Last update: 1 November 2017
1.1 Thank you for visiting the www.nandos.com.sg website (the “Website”). Nando’s is registered as Nando’s Chickenland Singapore Pte Ltd (“we”, “us” or “our”) and is committed to protecting and respecting your Personal Data .
1.2 This Personal Data Protection Policy (hereinafter referred to as PDP Policy), together with our Website terms and conditions available at [terms and conditions], sets out the basis on which any personal information we collect from you, or that you provide to us, will be used, stored and processed by us (“Collect”). Please read the following carefully to understand our views and practices regarding your Personal Data (as defined below) and how we will treat it.
1.3 In adopting this PDP Policy, we wish to balance our legitimate business interests and your reasonable expectation of privacy. Accordingly, we will take reasonable steps to prevent unauthorised access to, or disclosure of your Personal Data. However, we do not guarantee that your Personal Data shall be 100% secure.
1.4 By continuing to use the Website, you agree to the terms and conditions set out in this PDP Policy. You agree that we may collect all and process Personal Data for the purposes of providing you with access to our Website and for any of the purposes listed in clause 3 below.
What types of Personal Data do we Collect?
2.1 The types of Personal Data that we may Collect includes information necessary for our legitimate business interests. This may include personal information which contains identifiable information such as (amongst other things) your first and last name, screen name, email address, postal address, physical address, telephone number, date of birth, details about your telephone device (e.g. mobile phone) and your telephone service provider and information related to providing products and services (“Personal Data”).
2.2 We may also Collect other information, including your interests, preferences, purchasing behaviour, transactional information, geographical location and demographics (e.g., age, gender, and income information). We may, on occasion, combine Personal Data we receive online with other records (such as those from telephone and direct purchases) to develop a customer profile relating to you.
2.3 We will attempt to limit the types of Personal Data we Collect to only that to which you consent (for example, in the context of online registration, competitions, message boards, surveys, polls, games, SMS, MMS and other mobile services).
2.4 When you visit our Website, our web server also automatically records the name of your ISP (Internet Service Provider), the website from which you visit us, the pages on our sites you visit and in what sequence, and the date and length of your visit. This information is aggregate and anonymous data and does not identify you specifically.
How does Nando’s use your Personal Data?
3.1 We may use your Personal Data to:
3.1.1 provide services or products you request (e.g. send you by email or other electronic means our newsletters or other products or services in which you express an interest);
3.1.2 allow you to participate in recreational activities on the Website (e.g. participate in our message boards), to organise or carry out promotional activities, games or promotional events;
3.1.3 inform you of changes made to our Website;
3.1.4 inform you of products, services, promotions, offers and competitions which you may find interesting, subject to clause 6 below;
3.1.5 Respond to any queries you may have;
3.1.6 develop a more direct relationship with you for the purposes described in this section;
3.1.7 develop an online customer profile;
3.1.8 understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services; and
3.1.9 for security, administrative and legal purposes.
3.2 Where you choose to receive mobile services and content via SMS, MMS and other mobile services, we use this information to deliver such mobile services and content to you, to carry out market research, to track sales data and to plan other promotional activities which may be of interest to you.
What is Nando’s Cookies Policy?
4.2 We may also use “web beacons” that monitor your use of our Website. Web beacons (or web bugs) are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data, such as the IP (Internet Protocol) address of the computer that downloaded the page on which the web beacon appears, the URL (Uniform Resource Locator) of the page on which the web beacons appears, the time the page containing the web beacon was viewed, the types of browser that fetched the web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, web beacons let us know whether you received and opened our email. On their own, cookies or web beacons do not contain or reveal any Personal Data. However, if you choose to provide us with Personal Data, it can be linked to the anonymous data stored in the cookies and/or web beacons. Most browsers are initially set to accept cookies. However, if you prefer, you may adjust your browser to reject cookies from us or from any other website. Additionally, by setting your web browser to display HTML emails as text only, you may be able to prevent the use of some web beacons. However, please note that certain areas of our Website can only be accessed in conjunction with cookies or similar devices.
What about Personal Data that is publicly available?
5.1 If at any time our Website offers any chat rooms, message boards, blogs, newsgroups or forums, etc., we Collect the information that you disclose. Such information will be used in accordance with this PDP Policy. Please note that we are not responsible for other parties’ use of the Personal Data which you make available to such third parties through any chat room, message board, blog, newsgroup or forums, etc. on our Website.
Will my Personal Data be used for marketing purposes?
6.1 Upon obtaining your prior consent, we may use your Personal Data for the purposes of:
6.1.1 direct marketing of our own products and services and on behalf of other companies within Nando’s; and
6.1.2 direct marketing of products and services on behalf of selected third parties, if you have agreed to your details being passed onto third parties.
6.2 You are entitled to request that we desist from using your Personal Data for the purposes of direct marketing, and we will provide you with the necessary functionality for you to do so with ease, each time we market to you.
What security measures are in place to protect my Personal Data?
7.1 Although absolute security cannot be guaranteed on the Internet, we have in place up-to-date, reasonable technical and organisational security measures to protect your Personal Data against accidental or intentional manipulation, loss, misuse, destruction or against unauthorised disclosure or access to the information we Collect online.
7.2 While we cannot ensure or warrant the security of any Personal Data you provide us, we will continue to maintain and improve these security measures over time in line with legal and technological developments.
How will Nando’s store my Personal Data?
8.1 We store your Personal Data in AIMS Data Center located at Menara Aik Hua, Cangkat Raja Chulan, 50250 Kuala Lumpur and/or Lot 79, Lorong Memanda 1, Ampang Point, 68000 Ampang, Selangor . We may also or alternatively store your Personal Data on and transfer your Personal Data to a central database located in Nando’s CS Office, 123, 2nd Floor, Jalan Sultan, 50000 Kuala Lumpur. If the location of the central database is located in a country that does not have substantially similar laws which provide for the protection of personal data, we will take the necessary steps to ensure that your Personal Data is adequately protected in that jurisdiction.
8.2 Your information will not be stored for longer than is necessary for the purposes described in this PDP Policy.
Will my Personal Data be shared with anyone else?
9.1 Nando’s entities: We may share your Personal Data with other entities within Nando’s that have agreed to be bound by this PDP Policy. It is possible that we, or one of our divisions or affiliates, could merge with, be sold to or be acquired by a third party. To the extent legally permissible and in accordance with the conditions of this PDP Policy, we may share your Personal Data with any successor entity.
9.2 Third parties: We may disclose Personal Data about you to other third parties to comply with applicable laws and regulations. We also reserve the right to disclose such Personal Data to third parties where a complaint arises concerning your use of our Website and where we believe, in our sole discretion, that your use of our Website is inconsistent with the PDP Policy. We also share information about users of this Website in an anonymous or aggregate form with third parties including advertisers and business partners, to understand customer trends and patterns and manage and improve our business relationships. We provide your Personal Data to third party processors to administer and process for the purposes notified to you in this PDP Policy, and we may also share such details with third parties (such as auditors or legal advisors) to obtain professional advice. Any such processing will be governed by an agreement in the form required by law, preserving any and all of your statutory data protection rights.
9.3 Links, advertisers, third party sponsors & ad-servers: Our Website may contain links to other websites that are not covered by this PDP Policy and where information practices may be different from ours. Users should consult the other sites’ privacy policies on such third party sites before submitting any Personal Data, as we are not responsible for and have no control over Personal Data that is submitted to, or collected by, these third-party sites. On this Website, we sometimes offer content or programs that are sponsored by or co-branded with identified third parties (e.g. competitions or promotions). These third parties can obtain Personal Data that you voluntarily submit to them to make use of the offer. We are not responsible for the collection and use of your Personal Data by these third parties. However, you will be informed, at the point of collection of such personally identifiable information, if these third parties will obtain such information, how it will be processed and to whom it will be transferred. On our Website, third parties may present or serve advertisements, provide us with data collection, reporting and ad response measurement, as well as assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this PDP Policy.
How can I find out what Personal Data Nando’s holds about me?
10.1 To see the Personal Data we have collected through this Website that relates to you, to withdraw the consent for us to process your Personal Data and/or, correct or update this Personal Data or to specify the Personal Data that you consent us to process, please email us at firstname.lastname@example.org. In addition, we will always give you the opportunity to update your preferences regarding our use of your Personal Data. In the event you have signed up and joined our loyalty programme, you are allowed to update your Personal Data from time to time by visiting www.nandosloyalty.com.sg. The updated Personal Data will be reflected in the system after you have updated the said data.
10.2 To protect your privacy and security we will take reasonable steps to verify your identity before granting access. If you have any additional questions about Personal Data we hold about you, please contact us at email@example.com.
Nando’s application and our use of Facebook user data (where applicable)
11.1 Nando’s has an official application for iPhone, iPad, iPod and Android, available for download in certain countries (the “Official Application”). To check if the Official Application is available in your country and/or to find out more details about the Official Application please visit our Website.
11.2 The Official Application will access information from user’s Facebook accounts once they give us permission to do so whilst using the Facebook-related functionality of the application. Once permission is granted, the Official Application accesses a user’s friends list and location only. If the Official Application is not available in your country, this clause 11.2 will not apply to you.
Use of the Website by children
12.1 This Website is accessible to children under the age of 18.
12.2 We require children who are under the age of 18 to consult with their parents before providing Personal Data. We also encourage parents to supervise their children’s online activities by, for example, adopting parental control tools available from online services and software manufacturers that help provide a child-friendly online environment. These tools can also prevent children from disclosing online their name, address, and other Personal Data without parental permission.
12.3 We encourage parents to talk to their children about the use of the Internet and information they disclose to websites.
Changes to this PDP Policy
13.1 From time to time, we may revise this PDP Policy to reflect company initiatives, changes in the law or technology or changes in our practices regarding the collection and use of Personal Data. If we decide to change this PDP Policy, the changes will be posted on this Website so that you are always informed of the latest version.
13.2 We will not use or disclose Personal Data provided to us pursuant to this PDP Policy in ways other than the ones described above, without informing you and providing you with the opportunity to consent to such modified conditions concerning the use and disclosure of your Personal Data.
14.1 The contents of this PDP Policy shall be governed by the law of Singapore.
14.2 If any provision of this PDP Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced unless a court of competent jurisdiction determines that the substantive purpose of this PDP Policy is then frustrated, in which case you may contact Nando’s at the address in clause 15 below in order to opt-out of the PDP Policy.
How can I contact Nando’s?
15.1 If you have any questions or comments about this PDP Policy please feel free to write to Nando’s Customer Care, firstname.lastname@example.org.