collect, use, disclose or otherwise process information derived from your use of our products, websites, services and mobile applications made available from time to time by us, including iOS, Android, and Windows Mobile versions (the “Shuga Platform”). The capitalised terms in this Privacy Policy have the same meanings as those in the Terms and Conditions found at Terms and Conditions page (the “Terms”).

You will be asked to consent to the terms of this Privacy Policy when creating an account on the Shuga Platform. By creating an account, you agree to the collection, use and disclosure (including overseas transfers) of your Personal Data (defined below) and (with your consent) to direct marketing, each as set out in this Privacy Policy.

This Privacy Policy may be amended from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Please visit this Privacy Policy webpage frequently for the most current version before relying on any of the provisions here. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Ms. Stefanie
stefanie@shuga.io
6389 5323
2 Alexandra Rd, #06-01, Delta House, Singapore 159919

By using the Shuga Platform (including the products and services provided through the Shuga Platform), you agree that we collect, use, disclose and process the Personal Data (as defined below) you provide by registration on the Shuga Platform as a User or during any exchange through the Shuga Platform with us. We will not share any Personal Data with other parties except in the manner described in this Privacy Policy.

“Personal Data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access. If you are using the Shuga Platform or other products in Singapore, “Personal Data” has the meaning as defined in Section 2 of the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”). We will collect, use, disclose and process your Personal Data in accordance with the PDPA.

The Personal Data that we may collect from you will depend on the products, services, and promotions that are used by you. Your Personal Data will be collected by us when you:

  1. Sign up as a User through the Shuga Platform and/or submit any forms relating to any of our products and services;
  2. Update your User account;
  3. Use the Shuga Platform and any of our products and services;
  4. Sign up for alerts or newsletters; and
  5. Send us enquiries or requests for assistance.

Please note that collection of your Personal Data for certain products and services may be a prior requirement, such as for access to the services or to process any voucher redemptions.

The Personal Data collected by us will depend on the nature of your interaction with us and may include information relating to the following:

  1. Your identity: This includes your full name, e-mail address, date of birth, phone number, photographs, device ID, IP address, and payment-related information (e.g. bank account details or details of your account with a payment service provider such as PayPal).
  2. Your interactions with us: This includes recordings of your phone calls with us, emails you sent, and other records of any contact you have with us.
  3. Your User account: Details relating to your User account.
  4. Use of our services: This includes using cookies to track information relating to your location and your interaction with the Shuga Platform (e.g. the pages within the Platform that you visit, the time spent on those pages, items and information searched on the Shuga Platform, access time and dates, information relating to clicks and redirects, and purchases made).
  5. Your Preferences: This includes details that you have shared with us as to how you would like to be contacted, and your preferred products and brands.

We may also collect your Personal Data from third parties (such as business partners, social media providers and/or fraud prevention agencies) whom you have duly authorised to disclose your Personal Data to us and/or from publicly available sources.

We have no obligation to keep private Personal Data that you make available to other Users via the Shuga Platform. Details which relate to your use of your User Account such as duration and general patterns of use may be recorded and processed by us so as to improve your experience as a User.

We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

We may collect, use and process your Personal Data for any or all of the following purposes:

  1. performing obligations in the course of or in connection with our provision of the products and/or services requested by you;
  2. verifying your identity;
  3. managing your relationship with us, including responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
  4. processing payment or credit transactions;
  5. to deliver, develop and improve products, content and services which you have registered for. This may include using your Personal Data to track the crediting of points (or such other name and method of tracking and crediting usage and rewards from the use of the Shuga Platform) with merchants and/or to activate or deactivate your User account with us;
  6. communicating with you regarding voucher redemptions and/or any of your requests or queries;
  7. identifying your product and services preferences;
  8. administering loyalty, rewards and promotional programs;
  9. improving the effectiveness of the Shuga Platform;
  10. preventing fraudulent transactions;
  11. conducting market research, analyses, and surveys (at times in conjunction with our preferred partners) in order to understand your preferences, develop new services, personalise or otherwise improve the services being offered by us, or provide personalised recommendations and relevant marketing communications;
  12. providing third party merchants who partner with us (including merchants who provide lead generation to us) with meaningful data relating to User preferences and behaviour, as well as analytics and research in relation to such data, for the other purposes set out in this Privacy Policy and to enhance their product and service offerings, as part of the terms of our partnerships and arrangements with such merchants integral for the provision of our products and services;
  13. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  14. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the purposes set out in this Privacy Policy; and
  15. any other purposes for which you have provided the information and any other incidental business purposes related to or in connection with the above.

By consenting to the Terms, you also agree to receive marketing communications from us and consent that we may use Personal Data provided by you to send you information about us and the Shuga Platform, including news about product updates, promotions and special offers, to your email address, telephone number (whether by text messages, picture messages, call or otherwise), device running the Shuga Platform, home address, office address, or other types of messages directly sent to you outside or inside the Shuga Platform (“Messages”) but we will not share any Personal Data with third parties for marketing purposes without your consent. Instructions for discontinuing your receipt of such Messages from us will be provided in such Messages. Please refer to the Terms for information on how to opt out from such Messages.

We may also allow third parties located inside and outside Singapore performing services for us and/or merchants to access and use your Personal Data for the purposes set out in this Privacy Policy, but only to the extent necessary to provide those services and/or to allow us to perform the purposes set out in this Privacy Policy, including to bring you better deals and promotions.

Third party websites and other companies with links to and from the Shuga Platform may collect Personal Data about you when you visit their websites and as a requirement to using their services. This Privacy Policy does not extend to those third party websites and other companies. You should refer to the privacy policies set out on those websites.

The purposes listed in this Privacy Policy 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). Your Personal Data may be released by us to comply with court orders or laws that the disclosure of such information. If we participate in a reorganization, sale or merger, and if permitted by applicable law, you will be notified if your Personal Data has been transferred to the relevant third party.

We shall use our best endeavours to ensure that our employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of your Personal Data will observe and adhere to the terms of this Privacy Policy.

For the avoidance of doubt, we will not under any circumstances rent or sell any of your Personal Data.

The data collected by us may be transferred to and stored at destinations outside Singapore. It may also be processed by personnel operating outside Singapore who work for us or for one of our service providers. By providing us with your Personal Data information, you agree to this transfer, storing, and/or processing. To protect your Personal Data, we will enter into appropriate contractual arrangements or otherwise with any companies we share data with outside Singapore to ensure the safeguarding of your Personal Data and that such parties will act at all times in compliance with applicable laws. Further, we will only transfer your Personal Data to locations outside of Singapore where we are satisfied that an adequate or comparable level of protection is in place to protect your Personal Data held in that country.

We will retain your Personal Data for so long as necessary for the purposes for which we collect it (as set out in this Privacy Policy), our legal or business purposes, or as required by relevant laws. Where this is open-ended, such as where you agree we can send you emails about events, you can contact us or contact our data protection officer at any time to request that we stop using your data for these purposes. We will regularly review in accordance with applicable laws and regulations and will destroy and/or annoymise the Personal Data in our possession if the purposes for which it was collected has ceased and/or retention is no longer necessary for legal or business purposes.

Cookies are small files placed on your computer by websites that you visit or certain emails you open. Cookies customise your use of a product or website, keep records of your access to the website or product, or store information required by you while accessing the website or product. For instance, when you log on to the Shuga Platform, we may store your User id, your IP address and time of login as a cookie on your hard drive. This cookie allows you to move from page to page without having to log on again on each page. You can disable cookies by modifying your browser settings, but doing so may affect your experience on our website.

Information to do with your use of the Shuga Platform such as billing for services provided to you by us (including those through the Shuga Platform), your User account, and details about your internet connection is uploaded to our servers. Please note that we may use software which generates and submits reports of bugs to us whenever a crash or other issue is faced in the Shuga Platform, and such bug reports may contain information which includes information about other software or hardware on your computer system. This information is not stored with your Personal Data. However, if you manually submit a bug report to us through email or through the Shuga Platform’s support services, this report will be associated and stored with your Personal Data.

We adopt adequate data collection and processing practices. Digital security measures have also been put in place to protect against intrusions, alterations and disclosures of Personal Data by individuals seeking to gain unauthorised access to system data.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct and You may correct, update or remove your Personal Data from our records. Failure on your part to ensure your Personal Data is complete, accurate, true and correct may result in the inability to provide you with the products and services that you have requested.

You may contact our Data Protection Officer in writing to access your Personal Data if you are concerned about the accuracy of the Personal Data maintained by us as set out below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

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). In general, we will decline requests which jeopardise the privacy of others, or which threaten the safety of others.

You may also withdraw your consent for the use of your Personal Data by submitting your request in writing to our Data Protection Officer. 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 ten (10) 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 products 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 manner described above.

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.

If you have any questions about this Privacy Policy, you may contact us at hello@shuga.io or through the Shuga Platform’s support services.

Address

Singapore Office (Headquarters)
2 Alexandra Road #06-04
Delta House
Singapore 159919

Taiwan Office
No. 147 Section 2
Jianguo North Road
Zhongshan District
Taipei City 10491