Nudgyt Privacy Policy

Effective date: 1 Oct 2026 Last updated: 21 Sep 2026

This Privacy Policy explains how Nudgyt Pte Ltd ("Nudgyt", "we", "us") collects, uses, discloses and protects personal data when you visit our website or use (the "Services"). It should be read with our Terms of Service. We handle personal data in accordance with all relevant laws for example Singapore’s PDPA and Europes GDPR

If you have any questions or requests about your data privacy please email info@nudgyt.com and we will respond within 48 hours.

1. Data Protection Officer:

Chew Shao Yong

Email: shaoyong.chew@nudgyt.com

2. Personal data we collect

a. Account and profile data: email address

b. Learning and coaching content: AI-user transcripts, objectives completed, scores, feedback, evaluations, attempt history, and documents you choose to upload

c. Voice data: audio you speak during real-time conversations, which is converted to text so the AI character can respond. Raw Audio data is not collected

d. Facial-expression (puppetry) data: if Customer enables emotion detection, your device camera is used to derive facial-expression data points that animate the AI character. We store only those data points. We do not record or store your camera video.

e. Payment and billing data: billing contact details, plan, Seat count, invoices and transaction status. Card and payment details are collected and processed directly by our payment provider, Airwallex. We do not store full card numbers; we receive confirmation of payment, a payment reference and limited details such as the card's last four digits and brand.

f. Usage and device data: IP address, browser and device type, pages and features used, timestamps, error logs and approximate location derived from IP address.

g. Communications: emails, support requests, feedback you send us, and your preferences for marketing messages.

h. Cookies and similar technologies on our website.

We do not intentionally collect sensitive categories of personal data. Simulation scenarios are fictional, and you should not enter real patient or client information, health records, identification numbers or other personal data of real third parties into simulations or coaching sessions unless your organisation has authorised it and the content is necessary.

3. How we use personal data

We use personal data to:

create and manage accounts and Seats, and authenticate users;
deliver the Services: run simulations, generate AI characters' responses and feedback, track objectives, provide scores and evaluations, personalise coaching based on your earlier attempts, and match coachees with suitable mentors or collaborators where the Customer has enabled this;
give trainers and administrators dashboards and reports about their learners' progress,
process payments, send invoices and receipts, and manage subscriptions, renewals and refunds;
provide support, send service notices and respond to enquiries;
secure the Services, prevent fraud and abuse, and enforce our Terms, including moderating content that breaches our acceptable-use rules;
maintain and improve the Services, including producing de-identified, aggregated analytics and benchmarks;
send marketing communications about Nudgyt, where you have consented or where permitted by law (you can opt out at any time); and
comply with legal obligations and respond to lawful requests from authorities.

AI processing. To generate AI responses, parts of your input may be processed by third-party AI service providers listed in Annex A, acting for us under contract.

4. Consent and legal bases

By using the Services you consent to the collection, use and disclosure described here. Where the Customer obtains consent on behalf of its Authorised Users, the Customer is responsible for doing so. Processing is necessary for the performance of a contract, for legitimate interests that are not outweighed by the adverse effect on you (for example, security and fraud prevention), or where required by law. You may withdraw consent at any time by contacting us; withdrawal may mean we can no longer provide some or all of the Services to you.

4. Who we share personal data with

We do not sell personal data. We share it only with:

Your Customer: administrators and trainers at your organisation can see your activity, content, scores and reports as part of the Services.
Service providers (subprocessors) who help us run the Services, under written obligations to protect the data and use it only for our purposes. These are listed in Annex A
Professional advisers, auditors and insurers, under confidentiality duties.
Authorities, where required by law or to protect rights, safety or the security of the Services.
Successors, in connection with a merger, acquisition or sale of assets, where the recipient agrees to honour this Policy.

5. Retention and deletion

We keep personal data only as long as needed for the purposes in this Policy or as required by law. In general:

Account, learning and coaching data is kept while the Customer's subscription is active and is deleted or anonymised [60] days after the subscription ends, unless the Customer asks for earlier deletion or the law requires longer retention;
Billing and transaction records are kept for [5] years to meet accounting and tax requirements;
Marketing contacts are kept until you unsubscribe.

6. Cookies

Our website uses cookies and similar technologies that are necessary for the site to function, and, with your consent where required, for analytics and to remember preferences. You can control cookies through your browser settings or the cookie banner; blocking some cookies may affect how the website works.

7. Security

We maintain reasonable administrative, technical and physical safeguards, including [encryption in transit and at rest, access controls limited to authorised personnel, and regular security reviews]. No system is completely secure, so please protect your credentials and let us know immediately of any suspected unauthorised access. If a data breach is likely to cause significant harm or is of significant scale, we will notify the relevant authorities and the Customer

8. Your rights

You may

ask for access to the personal data we hold about you and how it has been used or disclosed in the past year;
ask us to correct inaccurate or incomplete personal data;
withdraw consent to the collection, use or disclosure of your personal data; and
opt out of marketing messages at any time using the unsubscribe link or by contacting us.

For personal data we process as data intermediary for a Customer, please contact your organisation first; we will assist the Customer in responding. We may need to verify your identity, and we will respond within a reasonable time (generally within 30 days). We may charge a reasonable fee for access requests, and we will tell you in advance.

9. Children and young people

The Services are intended for Authorised Users aged 16 and older and are not directed at children. If a Customer enrols minors, it must have obtained any parental or guardian consent that is required. If you believe a child under 16 has given us personal data without authorisation, contact us and we will delete it.

10. Changes to this Policy

We may update this Policy from time to time and will post the new version here with a new "Last updated" date. For material changes, we will give notice by email or in the Services before they take effect.

P&P