Privacy Policy
NEWM
Privacy Policy
This statement describes how NEWM (“we” “our” or “us”) collect, process, use, disclose, and transfer your personal information as a data controller, what information we may collect, how we handle it, and to whom we may make it available. It covers instances when you contact us, use our product or services, or interact with our website(s) https://www.newm.io/ ” and any derivatives thereof, thereafter "our website or websites".
We’re committed to protecting and respecting your privacy. We will keep your personal data safe and private, never sell or disclose your personal data without your consent, allow you to manage and review your marketing choices at any time.
1. About us
We are BaseBeat Inc. House of Francis, Room 303, Ile Du Port, Mahe, Seychelles, a company duly formed in the Republic of Seychelles and affiliates and we act as NEWM. We are using blockchain technology so artists can securely sell/auction music Intellectual Property (IP) rights directly to fans, music labels and investors via NFTs. (“Services”). We present a Marketplace, Recordstore, Wallet (“Products”), More information in our Terms and Condition https://newm.io/tos/
2. Representative and contact information
We have appointed a data protection specialist who also acts as our representative in the EEA/UK. For more information regarding privacy please contact us [email protected]
3. Which law applies?
As we operate worldwide, we understand and take into account privacy laws applicable to Your processing of data, in particular but not limited to GDPR, UK GDPR, CCPA.
4. Whose data we collect?
- If use and navigate the Site (“Vistor”)
- If register on our website (“User”)
- If upload and distribute music with NEWM to music streaming platforms (“Artist(s)”)
Collectively “YOU”
5. How do we collect personal data?
We collect data either directly from You once you visit our website or use our Products and Services or form third parties either with Your consent or if needed to fulfil our obligations.
| Directly | Third parties | Third parties data |
| While registration | While Registration | Google Apple |
| While using Marketplace (buy/sell) | While using Marketplace (buy/sell) | Sanctions screening providers; credit reference or agencies; Client due diligence providers; |
| Website | Website | Cookies - please see Cookies Preferences Settings |
| While uploading and distribute music | x | x |
| While using Wallet | While using wallet | Public ledger Blockchain |
5. What Personal data do we collect?
Personal data is any information related to You which can directly or indirectly identify you. Having this in mind please what kind of personal data we process:
- Your name, stage name, photograph, gender, address, your title or position;
- Information to enable us to check and verify your identity and conduct KYC,
- Electronic contact details, e.g., your email address and mobile phone number, Professional and social media exchanges and platforms;
- Blockchain-based information such as Wallet address, transaction ID
- Login ID and password set by you for our services for access control
- Technical information (including your IP address, the name of your internet access provider, the date and time of access, the name and URL of the retrieved file, the country from which the Websites are accessed, the operating system of your computer and the browser you are using like provider, version, and language), such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
- Information relating to the matter in which you are seeking our advice or representation
- Any other information relating to you which you may provide to us, or which may have been provided by others about any potential or actual engagement.
- Customer support and online services: If you contact us with a query or comment about any of our services, or would like us to keep you informed about the latest news and developments at NEWM, we will need to collect information about you (including your contact details) to help us respond to your query or request.
5. What Personal data do we collect?
To help you understand the legal grounds on which we process your data, please check the table below that sets out the legal bases upon which we process your personal information in certain circumstances. There may be one or more legal bases applicable to the activities listed.
| # | What we use your information for | Further details and our Legitimate Interest | Legal basis for using personal information |
| 1 | To provide the Service in accordance with our contract with you. | For example, we may use your personal data to:
| Your consent Contract fulfillment Our legitimate interest Our legal or regulatory obligationsat |
| 2 | To evaluate and develop new features, technologies, and improvements to the Service. | For example, we may use your personal data to:
| |
| 3 | To operate and maintain our relationship with clients, or conduct business planning, reporting, and forecasting, invoicing and hiring. | - Developing and growing our business - Obtaining your consent where needed for contact - Maintaining proper practice and efficiencies in meeting our legal, regulatory, and commercial obligations | |
| 4 | To manage additional services, we may provide to you | To ensure that we can carry out any additional services you request we will process special categories of data, such as your region, transaction history, and wallet details. | To perform our contract with you. |
| 5 | To communicate with you in relation to services being provided | In order to communicate with you to provide updates regarding service availed or products purchased, for example, if there are likely to be delays in the service provision or product delivery, we will need to process personal information about you such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. | |
| 6 | To provide you with customer support | In order to provide you with customer support including for inbound emails or other forms of communications relating to services availed on our platform, to modify, special services, cancellations and refunds, ancillary sales, and outbound calls for disruption related messages we will need to process personal information about you such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals. We may also process sensitive personal information such as race, ethnicity, or religion. | Legitimate interests. It is in our legitimate interests to promote our business and develop our relationship with you. In order to do this, we may wish to bring to your attention new offers from us or our affiliates. It is unlikely that us doing this will override your interests or fundamental rights and freedoms which require protection of your personal data. If you are a data subject protected by the GDPR you have the right to restrict or object to this processing, however, please note that this may adversely affect our ability to
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| 7 | To communicate with you on new offers and services from NEWM or other affiliates and do marketing | In order to communicate with you regarding new offers and services from either us or our affiliates, we will need to process personal information about you such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. | |
| 8 | To engage in surveys with you | In order to obtain feedback from you via surveys about our services and other matters related to our business we will need to process personal information such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. | |
| 9 | To handle complaints made by you | In order to handle complaints made by you, we will need to process your personal information such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details, and may include special categories of data such as data where relevant to your complaint. | |
| 10 | To comply with legal or regulatory obligation, including providing specific information to law enforcement or similar bodies upon legitimate requests. | In order to comply with a legal or regulatory obligation, including providing specific information to law enforcement or similar bodies upon request we will need to process your personal information such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. | Legitimate Interests Processing is necessary for compliance with a legal obligation to which we are subject. It is in our legitimate interests to be able to share information with law enforcement or similar bodies from time to time, subject to their legitimate requests. We will need to be able to process this information for us to comply with legitimate requests, including in cases where we determine that we are not compelled to by applicable laws. Prior to sharing that information, we will ensure that by properly exercising our right to act in our legitimate interest to share the requested data we will not be overriding your interests or fundamental rights and freedoms which require protection of your personal data. |
| 11 | In the case that you start a legal claim against us we need to defend that legal claim. | In order for us to defend the claim brought by you or a third party, we may need to process your personal information such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. We may also need to process your special categories of data such as your racial or ethnic origin, political, religious, or philosophical beliefs, or trade union membership, and the processing of KYC data to uniquely identify a natural person, data concerning your sex life or sexual orientation. | Legitimate Interests It is in our legitimate interests to be able to commence or defend legal claims as and when we consider it necessary for the protection of our business. We will need to be able to process this information for us to instruct our legal counsel and fully defend ourselves against the claim you may bring. It is unlikely that by properly exercising our rights to commence or defend claims we will override your interests or fundamental rights and freedoms that require protection of your personal data. |
| 12 | In the case that we start a legal claim against you. | In the event that NEWM wishes to commence a claim against you, we may need to process your personal information such as your name, address, date of birth, contact details, bank account details, wallet details, credit card details, passport details, ticket/reference number, identifiers for professionals and contact details. We may also need to process your special categories of data such as your racial or ethnic origin, political, religious, or philosophical beliefs, or trade union membership, and the processing of KYC data for the purpose of uniquely identifying a natural person, data concerning your sex life or sexual orientation. | Legitimate Interests It is in our legitimate interests to be able to commence or defend legal claims as and when we consider it necessary for the protection of our business. We will need to be able to process this information for us to instruct our legal counsel and fully defend ourselves against the claim you may bring. It is unlikely that by properly exercising our rights to commence or defend claims we will override your interests or fundamental rights and freedoms that require protection of your personal data. |
| 13 | To do profiling and analyze | Some of the legitimate purposes we profile and analyze data include:
| Legitimate Interests It is in our legitimate interests to be able to do profiling and analyses |
| 14 | To protect our reputation and interests. | blocking malicious actors or reporting them to the authorities. | Legitimate interests. Our website is accessible to the general public and actors with malicious intentions can also access our website (e.g., those who make inquiries as part of a phishing attempt or those who attempt to hack into our IT systems). hence we can use the information available with use to protect our legitimate interest |
7. Transfer of your personal information (Data Processors)
In order to properly conduct our Services we are using third parties vendors. We will always strive to adopt the highest standards of privacy protection, wherever your personal information is located and adopt appropriate measures (consistent with locally applicable laws) to secure an adequate level of privacy protection.
When we transfer your personal information outside NEWM or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information.
The list of our data processors and sub processors:
EVEARA: https://eveara.com/privacy/
iDenfy: https://www.idenfy.com/privacy-policy/
NMKR: https://www.nmkr.io/legal#privacy
SickCity: https://sickcity.xyz/
Google: https://policies.google.com/privacy?hl=en
The list will be updated periodically.
We are also disclosing data to: our affiliates, group companies, partnership ventures, or joint ventures.
8. To whom we disclose Your data (Third parties)?
In order to conduct our Services and Product we disclose Your data to third parties either upon your consent or legitimate interest, to this end:
- Cookies - if you decide to opt in to third parties cookies your data will be disclosed.
- Streaming Platforms - Apple, Spofify etc. We may change third party streaming platforms and it’s Artists sole discretion which one to choose.
Please note that we are not responsible for third parties' privacy policies and you should check privacy rules prior to giving your consent.
If required by applicable we disclose your personal information to the authorities.
We don’t sell you personal information.
9. How do we protect your information?
We utilise a range of tools, techniques, measures, and safeguards such as firewalls, backup and disaster recovery systems, antimalware, and encryption to ensure that your Personal Information is secure and not at risk of unauthorised access disclosure or accidental loss.
Notwithstanding our robust breach detection measures, no information system can be 100% secure and to this extent, we are unable to guarantee the absolute security of your information in cases where you transmit your Personal Information to us over networks that we do not control. In the event of a security breach, we will notify you in accordance with the requirements provided under our policies and applicable laws.
10. Storing your personal information
We will store your personal information for:
- the time You have a relation with us as an User or an Artist.
- the time we need to pursue our claims and rights.
- the time when you gave us your consent
- 3 months once you close your account unless we have other legal ground to store your data.
- as long as it is reasonably necessary for the purposes for which it was collected.
Where your information is no longer required, we will ensure it is disposed of in a safe manner. Furthermore, your personal data is stored in accordance with the retention period imposed by current regulations. This retention period depends on the purpose for which the data is being processed and takes into account regulations that impose a specific retention period for certain categories of data. IIn specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings
11. International Data Transfer
Your data is stored on an AWS server in the US. For EEA/Uk data subjects we inform You that the transfer is based on an adequacy decision granted by European Commision and Standard Contractual clauses.
12. What happens if you refuse to or fail to share your personal data with us
In general, we receive your personal data where you provide this on a voluntary basis. There are certain cases where your refusal or failure to provide the requested personal data may mean we will be unable to act for you i.e., if we are legally required to obtain such information to comply with anti-money laundering legislation.
13. Children's Information
To be a User or an Artist you need to be 18 years of age. As a Visitor we inform You that our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. NEWM does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
15. Updates
We may amend this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check this webpage and the privacy sections for the latest version of our Privacy Notice. If we make material changes to this privacy statement, we will seek to inform you by notice on our website or email ("Notice of Change").
GDPR and UK GDPR
If you are resident in the European Union or otherwise benefit from rights as a data subject under the EU General Data Protection Regulation ("GDPR"), you will have certain additional rights in relation to our handling of your personal information.
Right to be informed: Data subjects have the right to be informed about the collection and use of their personal data.
Right to access: Data subjects have the right to view and request copies of their personal data.
Right to rectification: Data subjects have the right to request inaccurate or outdated personal information be updated or corrected.
Right to be forgotten/Right to erasure: Data subjects have the right to request their personal data be deleted. Note that this is not an absolute right and may be subject to exemptions based on certain laws.
Right to data portability: Data subjects have the right to ask for their data to be transferred to another controller or provided to them. The data must be provided in a machine-readable electronic format.
Right to restrict processing: Data subjects have the right to request the restriction or suppression of their personal data.
Right to withdraw consent: Data subjects have the right to withdraw previously given consent to process their personal data.
Right to object: Data subjects have the right to object to the processing of their personal data.
Right to object to automated processing: Data subjects have the right to object to decisions being made with their data solely based on automated decision-making or profiling.
CCPA
If you are resident in California US or otherwise benefit from rights as a data subject under the California Privacy Rights Act , you will have certain additional rights in relation to our handling of your personal information.
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to opt-out of the sale or sharing of their personal information; and
- The right to non-discrimination for exercising their CCPA rights.
- The right to correct inaccurate personal information that a business has about them; and
- The right to limit the use and disclosure of sensitive personal information collected about them.