Legal

Privacy Policy

Effective date: 1 August 2026 · Last updated: 1 August 2026

READ THIS POLICY CAREFULLY. It is a binding statement of how NuGig handles personal information. By accessing, browsing, registering for, or otherwise using the NuGig website, assessment, or any related service (collectively, the “Service”), you acknowledge that you have read, understood, and consented to the practices described below. If you do not agree, you must discontinue use of the Service immediately and refrain from submitting any information to us.

1. Scope and Controller

NuGig (“NuGig”, “we”, “our”, or “us”) operates an editorial and diagnostic tool that evaluates self-reported responses and produces recommendations and structured 30-day plans. This Privacy Policy applies to all personal information processed by NuGig through the Service, regardless of the device or channel used to access it. NuGig acts as the controller (or the equivalent designation under applicable law) for that information.

This Policy does not apply to any third-party website, platform, employer, marketplace, or service that you may reach through a link, referral, or recommendation surfaced by the Service. Those parties operate under their own policies and we bear no responsibility for their practices.

2. Categories of Information We Collect

  • Account identifiers. Email address, a salted and hashed password credential (we never store your password in plaintext), account creation timestamp, and authentication metadata such as session identifiers and sign-in events.
  • Assessment responses. Every multiple-choice selection, slider value, multi-select entry, and free-text response you submit during the assessment, together with progress state, timestamps, and any partial answers saved before completion.
  • Derived and inferred data. Trait profiles, match scores, component breakdowns, archetype classifications, generated plans, goals, check-ins, and other outputs computed from your responses.
  • Voluntary submissions. Suggestions, feedback, ratings, survey responses, and any content you elect to send to us through in-product forms or correspondence.
  • Technical and diagnostic data. IP address, approximate coarse location derived from IP, browser and device characteristics, referring URL, pages viewed, request timestamps, error traces, and performance telemetry.
  • Communications. The content and metadata of messages exchanged with us, including support requests and email delivery events.

We do not request, and you must not submit, government identification numbers, financial account numbers, health records, biometric identifiers, precise geolocation, or any other category of sensitive personal information. Any such information submitted in free-text fields is submitted at your own risk and may be deleted by us without notice.

3. Sources of Information

We obtain personal information (a) directly from you when you complete the assessment, create an account, or contact us; (b) automatically from your device and browser when you interact with the Service; and (c) from our infrastructure providers, who generate operational logs and authentication records on our behalf. We do not purchase personal information from data brokers and do not enrich your profile with externally acquired datasets.

4. Purposes and Legal Bases for Processing

We process personal information only for the purposes set out below, and only where a valid legal basis exists:

  • Service delivery — generating recommendations, scores, plans, and downloadable documents. Basis: performance of a contract.
  • Account operation — authentication, session continuity, cross-device resumption, and account recovery. Basis: performance of a contract.
  • Product improvement — analysing aggregated and de-identified usage patterns, reviewing suggestions, and diagnosing defects. Basis: legitimate interests.
  • Security and abuse prevention — detecting fraud, credential stuffing, scraping, and other misuse; enforcing our Terms of Service. Basis: legitimate interests.
  • Legal compliance — responding to lawful requests, maintaining records, and establishing, exercising, or defending legal claims. Basis: legal obligation and legitimate interests.
  • Optional communications — product updates you have expressly requested. Basis: consent, withdrawable at any time.

We will not repurpose your personal information for a materially different purpose without first providing notice and, where required by law, obtaining your consent.

5. Automated Processing and Scoring

The Service applies a deterministic algorithm to your responses in order to produce match scores, rankings, and plans. This processing is automated. It does not produce legal effects or similarly significant effects concerning you: the outputs are informational suggestions only and are not used to determine eligibility for employment, credit, insurance, housing, or any other benefit. You may request a plain-language explanation of the factors contributing to any score presented to you.

6. Disclosure to Third Parties

We disclose personal information only in the following circumstances, and only to the extent strictly necessary:

  • Processors and infrastructure providers that host our application, database, authentication, email delivery, and model-inference services, each bound by written confidentiality and data-protection obligations and prohibited from using the data for their own purposes.
  • Legal and regulatory recipients where disclosure is compelled by valid legal process, or is necessary to protect our rights, property, safety, or that of our users or the public.
  • Successors in interest in connection with a merger, acquisition, financing, reorganisation, or sale of assets, subject to this Policy continuing to govern the transferred information.
  • Anyone you direct, including recipients of a plan or result you deliberately export, download, or share.

7. No Sale or Sharing for Cross-Context Advertising

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act as amended and comparable state statutes. We have not done so in the preceding twelve months. We do not permit third-party advertising networks to collect personal information through the Service.

8. International Transfers

The Service is operated using globally distributed infrastructure. Your information may therefore be processed and stored in jurisdictions other than your own, including the United States, whose data-protection laws may differ from those of your country of residence. Where such a transfer involves personal data originating in the European Economic Area, the United Kingdom, or Switzerland, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and equivalent instruments, together with supplementary technical and organisational measures.

9. Retention and Deletion

We retain personal information for no longer than is necessary for the purposes for which it was collected. As a general matter: account records and assessment responses are retained for the life of the account and for up to ninety (90) days after a verified deletion request, to permit reversal of erroneous or fraudulent deletions; server and security logs are retained for up to twelve (12) months; and suggestions and feedback may be retained indefinitely in de-identified form. Where you use the Service without an account, assessment progress is stored solely within your browser and is not transmitted to us except where you expressly submit it.

We may retain information for longer where required to comply with a legal obligation, resolve a dispute, prevent fraud or abuse, or enforce our agreements.

10. Security Measures and Their Limits

We employ technical and organisational safeguards commensurate with the sensitivity of the data we hold, including encryption in transit, encryption at rest for stored records, row-level access controls that restrict each record to its owner, hashed credential storage, least-privilege administrative access, and routine automated security review.

NO METHOD OF TRANSMISSION OR STORAGE IS ABSOLUTELY SECURE. We do not warrant, and you must not assume, that unauthorised access, disclosure, alteration, or destruction of information can never occur. You are solely responsible for maintaining the secrecy of your credentials, for using a unique and sufficiently strong password, and for promptly notifying us of any suspected compromise of your account.

11. Your Rights and How to Exercise Them

Subject to applicable law and to verification of your identity, you may exercise the following rights: access to the personal information we hold about you; correction of inaccurate or incomplete information; deletion of your account and associated records; portability of the information you supplied in a structured, machine-readable format; restriction of, or objection to, processing carried out on the basis of legitimate interests; and withdrawal of any consent previously given, without affecting the lawfulness of processing carried out before withdrawal.

To exercise a right, submit a request through the Suggestions form or contact the site owner using the details in Section 17. We will respond within the period prescribed by applicable law, and in any event without undue delay. We may decline a request that is manifestly unfounded, excessive, repetitive, or that would adversely affect the rights of another person, and we will explain the reason for any refusal. We will not subject you to discriminatory treatment for exercising your rights.

12. Cookies and Local Storage

We use strictly necessary cookies, local storage, and session storage to maintain your signed-in session, preserve assessment progress, and remember interface preferences. We do not deploy advertising cookies, cross-site tracking pixels, or third-party behavioural profiling technologies. Blocking or clearing this storage is permitted, but doing so will impair core functionality, including your ability to remain signed in or resume an incomplete assessment.

13. Children and Age Restrictions

The Service is intended exclusively for individuals aged eighteen (18) years or older, or the age of majority in your jurisdiction, whichever is greater. It is not directed to children. We do not knowingly collect personal information from any person under the age of thirteen (13), and where required, from any person under sixteen (16) without verifiable parental consent. If we become aware that such information has been collected, we will delete it promptly and terminate the associated account. A parent or guardian who believes a minor has provided information to us should contact us immediately.

14. Third-Party Links and Destinations

Recommendations and plans may reference external platforms, marketplaces, tools, or publications. Such references are provided for convenience and do not constitute an endorsement, partnership, or guarantee of any kind. Once you leave the Service, this Policy ceases to apply, and the receiving party’s own terms and privacy practices govern. Review them before disclosing any information.

15. Your Obligations Regarding Submitted Data

You must not submit personal information relating to any other individual unless you have a lawful basis to do so and have obtained all necessary consents. You must not submit confidential information belonging to an employer or third party, content that infringes the rights of others, or unlawful, defamatory, or malicious material. You warrant that all information you provide is accurate and that you are entitled to provide it. We reserve the right to remove any submission and to suspend or terminate any account that breaches this Section, without notice and without liability.

16. Changes to This Policy

We may amend this Policy from time to time to reflect changes in our practices, technology, or legal obligations. The “Last updated” date above will always reflect the current version. Where an amendment materially reduces your rights, we will provide reasonable advance notice through the Service or by email before it takes effect. Your continued use of the Service after the effective date constitutes acceptance of the amended Policy. If you object to an amendment, your sole and exclusive remedy is to cease using the Service and request deletion of your account.

17. Contact and Complaints

Privacy enquiries, rights requests, and complaints should be directed to the site owner via the Suggestions form. We take every complaint seriously and will investigate in good faith. If you are located in the European Economic Area or the United Kingdom and remain dissatisfied with our response, you retain the right to lodge a complaint with your local supervisory authority.

This page is maintained by NuGig. It is a statement of our own practices and does not constitute legal advice, an independent audit, or a certification by any third party.