1. Introduction and Data Controller
NML — New Media License PTE LTD ("NML", "we", "us", or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at nml.world, use our services, or otherwise interact with us.
NML acts as the data controller for the personal data described in this policy. Our registered office is located at 10 Anson Road #12-14, International Plaza, Singapore 079903 (UEN: 201540896K).
This policy applies to all individuals whose personal data we process, including website visitors, clients, business partners, prospective clients, and job applicants. By accessing our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.
2. Information We Collect
Personal Data You Provide
We collect personal data that you voluntarily provide to us, including but not limited to:
- Name, email address, phone number, and postal address
- Company name, job title, and professional details
- Information submitted through our contact forms, including messages and inquiries
- Identification documents provided for due diligence and compliance purposes
- CVs, cover letters, and related application materials submitted for employment opportunities
- Payment and billing information in connection with our services
Usage Data
When you visit our website, we automatically collect certain technical information, including:
- IP address and approximate geographic location
- Browser type, version, and operating system
- Pages visited, time spent on pages, and navigation paths
- Referring website or source
- Device type and screen resolution
- Date and time of access
Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your browsing experience and gather analytical data. For detailed information about the cookies we use, please refer to our Cookie Policy.
3. How We Use Your Information
We use your personal data for the following purposes:
- Service Delivery: To provide, maintain, and improve our payment aggregation, receivables management, telecommunications, and software licensing services.
- Communication: To respond to your inquiries, send service-related notices, and provide information about our services that may be of interest to you.
- Legal Compliance: To comply with applicable laws, regulations, and legal processes, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
- Security: To detect, prevent, and address fraud, security breaches, and other potentially prohibited or illegal activities.
- Business Operations: To manage our business relationships, process transactions, and administer our contractual obligations.
- Recruitment: To evaluate job applications and manage our hiring processes.
- Analytics: To understand how our website is used and to improve user experience, content, and functionality.
4. Legal Basis for Processing
In accordance with Article 6 of the General Data Protection Regulation (GDPR), we process your personal data on the following legal bases:
- Consent (Article 6(1)(a)): Where you have given clear consent for us to process your personal data for a specific purpose, such as receiving marketing communications or the use of non-essential cookies.
- Contractual Necessity (Article 6(1)(b)): Where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.
- Legal Obligation (Article 6(1)(c)): Where processing is necessary for compliance with a legal obligation to which we are subject, including regulatory requirements in Singapore and the European Union.
- Legitimate Interests (Article 6(1)(f)): Where processing is necessary for the purposes of our legitimate interests or those of a third party, provided that such interests are not overridden by your rights and freedoms. Our legitimate interests include operating and improving our services, marketing our business, and ensuring network and information security.
5. Data Sharing and Third Parties
We do not sell your personal data to third parties. We may share your information in the following circumstances:
- Service Providers: We engage trusted third-party companies and individuals to perform services on our behalf, such as hosting, analytics, payment processing, and customer support. These providers have access to your personal data only to perform specific tasks and are obligated to protect it.
- Legal Requirements: We may disclose your personal data if required to do so by law, regulation, legal process, or governmental request, including requests from regulatory authorities in Singapore and the European Union.
- Business Transfers: In the event of a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change and the choices you may have regarding your data.
- Professional Advisors: We may share data with our legal, financial, and other professional advisors where necessary to obtain advice or protect our rights.
- With Your Consent: We may share your personal data with third parties when you have given us explicit consent to do so.
6. International Data Transfers
As NML operates across Europe and Asia, your personal data may be transferred to and processed in countries other than your country of residence, including Singapore and countries within the European Economic Area (EEA).
Where we transfer personal data from the EEA to countries that have not been deemed to provide an adequate level of data protection by the European Commission, we implement appropriate safeguards to protect your data, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Binding corporate rules where applicable
- Transfers to countries recognised as providing adequate data protection
Singapore has been recognised by the European Commission as providing an adequate level of data protection. You may request a copy of the safeguards we use for international transfers by contacting us at privacy@nml.world.
7. Data Retention
We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, and applicable legal requirements.
In general:
- Client and contractual data is retained for the duration of the business relationship and for a period of seven (7) years thereafter to comply with regulatory requirements.
- Contact form submissions and general inquiries are retained for up to two (2) years.
- Job application data is retained for up to twelve (12) months after the conclusion of the recruitment process, unless you consent to longer retention.
- Website analytics data is retained in aggregated, anonymised form and does not identify individual users.
8. Your Rights
Under the GDPR and applicable data protection laws, you have the following rights regarding your personal data:
- Right of Access: You have the right to request a copy of the personal data we hold about you and information about how we process it.
- Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data.
- Right to Erasure: You have the right to request the deletion of your personal data where there is no compelling reason for continued processing.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
- Right to Object: You have the right to object to the processing of your personal data based on our legitimate interests or for direct marketing purposes.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise any of these rights, please contact us at privacy@nml.world. We will respond to your request within thirty (30) days. You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.
9. Cookies
Our website uses cookies to distinguish you from other users, to provide a better browsing experience, and to help us improve our site. Cookies are small text files that are placed on your device when you visit our website.
We use essential cookies that are strictly necessary for the operation of our website, as well as analytics and functional cookies that help us understand how visitors use our site and allow us to remember your preferences.
For comprehensive information about the types of cookies we use, how we use them, and how you can manage your cookie preferences, please see our Cookie Policy.
10. Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit using TLS/SSL protocols
- Encryption of sensitive data at rest
- Access controls and authentication mechanisms to limit access to personal data
- Regular security assessments and penetration testing
- Employee training on data protection and security best practices
- Incident response procedures for data breaches
While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining industry-standard safeguards.
11. Children's Privacy
Our website and services are not directed at individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without verification of parental consent, we will take steps to delete that information promptly. If you believe that we may have collected information from a child, please contact us at privacy@nml.world.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes to this policy, we will notify you by posting the updated policy on our website with a revised "Last updated" date. We encourage you to review this page periodically to stay informed about how we protect your data.
13. Contact
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:
NML — New Media License PTE LTD
10 Anson Road #12-14, International Plaza
Singapore 079903
Email: privacy@nml.world
Phone: +65 6123 4567