NUGDi Privacy Notice

Introduction

At nugdi.com SV Limited (referred to as "NUGDi", "we", "us", and "our"), we are fully committed to safeguarding the privacy and personal information of our users. If you are located in the United Kingdom (UK) or the European Union (EU), NUGDi acts as the data controller, unless otherwise specified. Please carefully review the following Privacy Notice, which outlines how we collect, manage, and protect your personal data to ensure transparency and trust in every interaction.

This Privacy Notice (“Notice”) applies to the website www.nugdi.com , as well as all NUGDi-affiliated websites (“Sites”) and our mobile or web applications (“Apps”) — collectively referred to as our “Services.”

Contacting us

If you have any questions, comments, or requests regarding this Notice, you may contact us through our Contact Us page or by email at info@nugdi.com. We are always happy to assist you and address any concerns related to your privacy.

What information do we collect & how do we use it?

This Privacy Notice is applicable in the following circumstances:

⦁ You visit or browse our Sites or Apps.

⦁ You order products from, or book appointments with, our Partners through us (referred to as a “Client”).

⦁ You purchase a NUGDi gift card for use with participating Partners (also referred to as a “Client”).

⦁ You are self-employed and/or work for a business that uses the NUGDi platform (we’ll refer to you and/or that business as a “Partner”).

We will only collect and use your personal information when we have a valid and lawful reason for doing so, in accordance with applicable data protection laws. Your phone number is handled strictly in line with the terms outlined below. NUGDi does not sell, share, or disclose your phone number to any third party, except where required by law. In the following sections, we outline the specific reasons for collecting your data and explain what each of these legal bases means under the heading “What do each of these legal reasons mean?”

If you visit our services

We use your personal information to deliver and improve our Services. Whenever you access or interact with any of our Services—whether you are simply browsing or using a registered account—we automatically collect certain information each time you visit our Sites. This may include technical details, usage data, information about your visit, and, if you choose to opt in, your location data.

Technical information

Technical information may include details such as your phone number, Internet Protocol (IP) address, login credentials, browser type and version, browser plug-in types and versions, device identifiers, social login ID or email address, time zone settings, operating system and platform, hardware specifications, and device settings (e.g., language and time zone). It may also include file and software names or types associated with your device and/or the Services, as well as battery level, signal strength, and information related to your mobile network operator or Internet Service Provider (ISP).

Information about your visit

Information about your visit may include details such as the full Uniform Resource Locators (URLs), clickstream data to, through, and from our Site (including dates and times), pages or services viewed or searched for, and demographic information (such as age and gender). It may also include page response times, download errors, duration of visits to specific pages, and page interaction data (including scrolling, clicks, and mouse-overs). Additionally, we may collect information from traceable campaign links (for example, in emails or tracking URLs), the methods used to navigate away from a page, and any phone numbers used to contact our customer service team, or social media handles used to engage with our customer support channels or official social media accounts.

Location data

Location data may include information such as your country or regional location, derived from your full or partial IP address and/or Google Analytics data. We use this information to provide location-based services (where you request or permit us to do so), enabling us to deliver content, advertising, or other services that rely on knowing your approximate location — for example, to help detect and prevent fraudulent transactions.
Location data may also be collected in combination with your device identifier (ID), allowing us to recognize your mobile browser or device when you return to our Services.

The delivery of location-based services may require us to verify one or more of the following:
- The geographical coordinates (latitude and longitude) of your current location.
- Your country or region, determined by referencing your current IP address against publicly available sources.
- Your device’s unique advertising identifier, such as the Identifier for Advertisers (IFA) on Apple devices, the Android ID on Android devices, or another similar device identifier.
You may enable or disable location sharing at any time by adjusting your device’s privacy or location settings.

We utilize this automatically collected information to:

We use this information to better understand how individuals interact with our NUGDi Site and identify opportunities for ongoing improvement. Our goal is to ensure that all content on our Site is displayed in the most efficient, accessible, and engaging way for you and your devices. Additionally, we utilize this data to deliver the information, products, and services you request from us — as well as those we believe may align with your interests and preferences.

Automated decision-making

We may use ‘profiling’ or automated decision-making tools when processing the personal data we automatically collect about you. This allows us to better understand your preferences and interests. We may use this information to provide you with personalized marketing communications through email, SMS, postal mail, social media advertisements, and other digital channels from NUGDi regarding our Services.

If you contact or engage with us

If you contact or engage with us, we will collect your contact details along with any other information you choose to share during your communication with us.
Contact information includes basic contact information you provide:

⦁ email address,

⦁ first and last name,

⦁ phone number(s),

⦁ social media handle (for example, if you engage with us on social media).

Communications information refers to any correspondence you have with us — for example, when you contact our Customer Service team regarding an order, booking, or to report an issue with our Site. This may include:

⦁ emails

⦁ texts, in-app messaging & other digital messaging

⦁ calls

⦁ letters

⦁ any in-person conversations you have with us.

We use this contact and communications information to

⦁ Contact you upon your request, including responding to your inquiries, resolving issues, and assisting with any problems you may experience with our Services.
⦁ Provide you with information or resources you have requested regarding our Services.
⦁ Connect you with Partners when you have asked us to share your information with them.
⦁ Deliver important technical notifications and service updates — for example, when we make changes to our Terms of Use or Terms of Service.

If you use our services to book an appointment

When you create a NUGDi account through any of our Services — including when purchasing or using a NUGDi gift card — we may collect the following information:

⦁ first and last name;

⦁ date of birth

⦁ gender

⦁ email address;

⦁ address

⦁ mobile phone number(s),

⦁ your photo, if uploaded (optional).

⦁ If you choose to use your Google, Facebook, or Apple account to sign into NUGDi, we will get an access token that enables this sign-in process (granting us access to your first and last name, email, user ID and (apart from Apple) your profile photo).

⦁ We assign unique user IDs or other account-level IDs to your NUGDi account.

As you use your account, we may collect information about your:

⦁ Purchase history, including product orders, appointment bookings, or NUGDi gift card and Partner voucher purchases and usage.

⦁ Saved favourites (for example, your preferred salon, spa, or gym).
⦁ Account settings and preferences.
⦁ Social login credentials or information, if you choose to sign in using a social account.
⦁ Securely stored payment methods.
⦁ Additional information you may provide voluntarily, such as your preferences, referrals, how you discovered our Services, or other user-generated content (e.g., profile photos, reviews).
⦁ Data collected in accordance with our Cookie Notice.




We use this account and related information to manage your account with us, including to

⦁ Maintain and manage your NUGDi account.
⦁ Provide dedicated customer support and assistance.
⦁ Enable you to connect, place orders with, and make bookings through our Partners.
⦁ Allow you to make and pay for orders and bookings directly through your account.
⦁ Fulfil our contractual obligations to you in relation to any NUGDi gift card purchases — including processing orders, managing or receiving payments, applying fees and charges, and collecting or recovering any outstanding amounts owed.
⦁ Facilitate home service bookings at your provided address, where a Partner offers such services and you have selected that option.
⦁ Deliver a personalized experience by recommending features, services, products, and Partners that align with your interests and preferences.

You may share consultation, order, and booking details with Partners (for example, the date and time of your appointment). Partners may also request additional information through consultation forms available on our Services — including health-related details (such as whether you are pregnant) or other sensitive data (referred to as “special category data”).

You may choose to opt in to receive marketing communications directly from a Partner. Partners may also upload their own customer information to the NUGDi platform, including for the purpose of using our Services to send marketing communications. NUGDi does not use any Partner-uploaded customer information for its own purposes. Each Partner is solely responsible for managing and complying with their own marketing activities and related data protection obligations.

The Partner acts as the data controller for this information. If you have any questions or concerns regarding how your data is handled, please contact the relevant Partner directly.




If you order any products from a Partner's shop

When you order any products from a Partner's shop, we may collect your:


⦁ Order details and purchase records, including any related correspondence conducted through our Services.
⦁ Records of cancellations, returns, and refunds.
⦁ Securely stored payment methods.
⦁ Product reviews, feedback, or ratings you provide.
⦁ Data collected in accordance with our Cookie Notice.

We use your account and order information to enable our Partners to process, fulfill, and manage your orders effectively, including to:

⦁ Enable you to communicate with and purchase products or services from our Partners, including making secure payments.
⦁ Share your contact and order details with the relevant Partner to allow them to process, fulfill, and manage your order — including handling any cancellations, returns, or refunds — and to communicate with you regarding your purchase.
⦁ Store and maintain records of your orders, cancellations, returns, and refunds for service management and compliance purposes.




If you work for a Partner

If you are employed by, or otherwise engaged with, one of our Partners (for example, as an employee, contractor, or worker), we may collect certain contact and business-related information from you, including:


⦁ first and last name
⦁ role title
⦁ company name
⦁ email address
⦁ contact number
⦁ log-in details
⦁ KYC and ID verification results (we do not keep any underlying documents)
⦁ details in accordance with our Cookie Notice

Company information may include:

⦁ company address
⦁ business type (e.g. salon, spa, gym)
⦁ consultation form content
⦁ historical and future appointments
⦁ point of sale data
⦁ payment processing data (we don't see this, only our payment processors do)
⦁ reporting and analytics
⦁ Client data and promotions;
⦁ Pictures and marketing materials

We may also process additional information on behalf of your company that does not constitute personal data — for example, financial records, transaction details, and product inventory information.
We use this contact and company information to manage and support the Partner’s account with us, including to:

⦁ Maintain and manage the Partner’s account.
⦁ Provide dedicated customer and technical support for our suite of business tools.
⦁ Enable the Partner to effectively use our business tools, including staff management and appointment scheduling features.
⦁ Facilitate transactions and payment management for the Partner.
⦁ Support the Partner in creating and managing marketing campaigns and promotions through our Services.
⦁ Allow the Partner to list their business on the NUGDi marketplace.
⦁ Enable the Partner to manage inventory and operate point-of-sale (POS) devices.
⦁ Contact Partner staff when necessary to assist in setting up Partner-specific accounts with appropriate access permissions and to manage those accounts.
⦁ Process information in accordance with our Cookie Notice.


he Partner can access and manage details associated with their NUGDi account. Partners also have control over the information that Clients can view about them, which may include order or booking details, staff names, profile information, special offers, ratings and reviews (including feedback mentioning staff members), pricing and discounts, appointment availability, and other related data.

The Partner you are employed by is the data controller for this information. If you have any questions or concerns regarding how your data is processed, please contact your Partner directly.




If we send you offers, updates or other marketing material from us

We may collect your contact information (as described above), such as your name and email address.
We may also collect information about your marketing preferences — including records of the types of communications you wish to receive from us, as well as any instances where you have chosen to opt out of receiving direct marketing messages.

We use this contact and marketing preference information to:


⦁ Send you offers, updates, promotions, newsletters, insights, and other marketing materials.
⦁ Provide you with personalized marketing content, including tailored offers, features, services, products, and Partners we believe may be of interest to you.
⦁ Collaborate with digital advertising partners to deliver relevant marketing and promotional campaigns.
⦁ If you are employed by an organization we are interested in partnering with, we may contact you regarding our NUGDi Services and potential partnership opportunities.
⦁ Reach out to request feedback, including through surveys and other forms of market research.
⦁ Process related information in accordance with our Cookie Notice.

You can opt-out of further marketing at any time by selecting the “unsubscribe” link at the end of all our promotional updates.




What do each of these legal reasons mean?

We are required to have a valid legal justification — known as a ‘lawful basis’ — for each way in which we process your personal data.



Consent

We use your personal data to send you promotional and marketing communications — such as newsletters, updates, or insights — where you have provided your consent for us to do so, where required by law. In certain circumstances, we may also send direct marketing communications based on our legitimate interests, as permitted under applicable data protection laws (see below for further details).

You can opt-out of further marketing at any time by selecting the “unsubscribe” link at the end of all our promotional updates and marketing to you.
We also rely on consent for some of the cookies we use (see our Cookies Notice for more detail).



Contract

We collect, store, and process your personal data where it is necessary for the performance of a contract you have entered into with us — for example, under our Terms of Use or Terms of Service — or where you have requested that we take specific steps prior to entering into such a contract. This may include actions such as notifying you about updates or changes to our Services.

This lawful basis does not apply to any agreement we hold with a Partner. If you are a Client (Booker) or a Partner’s staff member, our processing in those contexts is instead based on our legitimate interests (see below).



Legal obligation

We may process your personal data where it is necessary to comply with our legal obligations, including those arising under applicable UK laws or court orders. This may involve fulfilling regulatory requirements such as know-your-client (KYC) and anti-money laundering (AML) obligations, or responding to lawful requests from public authorities.



Legitimate interests

We may process your personal data where such processing is necessary to pursue our legitimate interests or those of a third party, provided that these interests are not overridden by your own rights, freedoms, or interests. This lawful basis allows us to operate, improve, and protect our Services in ways that are reasonable and proportionate to your expectations.

Our legitimate interests include:

⦁ Keeping our records updated.
⦁ Gaining insights on how you use our Services.
⦁ Gaining your feedback and reviews,
⦁ Delivering, developing and improving our Services.
⦁ Enhancing, customizing or modifying our Services and communications.
⦁ Implementing and improving our security measures
⦁ Growing our business and informing our marketing strategy.

You can opt-out of further marketing at any time by selecting the “unsubscribe” link at the end of all our promotional updates.



Marketing

⦁ Marketing and promoting our Services to the company you work for or provide services to.
⦁ Measuring and evaluating the effectiveness of our advertising campaigns, including the advertisements we deliver to you and others, and ensuring that the marketing content you see — both on our platform and on other websites — is relevant and tailored to your interests.




Fulfilling agreements with another organization

⦁ Complying with or enforcing agreements that NUGDi has — or that you may have (for example, any additional Partner-specific terms) — with a Partner from whom you have purchased goods or services as a Client.
⦁ Complying with or enforcing agreements we have with a company you work for or provide services to (for example, if you are employed by or contracted to a Partner).


In each case, these legitimate interests apply only where they are not outweighed by your rights and interests. If you would like more information about how we assess our legitimate interests, please contact us at info@nugdi.com.

We also use various types of cookies on our Site — please refer to our Cookies Notice for more details.




Who do we share your information with?




If you are a Client

We will share your information with our Partners if you have requested us to do so — for example, when you choose to connect with, place an order from, or make a booking with one of our Partners. We may share your contact and account information, along with any other details you provide through NUGDi (such as responses to a Partner’s consultation form). Partners may use this information to manage your communications, orders, and bookings with them.

If you post a public review for a Partner or any of their products listed in their shop on our Services, your rating, review, review date, and first name with last initial will be published on NUGDi. Other NUGDi users and members of the public may be able to view your reviews. Reviews may also be displayed or syndicated on third-party websites. Please note that public reviews may remain visible even after your NUGDi Terms of Service have been terminated or expired.



If you work for a Partner

NUGDi users may rate the Partner you work with or for, and may also provide ratings or reviews about you as an individual. Your individual ratings may be shared with the relevant Partner and, in some cases, may be publicly visible on our Services.

We may also publish selected Partner information — including both individual and business reviews and ratings — on other websites to enhance visibility. This may include featuring such information in search results or within online and offline promotional materials and advertisements, such as on Google, Google Ads, Facebook Ads, Twitter, email campaigns, and through collaborations with third-party business partners and affiliates.



If NUGDi processes your information as a Client, Partner staff member, or in any other capacity

We may also share your information with:

⦁ Any member of our corporate group, including our ultimate holding company, its subsidiaries, and/or our own subsidiaries, who may support the processing of personal data under this Notice.
⦁ Our service providers—organizations that process your personal data on our behalf and in accordance with our instructions and applicable data protection laws.

This includes companies that:

⦁ provide website and data hosting services;
⦁ distribute communications on our behalf;
⦁ support or maintain our marketing databases;
⦁ deliver customer support services;
⦁ facilitate feedback on our Services;
⦁ provide digital invoicing and secure payment processing; and
⦁ offer IT maintenance and technical support.

These organizations (including third-party suppliers, agents, subcontractors, and/or other companies within our group) will only use your data as necessary to perform their contracted support functions.


⦁ Our digital marketing partners, in certain circumstances, to help us deliver or measure the effectiveness of online advertising campaigns.
⦁ Partners associated with a Referral Link, if you create a Partner Account using one — allowing them to view the progress of your Partner Account registration.
⦁ Commercial partners, if you participate in surveys, competitions, promotional campaigns, offers, or similar activities. In such cases, we may share limited information with these partners, and more detailed privacy information will be provided at the time of participation.
⦁ Our auditors, legal advisers, and other professional consultants, for regulatory, legal, or business advisory purposes.
⦁ Prospective buyers or sellers, in the event that we sell or acquire any business or assets, in which case your personal data may be disclosed as part of that transaction.
⦁ Relevant third parties, when disclosure is necessary to protect the rights, property, or safety of NUGDi, our clients, or others, and to enforce our rights under this Notice or any applicable agreement (for example, our Terms of Use or Terms of Service). This may include exchanging information with other organizations for the purposes of fraud detection, prevention, and cybersecurity.
⦁ Law enforcement agencies, regulators, or other governmental bodies, if required by law, court order, or where we reasonably believe we are legally obligated to disclose such information.




Where do we store your information?

NUGDi operates globally, including in the United States, Canada, the United Kingdom, Australia, the United Arab Emirates, the Netherlands, and other countries within the European Economic Area (“EEA”). We generally do not share personal data between our group companies unless necessary for operational or legal purposes.

We may transfer your personal information outside the UK and/or EEA in the following circumstances:


⦁ to store or securely back up your data;
⦁ to enable us to provide our Services to you effectively;
⦁ to support the operation of our global business, where such transfers are in our legitimate interests and not overridden by your rights; and
⦁ where required by law or regulatory obligations.

Whenever we transfer your personal data outside the UK or EEA, we ensure that appropriate legal safeguards are in place in accordance with applicable data protection laws to protect your information.

We may also transfer your personal data to trusted partners and service providers located outside the UK and EEA, including the key organizations listed in this Notice.

As NUGDi continues to expand and update its partnerships, we will revise this Notice periodically to reflect any changes. For more information about how we currently manage international data transfers and the protections in place, please contact us at info@nugdi.com.




How do we protect your information?

All information you provide to us is stored securely. NUGDi employs end-to-end encryption to safeguard your data, and all connections to our platform are protected using industry-standard encryption and security protocols.

All personal data we collect is maintained in secure databases and storage systems with strict access controls. Access to such data is granted only to authorized personnel, and every access request is logged, monitored, and reviewed in line with our threat detection and cybersecurity policies.

While we take robust measures to protect your information, please note that data transmission over the internet cannot be guaranteed to be completely secure. We make every reasonable effort to protect your personal data, but we cannot guarantee its absolute security during transmission, even when specific notices indicate encryption (for example, during payment processing). Any information you transmit to us is done at your own risk. Once we receive your data, we apply strict security procedures and safeguards to help prevent unauthorized access, alteration, or disclosure.





Payment processing

Payments made through our Services are securely processed by our trusted payment gateway partners — Adyen N.V. (“Adyen”) or, if you are located in the UAE, Checkout MENA FFZ LLC (“Checkout”). When you make a payment, your credit or debit card details are provided directly to Adyen (or Checkout), which operates a secure, encrypted server to process and authorise your payment.

NUGDi only has access to pseudonymized cardholder information, ensuring that your full payment details remain protected. NUGDi securely stores the following limited card data for transaction verification and customer support purposes:


⦁ Card brand
⦁ Cardholder name
⦁ Last four digits of the card number
⦁ Card expiry month and year

Please note that any payment information you provide directly to Adyen (or Checkout) is not under NUGDi’s control and is governed by Adyen’s own privacy policy and terms (or Checkout.com’s privacy policy and terms, respectively).




External sites

NUGDi’s Services may, from time to time, include links to external websites or third-party platforms. Please note that if you choose to follow any of these links, those websites operate under their own privacy policies and terms of use. NUGDi does not accept any responsibility or liability for the content, practices, or privacy policies of external sites, nor does it necessarily endorse the opinions or material presented on them.

NUGDi also has no control over the availability, accuracy, or security of any linked websites. We strongly encourage you to review the privacy policy and terms of service of each website before submitting any personal information.





How long is your information kept for?

We will generally process personal information:
We retain your personal information only for as long as necessary to fulfil the purpose(s) for which it was originally collected — for example, while maintaining your account with us or processing information on behalf of a Partner.

After that, we may securely retain your data for up to six years to help identify potential issues, maintain business records, and resolve any legal or regulatory matters that may arise.

In certain situations, we may retain your personal data for a longer period — such as in the event of a complaint, if there is a reasonable likelihood of legal proceedings, or when required by applicable law.

If you have subscribed to receive updates, insights, newsletters, or other promotional materials but later choose to opt out or object to such processing, we may retain a record of your preference to ensure that your choices are respected in the future.

We may also retain aggregated, anonymized, or pseudonymized data (for example, for reporting or analytics purposes) for extended periods, as this information no longer identifies you personally.





Aggregated data

In certain cases, we may anonymize your personal data, meaning it will no longer be associated with you and cannot be used to identify you in any way. Once anonymized, this information is no longer considered personal data under data protection laws.

We may retain and use such anonymized or aggregated data — for example, for statistical analysis, research, or business insights — indefinitely and without further notice to you, as it no longer relates to an identifiable individual.

We use this to help us provide, develop and improve our services, including to:


⦁ Gain a better understanding of how individuals interact with and use our Services,
⦁ Provide our Partners and Clients with relevant information about our Services, including general usage statistics (such as total user counts and broad demographic trends), and
⦁ Generate insights and improvements to enhance the performance, usability, and overall quality of our Services.




What rights do you have with your personal information?

You have several rights in relation to the personal information that NUGDi holds about you. These include the right to:


⦁ Access a copy of your personal information held by us,
⦁ Request correction or deletion of your personal information,
⦁ Request restriction of the processing of your personal data (for example, while we verify or investigate your concerns),
⦁ Object to the further processing of your personal data, including for direct marketing purposes,
⦁ Request data portability, meaning you can ask us to transfer the personal data you provided to another third party, and
⦁ Withdraw your consent at any time, where processing is based on consent.

If you wish to exercise any of these rights, please contact us at info@nugdi.com.

If you have concerns about how we handle your personal data, you also have the right to lodge a complaint with your local data protection authority.

In the United Kingdom, this is the Information Commissioner’s Office (ICO), which provides detailed information about your rights and can handle complaints regarding data protection. You can visit their website at www.ico.org.uk.

If you are located outside the UK, you can find contact details for your local data protection authority here.




Updating this Privacy notice

This Notice was last updated on 10 October 2025.

NUGDi may update or revise this Notice from time to time to reflect changes in our practices, technologies, or legal requirements. Any updates will be posted on this page, with the revised date clearly indicated at the top.

If we make any material or significant changes, we will notify you through appropriate means — such as email, in-app notifications, or pop-up alerts on our website — so that you remain informed about how your personal information is being used.