Privacy Policy

1. Introduction

NuraTerra Inc (“we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain and protect your personal information when you visit our website at www.nuraterrainc.com and engage with our services.

By providing us with your personal data, you warrant that you are over 13 years of age.

We are the data controller with respect to your personal data.

Contact details:

Full legal entity: NuraTerra Inc

Email address: contact@nuraterra.com

Postal address: PO BOX 360, Port Moresby, Papua New Guinea

It is important that the data we hold about you is accurate and up to date. Please notify us of any changes by emailing contact@nuraterra.com.

2. What personal data do we collect, for what purpose and on what lawful basis?

“Personal data” means any information capable of identifying an individual.

We may collect, process and hold the following categories of your personal data:

Communication Data: any communication that you send to us (via a website contact form, email, text, social-media message or post). We use this data to correspond with you, for record-keeping, and for the establishment, pursuance or defence of legal claims. Our lawful basis for this processing is our legitimate interests (to respond to communications, keep records, and assert or defend our rights).
Customer Data: data relating to any purchase of goods and/or services you make from us: your name, title, billing/delivery address, email, phone number, purchase details, payment card data. We process this data to fulfil the contract between you and us or to take steps at your request before entering the contract.
User Data: data about how you use our website and online services, and data you post for publication via our website or online services. We process this to operate our website, provide relevant content, secure our systems, maintain backups, manage our business, publish content, and administer our services. The lawful basis is our legitimate interests (to run our website and business).
Technical Data: data such as your IP address, login data, browser type, length of visit, page views, navigation paths, number of visits, time zone settings and other technology on devices you use to access our website. This is collected via analytics and used to analyse website use, administer and protect our business and website, deliver relevant content/advertising, and understand advertising effectiveness. Lawful basis: our legitimate interests (to manage our website/business).
Marketing Data: data about your preferences in receiving marketing from us and from third parties, and your communication preferences. We process this to run promotions (competitions, giveaways), send you relevant content and advertising, and measure advertising effectiveness. The lawful basis for marketing communications is either your consent or our legitimate interests (to study customer use of our products/services, develop them, grow our business and decide our marketing strategy).

We may combine the Customer Data, User Data, Technical Data and Marketing Data to deliver relevant content and advertisements and to measure advertising effectiveness. Legal basis: legitimate interests or (where required) consent.

Sensitive Data

We do not collect any “Sensitive Personal Data” (e.g., racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade-union membership, health/biometric/genetic data, criminal convictions/offences), unless you provide it voluntarily for a specific reason and we inform you accordingly.

If you choose not to provide the requested personal data when required for a contract or law compliance, we may not be able to perform the contract (for example to deliver goods/services) and may have to cancel an order: if we do we will notify you at the time.

We will only use your personal data for the purposes for which it was collected, or for another purpose which is reasonably compatible with that original purpose. Where we need to use your data for an unrelated new purpose, we will notify you and explain the legal basis.

We may process personal data without your consent where required or permitted by law.

3. Marketing communications

We will only send you marketing communications if:

you have consented to receive them; or
you have purchased goods/services from us or requested information about them and you have not opted out of receiving marketing (in which case legitimate interests can apply).

Before sharing your personal data with any third party for their own marketing purposes we will obtain your express consent.

You can opt out at any time by using the ‘unsubscribe’ link in any marketing email we send or by emailing contact@nuraterra.com.

If you opt-out of marketing communications, this will not affect processing of your personal data for other transactional/purchase purposes (e.g., fulfilling a contract, warranty registrations etc).

4. Disclosure of your personal data

We may share your data with:

our group companies who help provide services to us;
service providers (IT/infrastructure, system administration);
professional advisers (lawyers, bankers, auditors, insurers);
government, regulatory or law-enforcement bodies where required;
third parties to whom we transfer or sell parts of our business or assets.

We require all third-party recipients to respect the security and confidentiality of your personal data, and to use it only for specified purposes and in accordance with our instructions.

5. International transfers

Since we operate in Papua New Guinea, and you may access our site from anywhere, your data may be transferred to or processed in other jurisdictions. We will ensure that appropriate safeguards are in place so that your personal data receives an adequate level of protection (for example via contracts or by obtaining your consent). Where the law requires, we will ask for your explicit consent before the transfer and you will have the right to withdraw that consent at any time.

6. Data security

We have implemented technical and organisational measures to protect personal data from accidental or unlawful loss, destruction, alteration, unauthorised disclosure or access. Access to your personal data is restricted to personnel who need access for business reasons. They will only process your data on our instructions and are required to keep it confidential.

We also have procedures in place to respond to personal data breaches, and will notify you and any applicable regulator when required by law.

7. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected including satisfying legal, accounting or reporting requirements.

When deciding the retention period we consider the nature, sensitivity and volume of the data, the risk of harm from unauthorised use/disclosure, the processing purposes, whether these purposes can be achieved by other means, and legal obligations.

For example: for tax and accounting purposes we keep basic customer data (identity, contact, financial/transaction data) for six years after you stop being a customer.

In certain cases we may anonymise your personal data (so that you cannot be identified) and use it for research or statistical purposes indefinitely without further notice.

8. Your legal rights

You have rights in relation to your personal data, including the right to:

request access to your personal data;
request correction of inaccurate or incomplete data;
request erasure of your personal data (in certain circumstances);
request restriction of processing;
object to processing (including for direct marketing);
request portability of your personal data (in certain circumstances);
withdraw consent (if the processing is based on consent).

To exercise any of these rights, please email contact@nuraterra.com. You will not have to pay a fee to access your personal data or to exercise these rights (unless your request is clearly unfounded/repetitive/excessive, in which case we may charge a reasonable fee or refuse).

We may ask for information to verify your identity and ensure you have the right to make the request. We aim to respond to all valid requests within one month; occasionally it may take longer if your request is complex or you have made numerous requests, in which case we will tell you and keep you informed.
If you are not satisfied with how we process your data, you may lodge a complaint with the relevant regulator or authority in Papua New Guinea.

9. Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and are not responsible for their privacy practices. When you leave our site we encourage you to read the privacy notice of every site you visit.

10. Cookies

We use cookies on our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies some parts of our website may become inaccessible or not function properly. For more information about how we use cookies (and how you can control cookies) please see our Cookie Policy.

11. Changes to this Privacy Policy

We may update this policy from time to time. The new version will be posted on our website with an updated effective date.

12. Interpretation & contact

In this policy “business days” means Monday to Friday excluding public holidays in PNG.

If you have any questions about this policy or our data practices, please contact us at contact@nuraterra.com.

Effective Date: 20/10/2025

Last Reviewed: 20/10/2025