Privacy Policy

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NUSANTARA KITCHEN INDONESIA PRIVACY POLICIES

GENERIC PRIVACY POLICIES 

1.1 Background

This Standard Operating Procedures (SOP) are to highlight our standard practices of protecting data and privacy of our stakeholders (clients, partners, vendors, collaborators, shareholders, directors, and so on).  These standard practices and policies are practiced by our personnel, publicized on our website, and through all our business conducts. As part of following the requirement set by the government of Singapore and Indonesia on PDPA. We will cover information such as the data protection lead officer, how do we keep and dispose of data, how we manage our risks and mitigations, and contingency planning when it comes to data breaches or malpractices. 

1.2 Purpose 

The purpose of this SOP is to ensure and communicate clearly on all our practices and policies to our staff and our clients. Giving all our stakeholders’ assurance on our highest regards and priorities in assuring protection of data and its privacy. 

1.3 Functionality

These policies should be consistently and frequently updated, refreshed, and communicated by the data officer of the company, which in this case will be for Nusantara Kitchen Indonesia. These generic practices should be accompanied with training slides as well as another internal SOP on data handling and client privacy that should be honored by all staff of Nusantara Kitchen Indonesia or even at our Walker Group as well as its’ subsidiaries. 

2.1 Terms and Conditions

For any information provided by Nusantara Kitchen Indonesia or even at our Walker Group as well as its’ subsidiaries on our public domain, including our website is copyrights of Nusantara Kitchen Indonesia or approved contents provided by either relevant agencies or stakeholders. Pertaining to this information, you agree and comply to: 

a) Abide by the rules and code of conduct provided on our website and should follow the instructions set on our official website. 

b) To abide to all the laws and regulations in the use of this website

c) Shall not at any point in time impersonate to be a personnel or representative of Nusantara Kitchen Indonesia or its relevant partners. 

d) Shall not misuse or misrepresent the information that is provided from this website and shall not claim credit nor claim ownership of any information or digital assets not limiting to photos, videos, and so on. 

e) You agree if you provide your contact information on our contact page, it is on your own free will and given the consent for any one of our personnel to reach out to you based on the inquiries that you have keyed in. 

f) You shall not attach nor input any illegal contents nor vulgarities in the comment section or feedback section. 

g) You should only provide genuine information and shall not engage or contact us for the purpose of vein or mischievous activities which may result in legal action. 

h) You shall be responsible for obtaining and using the necessary web browser and/or other software and/or equipment necessary to obtain access to this website at your own risk and expense. If new or different versions of the web browser and/or other software and/or hardware and/or equipment necessary for the operation of this website become available, we reserve the right not to support any prior version of the web browser or other software.

Our rights include the following (our rights refer to the right Nusantara Kitchen Indonesia in relation to the website or public domain such as our social media assets): 

a) Monitor, screen, moderate, edit, censor, or otherwise control any activity, content, communication, or material including, without limitation, discussions, chats, postings, transmissions, forums, message boards, bulletin boards, and the like on this website.

b) Investigate any violation of the terms and conditions contained herein and may take any action we deem appropriate.

c) In our absolute discretion, and without stipulating any reason, stop, suspend, modify, delete, or edit any Material appearing on this website or any social media asset’s part thereof.

d) Report any activity we suspect to be in violation of any applicable law, statute, or regulation to the appropriate authorities and to co-operate with such authorities.

e) Choose when, where, and how we keep in touch with you should you have indicated your contact and request for our personnel to contact you in person. 

In terms of the use of our social media (Instagram, LinkedIn, Facebook, TikTok, and so forth), we would like to emphasis the following code of conducts: 

a) Share your opinions respectfully.

b) Do not post content that is false, obscene, defamatory, threatening, harassing, discriminatory, or hateful to another person, race, religion, or entity.

c) Do not post spam or content that violates any law or intellectual property rights.

d)  Do not upload files that contain viruses or programmes that can cause damage to other people's mobile devices or computer.

e) For your privacy and safety, please avoid posting confidential information such as your personal details.

Finally, we own the intellectual property rights to all published information otherwise stated so and have full discretion on how to organise, disseminate, edit, and utilize the information with exception to our clients’ personal contact details and information. In addition, Permission is granted to download and print the Materials on this website for personal, non-commercial use only, provided you do not modify the Materials and that you retain all copyright notices and other proprietary notices contained in the Materials. You may not, without our permission, “deep link” to any part of this website, “frame” or "mirror" any Material contained on this website on any other server.

3. General Policies and Data Protection Policies. 

3.1. Ethical, Lawful, and Transparency: 

We adopt minimal data collection policies and only collecting based on what is required nor our website our public domain was equipped with unnecessary cookies other than for safety and privacy. For any events or any campaigns that may require customer registration or data collections, these data are collected only through secure and trustworthy platforms in which is only accessible to our personnel that has clearance. The purpose of these data collections is to confirm the identity of the registrants as well as the accompanying information. For any marketing purposes or engagements, there should be clear choices given during any registration whether to opt-in or opt-out to receive any email or mobile notifications of our newsletter or campaigns. Should there be approval to receive any marketing collaterals in the past and if the recipient decides to no longer want to receive them, they can simply unsubscribe to write to our generic email as follows: info@nusantara-kitchen.com

Please note that all the external links provided on our website are genuine and official links that have been given permission for us to provide the information on our website or social media.  

3.2 Data Security

Data protection is always considered, from the moment we collect your personal data in business activities.  We encrypt, pseudonymize or anonymize the data wherever possible.  This is something that our staff are always aware of. We have internal data protection policies and IT security policies for our staff and build awareness about data protection.  Our business leaders know when to conduct a data protection impact assessment and we have a process in place to carry it out.  For data breach matter, we have a process to notify authorities and other stakeholders that is guided by an internal data breach reporting policy and business continuity management programme. All staff, new and old will have to attend occasional training on PDPA be it conducted internally by the data protection lead officer or by external approved institution. Our entity is ISO certified and requires going for routine audits and checks. 

3.3 Accountability and Governance 

Governance is our primary priority and good administration is what we practice at Nusantara Kitchen Indonesia. We have a data protection officer that overlooks at the overall implementation as well as control over data protection and governing policies. Under the regulation of IMDA or Infocom Media Development Agency of Singapore, we are intimately aware of our PDPA obligations which include appointing a data protection officer, providing clarity as well as communications on how our data is being handled, and identify potential risks as well as breaches to ensure countermeasures and contingency planning. 

In the event of more information or clarity required, you can send an email or contact our data protection officer or lead as follows: 

Officer Name: Andre WD

Designation: Data Protection Officer

Email: info@nusantara-kitchen.com

General Line: +65 6685 9034

We will reply to you within 3 working days should there be any relevant case or inquiry lodged. 

3.4 Data Privacy and Rights 

We have proper security procedure to handle our customers who make request about their personal data that is with us. It is easy for our customers to correct or update inaccurate or incomplete information.   We do not use automated processes to make decision about our customers.  If there is use of Artificial Intelligence/Machine Learning or use of website cookies to make decision, this is notified to our customers on the relevant company websites where such activities are taking place.

Our personnel in the company would have to attend the PDPA workshop especially for the data protection officer in which also has the responsibility to train and share information pertaining PDPA and cyber security through all the staff in the Nusantara Kitchen Indonesia. In addition, we also follow strictly the code of conducts provided by the IMDA regarding PDPA. For personal contact information with exception to working email and working contact number, we do not publish, share, nor engage with personal information directly or indirectly without the consent of the data owner unless the consent was given to third party collaborators or partners. 

4. Personal Data Protection Policies 

Protection of your Personal Data is important to us. This Nusantara Kitchen Indonesia ‘s Data Protection Policy (“Policy”) outlines how we manage the data within our organisation. Policy applies to:

a)       Nusantara Kitchen Indonesia (Registration Number 53467378C) that holds all the clients’ details and assigned projects. 

b)      Related corporations and affiliates.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”), where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.

We adopt a pragmatic “Data-light, Data-tight” approach in our business conduct.

“Data-light” means that we collect Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose. We do not collect Personal Data randomly or indiscriminately without purpose.

“Data-tight” means that we do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.

Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.8 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between Nusantara Kitchen Indonesia and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement or may be necessary to perform any contract you have agreed with us or perform services that you have requested.

In addition, if your Personal Data has been collected, used, or disclosed by us in a particular jurisdiction which has specific requirements or exceptions to the definition of Personal Data, including sensitive Personal Data, we will comply with those requirements under the applicable data protection regulations in that jurisdiction.

4.1 Your Personal Data

“Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

a) Your name, national registration identification number, passport number or other identification number, telephone number(s), mailing address, email address, facial image in a photograph or video recording, fingerprint and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you.

b) Information about your business, your products, your business planning, stakeholders, and so on derived either form advisory sessions or grant application. 

c)  Your employment history, education background, and income levels; and

d)  Your company or personal financial information that may have been provided to use for the purpose of applying grant.

e) Any other generic information obtained either direct or indirect such as from contact us from our website or from our social media that may contain your contact number, name, email, and so forth. 

4.2 Collection of Personal Data

Generally, we collect your Personal Data in the following ways:

a) When you made contact either directly through our channels or affiliated channels. Direct channels include walk-ins, submitting inquiries from our website or social media, emailing, or calling our direct email or line, and so on. Indirect means contacting our affiliate partners. 

f)  When you engage our consultants either through the phone, virtual meeting, or face to face. 

g)  When you request that we contact you.

h)  When you respond to our request for additional Personal Data.

i)   When you ask to be included in an email or other mailing list.

j)   When you respond to our promotions or other initiatives.

k)  When you respond to our market surveys.

l)  When you submit a grant application or other interest application such as attending our events and workshops. 

m) When we receive references from business partners and third parties, for example, where you have been referred by them.

n)  When you submit your Personal Data to us for any other reason; and

o)  When you browse our website. As mentioned, our cookies do not drop trackers other than security or urgent related matters. 

p) All the information is kept confidential and will not be shared with anyone outside the organisation and internally, the access is also only given to permitted personal. 

4.3 Use and Disclosure of Personal Data

Our office is only collecting and utilizing primarily commercial information provided with consent by the client and only for the purpose of assisting with the clients’ needs such as products’ purchasing, appointments’ booking, and so on. Mobile phones and emails collected are basically those related for work or business. 

b) In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:

- Provide you with the products or services that you have requested.

- Help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing future customer needs, conducting market research and data analytics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR).

- Communicate with you and respond to your queries, requests, and complaints.

- Provide ongoing information about our products and services which may be of interest to you.

- Handle disputes and conduct and facilitate investigations and proceedings.

- Protect and enforce our contractual and legal rights and obligations.

- Prevent, detect, and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks.

- Comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.

c) If you are a vendor, a prospective vendor, or a contractor, we may use and access the following information: 

- Evaluate your proposal.

- Conduct background checks on you.

- Communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and

- Any other purpose related to any of the above.

d) If you apply to us as a candidate for employment:

- Process your application including pre-recruitment checks.

- Provide or to obtain references for background screening/vetting.

- Collect information about your suitability for the position applied for.

- Organise training and staff development programmes. 

- Assess your performance.

- Administer benefits and payroll processing.

- Provide you with tools to facilitate or as required for you to do your job.

- Communicate with you to comply with our policies and processes, including for business continuity purposes; and

- Any other purposes related to the aforesaid.

k)     If you are an existing employee of Nusantara Kitchen Indonesia, Employee Personal Data Protection Policy would also apply to you.

l) Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.

The third parties are:

a) Our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services such as telecommunications, information technology, payment, payroll, training, market research, storage and archival.

b) Any third-party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not, and were permitted by applicable laws.

c) Insurers or insurance investigators and credit providers.

d) The Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres.

e) Our professional advisors such as our auditors and lawyers.

f) Relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority.

g)  Any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices.

5. Transfer of Personal Data

a) As mentioned earlier on, we collect primarily commercial information and personal data should only be limited to personal name, mobile phone, and email unless you are a registered vendor, or partner, or employee of Nusantara Kitchen Indonesia, or on special case in which we are required to collect your personal information such as NRIC number under the consent of the client or required by legal or authorities. 

b) The storage of all information collected externally are stored locally in Singapore Nusantara Kitchen Indonesia cloud storage and may include our own private server except for information collected to Partner Engagement Portal or database assigned by Enterprise Singapore in which the information will be stored directly with Enterprise Singapore. 

c) All staff of Nusantara Kitchen Indonesia have been briefed and continuously reminded as well as audited to store the soft copies of all information pertaining the advisory, grants, or clients, to be stored within our organization cloud storage using google drive.

d) We implement data recovery and back up practices to ensure the safety of the information within our cloud storage or private server. On top of this, we ensure that all the platforms to collect information including company’s laptops distributed to our staff are protected with antivirus software which will include anti-malware, firewall, and so on. 

Should there be any requirement to transfer data outside Nusantara Kitchen Indonesia internal cloud storage or private server, it is only done based on the following: 

- By the consent of the data owner and data controller. 

- For safety reasons and data migration requirements

- Based on the request of the government agencies or authorities. 

- For legal and investigation purposes. 

- Any other valid reason which must be approved by the Centre Director and witnessed as well as consented by the Data Protection Officer. 

6. Your Rights

a) You have the following rights, under applicable data protection laws (except where the exercise of these is restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant Data Protection Officer at the contact details provided in paragraph 3.1.

b) To obtain from us confirmation as to whether or not your Personal Data is being processed and request a copy of your information. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties.

c) Rectification of your Personal Data. We endeavour to ensure that all Personal Data we have about you is accurate and up to date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

d) In certain circumstances, you can request to have your Personal Data deleted or restrict the processing of it.

e) If we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or by contacting us. 

f) Prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual.

7. Management and Security

7.1 We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.

8. Governing Law

8.1 This Policy and your use of this website shall be governed in all respects by the laws of Singapore.  For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.

9. Review of this Policy

9.1 This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.

9.2 In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.