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Privacy Policy - European Union (GDPR)

Effective Date: January 1, 2025

Last Updated: September 21, 2025

1. Data Controller

New Internet Media (NIM) is the data controller for the purposes of the General Data Protection Regulation (GDPR) and other relevant data protection laws.

Contact Information:
Email: [email protected]
Data Protection Officer: [email protected]

2. Legal Basis for Processing

We process personal data based on the following legal grounds:

  • Contract Performance: To provide our blockchain copyright services
  • Legal Obligations: To comply with KYC/AML requirements
  • Legitimate Interests: To improve our services and ensure platform security
  • Consent: For marketing communications and analytics cookies

3. Categories of Personal Data

We collect and process the following categories of data:

  • Identity Data: Name, username, date of birth
  • Contact Data: Email address, telephone number, postal address
  • Technical Data: IP address, browser type, device information
  • Usage Data: How you use our platform and services
  • Copyright Data: Musical works, recordings, and ownership information
  • Blockchain Data: Wallet addresses, transaction history (pseudonymized)

4. Your Rights Under GDPR

As an EU data subject, you have the following rights:

  • Right to Access: Request copies of your personal data
  • Right to Rectification: Request correction of inaccurate data
  • Right to Erasure: Request deletion of your data (subject to blockchain immutability)
  • Right to Restrict Processing: Request limitation of data processing
  • Right to Data Portability: Receive your data in a structured format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent at any time

5. Blockchain Immutability Notice

Important: Due to the immutable nature of blockchain technology:

  • Data recorded on the blockchain cannot be modified or deleted
  • Copyright registrations are permanent and publicly verifiable
  • We can restrict access to off-chain data but cannot alter blockchain records

6. Data Retention

We retain personal data for:

  • Account Data: Duration of account plus 5 years
  • Copyright Records: Permanently on blockchain
  • Transaction Data: 10 years for legal compliance
  • Marketing Data: Until consent withdrawn

7. International Data Transfers

Your data may be transferred outside the EEA. We ensure adequate protection through:

  • Standard Contractual Clauses (SCCs)
  • Adequacy decisions where applicable
  • Your explicit consent for specific transfers

8. Data Security

We implement appropriate technical and organizational measures including:

  • Encryption of data in transit and at rest
  • Regular security audits and penetration testing
  • Access controls and authentication mechanisms
  • Employee training on data protection

9. Third Party Recipients

We may share data with:

  • Service providers (under data processing agreements)
  • Legal and regulatory authorities when required
  • Blockchain network participants (pseudonymized)
  • Partners with your explicit consent

10. Cookies and Tracking

We use cookies for:

  • Essential platform functionality
  • Analytics (with consent)
  • User preferences

You can manage cookie preferences through our cookie banner or browser settings.

11. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect data from children without parental consent.

12. Automated Decision Making

We use automated systems for:

  • KYC/AML verification
  • Copyright verification
  • Fraud detection

You have the right to request human review of automated decisions.

13. Data Breach Notification

In case of a data breach that poses risk to your rights and freedoms, we will notify you within 72 hours in compliance with GDPR requirements.

14. Complaints

You have the right to lodge a complaint with your local supervisory authority. We would appreciate the opportunity to address your concerns before you approach the supervisory authority.

15. Contact Us

For any privacy-related questions or to exercise your rights:

Email: [email protected]
Data Protection Officer: [email protected]
Postal Address: [To be provided]