Please note that the User must be 18 years of age or older to subscribe to the NMA’ Services. In certain jurisdictions, the age of majority may be older than 18, in which case, User must satisfy that age in order to become a user. While individuals under the age of 18 may utilize the NMA’ Services, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.
- Why NMA collect and process the User’s Personal Data
NMA collects and process User’s Personal Data for the following purposes:
- To provide the User with the services he requests from NMA; allow the User the use of online forms, surveys, including NMA’ Services that do not require any form of registration; allow the User to sign up for certain services, such as newsletters, information feeds, SMS updates or to create an account in which case, NMA will ask for Personal Data, such as name, email address, or telephone number;
- AS THE CASE MAY BE, to allow the User to share information; allow the User to take full advantage of the sharing features that NMA offer such as the participation in viewer forums and discussion boards, engagement with 2nd screen co-viewing apps; allow the User to create a publicly visible NMA Profile, which may – if he chooses – include User’s name and photo; combine Personal Data from one service with information from other NMA’ Services to make it easier to share things with people User knows;
- To maintain and improve NMA’ Services; understand how User uses the NMA Services and implement other functionalities; develop new services and offers;
- To tailor the services to the User needs and interests; provide User with tailored content – such as relevant ads and services; allow NMA to know User better to give User more of what User’s want – more shows, more exclusives, more information, more competitions and a better user experience; figure out more complex things like which ads User will find most useful or services and information that are most relevant to User, thereby giving a much better and more useful experience of NMA digital services;
- If such services and features have been activated by NMA at any time: to carry out payment transactions; store transaction history; make sure that User’s subscription to NMA’ Services has been paid; comply with the legal or regulatory obligation in this respect;
- To communicate with User; to allow User to contact NMA; keep record of our exchanges; help solve any issues User might be facing; send User promotional offers and direct marketing; inform User about NMA services, such as letting User know about upcoming program information or improvements to our digital services; contact user for competition and casting to participate in different shows, if any;
- To create and maintain a trusted and safer environment; investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, or other potentially prohibited or illegal activities; protecting NMA sellers’, or User’s rights or property, or the security or integrity of NMA Services; enforcing NMA terms of service or other applicable agreements or policies; verifying User’s identity;
- Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process; fulfilling any other purpose disclosed to User in connection with NMA’ Services; contacting User to resolve disputes and provide an assistance with NMA services.
2 .On what legal basis NMA process the Personal Data
Depending on the data processing at stake, we will generally process your Personal Data on either one of the following bases:
- User’s prior consent: for instance, when Visionless offer the User to register to its services and create an account, subscribe to NMA newsletter or marketing emails or when NMA asks to follow any relevant procedure to allow User to either clearly accept or refuse the envisaged data processing; if User accepts, he will be entitled to withdraw his consent at any time. However, in certain cases, User’s choice not to communicate User’s Personal Data or to withdraw his consent may result in a limitation of his access to NMA services, features or offering. For instance, it may not be possible for User to gain access to certain parts of the websites and for NMA to respond to User’s queries without providing the related information;
- A contractual relationship: in such case, the processing of User’s Personal Data is generally necessary for the execution or the performance of the contract; this means that if User do not wish NMA to process his Personal Data in that context, NMA may refuse to enter into such contract with the User;
- Legal obligations applicable to NMA activities.
3. who may access to the Personal Data
3.1 For the purposes described above, NMA shall grant access to User’s Personal Data to authorized NMA employees who have a need-to-know in order to process it for NMA, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
3.2 In addition, NMA may need to transfer or allow access to the following authorized third-parties:
- Successors in title to NMA’ business (or who are in meaningful discussions about such a possibility with the (prospective) new owners of the business or company); in this respect, if ownership of all or substantially all of NMA’ business changes or undertakes a corporate reorganization or any other action or transfer between NMA entities, User acknowledge that NMA may need to transfer User’s Personal Data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale to, or re-organization by the new owner. NMA may also need to transfer User’s Personal Data to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy;
- NMA’ media representatives;
- Legal advisers, witnesses, experts and judicial and quasi-judicial authorities in order to protect NMA against harm to the rights, property or safety of NMA, NMA users or the public as required or permitted by law, and other third-parties to enforce applicable Terms of service, including investigation of potential violations;
- Administrative or judicial authorities in order to meet the requirements of any applicable law, regulation, legal process or enforceable governmental request.
- NMA may also aggregate, anonymize data publicly and to other authorized third-parties and partners – like advertisers or connected sites. For example, NMA may share information publicly to show trends about the general use of its services.
4. where the Personal Data may be stored or transferred
- NMA may engage multinational affiliates, partners and subcontractors may located in many countries around the world, for that reason, NMA may need to transfer Users’ Personal Data to other jurisdictions, including outside the European Economic Area, in countries whose data protection laws may be of a lower standard than those in User’s country. For instance, NMA may process User’s Personal Data on a server located outside the country where User lives and for this purpose transfer User’s Personal Data out of his country of residence.
5.How NMA protect the security of User’s Personal Data
- NMA maintains appropriate physical, electronic, technical, organizational procedural safeguards and security measures, including governance models, to protect User’s Personal Data in accordance with data protection law against unauthorized access, use, alteration, disclosure or destruction of Personal Data.
- Please note however that no data transmission over the Internet or website can be guaranteed to be secure from intrusion. In addition, User should also take appropriate measures to safeguard his personal data, in particular by keeping his password secure and confidential. If User knows or have reason to believe that his account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of User’s account, please contact NMA following the instructions in the “HOW TO CONTACT US” section below.
- If NMA know or have reason to believe that User’s Personal Data were compromised, NMA will immediately notify affected users of a breach if such one happens in accordance with applicable laws.
6. How long the Personal Data will be kept
- NMA will retain User’s Personal Data as long as his account is active or otherwise for as long as is necessary for the purpose for which NMA have initially collected it. This duration can be up to 10 years. NMA retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized or destroyed.
- NMA aim to maintain its services in a manner that protects information from accidental or malicious destruction. Because of this, after information is deleted from NMA services, NMA may not immediately delete residual copies from its active servers and may not remove information from its backup systems.
- NMA may also retain User’s Personal Data for longer periods if necessary to comply with NMA legal obligations or to protect its legitimate interests.
7. how the User can access, update, and delete his personal data
7.1 In accordance with data protection law User is entitled to exercise the following rights:
- Right to obtain access to his Personal Data, in which case NMA may provide the User a copy of such data, unless it is made available to him directly, for instance within his personal account;
- Right to rectify his Personal Data, should his data be inaccurate or obsolete; in this respect, it is important that the Personal Data NMA hold about User is accurate and current. Please keep NMA informed if User Personal Data changes during the period for which NMA hold User’s data;
- Right to withdraw consent, where the processing relies on his prior consent and to withdraw User’s consent to all marketing processing;
- Right to object to the processing of his Personal Data, where the processing relies on NMA legitimate interest, insofar as User’s particular situation justifies so;
- Right to erasure of User’s personal data;
- Right to restrict the processing of User’s Personal Data;
- Right to receive User’s Personal Data for transmission to a third-party or to obtain the transfer of User’s Personal Data to a third-party of User’s choice where technically possible;
- Right to lodge a complaint with a competent data protection authority if User consider the processing of his Personal Data to infringe data protection law.
7.2 User must note that:
- NMA may need to verify User identity before NMA can act on User’s request;
- Because the exercise of these rights is subject to certain legal conditions and limitations, NMA may have to decline User’s request if those conditions are not fulfilled or if legal limitations apply;
- NMA may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or create a risk on the privacy of others.
- In any case, NMA will seek to deal promptly with User’s request, and in any event within one month (subject to any extensions to which NMA are lawfully entitled). If NMA refuse User’s request, NMA will tell User the reasons for doing so.
8.1 What are the cookies
- A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. A cookie cannot read data off your computer’s hard drive.
- If you browse NMA Services’ websites, cookies will be placed on User’s device: this is why User are informed by the appearance of a pop up. User’s are consent to these cookies if User use NMA Services’ websites.
8.2 Who deposits cookies?
Subject to User’s consent and the choice of configuration of User’s device (computer, tablet, smartphone, etc.) and/or User’s browser, when User access NMA Services’ websites, cookies may be stored by:
- § NMA;
- § NMA suppliers and services providers (in particular technical service providers who process User’s navigation data on behalf of NMA);
- § Third parties (e.g. social media networks, advertisers, advertising agencies, data brokers, programmatic intermediaries). In this case, as we have no control over the storage of these cookies, we invite you to consult the privacy policies and cookie policies of such third parties.
a. Cookies and similar technology are stored, modified, and read for the following purposes when you use NMA Services, where strictly necessary for the NMA Services:
- § To enable User to navigate the websites and provide User the NMA Services;
- § To deliver the proper content allowed in each geographical region based on intellectual property rights licensed to NMA;
- § To identify User and its preferences when he visits NMA digital properties websites;
- § To ensure the security of the NMA Services;
- § To fulfil NMA legal obligations.
- § For the improvement of the performance of the NMA Services:
- § To improve your user experience and the overall quality of the NMA Services;
- § To follow and study User’s browsing / navigation patterns through the website, build up User’s demographic profile and provide User with the most relevant service (for instance, improved recommendations for content that User enjoys);
- § To analyze content consumption habits (for example, programs watched, content read, devices used, etc.) to provide, personalize, measure, and improve NMA advertising and marketing;
b. Why the Cookies being shared
- § To allow social networking sites to track User’s browsing of the NMA Services, especially when User’s relevant social networking account is activated on its device (open session) during User’s browsing;
- § To enable NMA social media, advertising and analytics partners to combine it with other information that User have provided them or that they have collected from User’s use of their services.
c. How can the User manage its cookies preferences?
However, some cookies are essential for NMA to use in order to provide the User with the NMA Services User have requested and switching off cookies may impact NMA’ ability to deliver its Services to the User, resulting in a degraded experience.
- Where applicable (for instance, if the changes imply new data processing that shall rely on User’s prior consent), NMA will ensure that User have had the possibility to accept those changes so as to allow User to continue using NMA services or to refuse – in which case, User will be entitled to cancel your use of the NMA Services.
11. How to contact NMA
If you have any further queries, please contact us on the below email address: [email protected]