Privacy Policy

Effective Date: 25 May 2018

General

NMG Consulting Ltd. (“NMG”, “we”, “our” or “us”) is committed to respecting your privacy and protecting information that identifies or is associated with you (“personal information”), whether you are a client, a research respondent, or an individual visiting our website (https://nmg-group.com/).

This Privacy Policy contains important information about who we are; what personal information we collect and how we use it; the legal bases that we rely on to process that information; who we share it with and why; and what rights you have in respect of the personal information you give us.

Occasionally, we may need to make changes to our Privacy Policy. If there are important changes to our Privacy Policy, we will let you know.

This Privacy Policy applies to NMG and its subsidiaries, which manage the products and services we offer to our clients. It also applies to all personal information received by NMG, whether electronically, verbally, or in paper format.

 

Who We Are

NMG offers client focused strategy, management and actuarial consulting services; objective studies into market trends, business allocations, competitive dynamics and client positioning and capability; and detailed Market and Custom Analytics for financial institutions including insurers, reinsurers and fund managers. NMG has offices in the United Kingdom, Canada, Malaysia, Singapore, Australia, Sri Lanka, and the United States.

The identity of the controller responsible for your personal information will depend on who you are and how you are engaging or interacting with NMG. If you are an individual using our website, the data controller is NMG. If you are a research respondent, the data controller is the NMG entity you have interacted with. If you are a client (or representative of a client), the relevant data controller will depend on the NMG office you are engaging with, as set out below:

Office Relevant Data Controller
United Kingdom N.M.G. Financial Services Consulting Ltd.; or

BQM UK Ltd.

Canada NMG FSC Inc.
Malaysia NMG Financial Services Consulting Sdn. Bhd.
Singapore NMG Financial Services Consulting Pte. Ltd.; or

BQM Holdings (trading as NMG Strategic Insights) Pte. Ltd.

Australia NMG Financial Services Consulting Pty Ltd.
Sri Lanka NMG Management Advisors Pvt Ltd.
United States NMG Consulting Inc.

Flaspöhler Research Group, Inc.

How We Collect and Obtain Your Personal Information

We may collect your personal information from a variety of sources.

Where you are a research respondent this may include:

  • From publicly available sources (for example, LinkedIn), where permitted by law;
  • Information we lawfully obtain from third parties such as marketing and other lists;
  • Information we lawfully obtain from our clients;
  • Referrals from clients and research respondents; and
  • Information you have provided where you have participated in research surveys conducted by NMG or an associate on our behalf.

 Where you are a visitor to our website or a client (or representative of a client), this may include:

 Directly from you when you voluntarily submit information to us; for example, when you access our website, contact any of our personnel, use our services or where you apply for a job via our website, LinkedIn or other external job board;

  • Directly from you when through email or phone conversations you have with us; and
  • Your interaction with NMG’s website including information we automatically collect when you browse the NMG website.

 

What Personal Information We Collect and How We Use It

Where you are a research respondent, the table below sets out the categories of personal information we collect about you, how we use that information and the relevant legal basis.

If we obtain your contact information from a research panel or other third party, we will use that information in accordance with your agreement with that third party when you signed up to participate in the survey research or when you became a customer of that third party. We may occasionally re-contact you to validate your contact information or your consent to participate in a research study; we will identify ourselves and our purpose when we conduct such validation contacts.

Category of personal information How we use it Legal basis for the processing
Contact details and basic personal details. This includes your name, company, company location, business email and business phone.

 

We use this information to contact you to participate in market research surveys.

 

The processing is necessary for our legitimate interests, namely our business and commercial interests in performing and providing market research and insights. In addition, where we have obtained your contact details from a third party, we will process your information on that third party’s warranting they have a proper legal basis to request that we process your information.]

 

We use this information to manage our relationship with you, including maintenance of our database of research respondents for administration, accounting, and relationship management purposes.

 

The processing is necessary for our legitimate interests, namely our business interests in efficiently and effectively managing our relationship with you and related purposes.
Professional information. Such as income level / range.

 

We use this information as part of analyses incorporated into the study that is being conducted. Studies may include the following:

·    To help our clients plan products or services;

·    To gauge customer / member satisfaction;

·    To measure awareness of products or services; or

·    To test reaction to products, services or communications.

 

The processing is necessary for our legitimate interests, namely our business and commercial interests in performing and providing market research and insights.
Personal details. Such as your gender and age.

 

We use this information to help us in segmenting the sample of the population we are studying.

 

The processing is necessary for our legitimate interests, namely our business and commercial interests in performing and providing market research and insights.
Bank account information. Such as your account number.

 

We use this information to provide rewards for participation in our research studies. We process this information where you have provided your consent.
Any other such information which we may obtain from you in the course of your completing a questionnaire. We use such information in connection with our research studies, which may have certain bespoke requirements based on our clients’ requests. The processing is necessary for our legitimate interests, namely our business and commercial interests in performing and providing market research and insights.

Where you are a visitor to our website or a client (or representative of a client), the table below sets out the categories of personal information we collect about you, how we use that information and the relevant legal basis:

Category of personal information How we use it Legal basis for the processing
Contact and basic personal details. Such as your name, contact information or other information that you give to us to inquire about our services.

 

We will use this information to contact you about our services. We will process such personal information based on the legitimate interest of providing you information related to our services.

 

We will use this information to correspond with you and to perform our services to you. The processing is necessary for the performance of a contract to which you are a party (and to take steps at your request prior to entering into such contract).

 

We may process this personal information in order to manage our relationship with you. This would include maintenance of our database of clients for administration, accounting, and relationship management purposes.

 

The processing is necessary for our legitimate interests, namely our business interests in efficiently and effectively managing our relationship with you and related purposes.
Recruitment information. Information you provide when apply for positions at NMG including employment information such as resume, references or LinkedIn profile.

 

We may process your personal information in connection with any job application you (or your authorized representative) have submitted.

 

We process this information where you have provided your consent.
Information that is automatically collected when you visit our website. This would include information about how you access and use our website and information about the device you are using to access our website.

 

We may process your personal information in relation to the functioning of our website. Namely, we may process your information:

 

·    To enhance and customize our website according to your interests and preferences through means including troubleshooting, data analysis, testing, research, statistical and survey responses;

·    To allow you to participate in interactive features on our website when you choose to do so; and

·    To aid our efforts to keep our website safe and secure.

 

We process this information for our legitimate interests namely to tailor our website to you, for marketing purposes, to allow you to participate in features on our website and to ensure the safety and security of our website.
Contact and basic personal details; Recruitment Information; Information that is automatically collected when you visit our website. We may process your personal information in order to comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place. We process the information in where it is necessary to comply with a legal obligation.

 

We may process your personal information as we feel is necessary to prevent illegal activity or to protect our interests.

 

We process this information for our legitimate interests namely to prevent illegal activity and to protect our business interests.

 

Place of Processing

If you are visiting our website or are participating in one of our research studies, please be aware that your information may be transferred to, stored, and processed in the United Kingdom, Canada, Malaysia, Singapore, the United States, Sri Lanka, Belgium and/or Australia where NMG and our affiliate companies have operations. While the data protection and other laws of these countries might not be as comprehensive as those in your country, please be assured that we take steps to ensure that your privacy is protected, including restricting access, enabling encryption, and putting in place standard contractual clauses between the various NMG entities. Additionally, NMG personnel may access our systems remotely when working abroad (including from jurisdictions outside the EEA). Where they do so, they are required to use our data systems and access any personal information in accordance with NMG’s internal policies and procedures.

Furthermore, if we need to share your personal information with a third-party service provider, we will ensure we do so in compliance with relevant data protection legislation and will review our contracts regularly to ensure we are compliant.

 

Individual Rights

 You have the following rights under applicable data protection legislation in relation to your personal information:

  • Right of access. The right to obtain access to your personal information along with certain related information;
  • Right to data portability. The right to receive your personal information in a commonly used format and to have your personal information ported to another data controller;
  • Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
  • Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
  • Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

If you wish to exercise one of these rights, please contact us using the details set out at below. You also have the right to lodge a complaint to the relevant data protection regulator.

 

Disclosure of your Personal Information

We will share your personal information with the following categories of recipients for the purposes set out above.

  • Service providers: that enable us to fulfil our contractual obligations to you and/or our clients in the course of business, which may include:
    • contractors who conduct fieldwork, including interviews, for our studies;
    • third-party transcription services;
    • third-party recruitment services;
    • banks and other payment processors;
    • third parties that provide security, email security, data governance, archiving, research support and other IT and business support services;
    • email marketing platform provider and our website platform provider; and
    • selected partner digital agencies and online job application providers; analytics and search engine providers that assist us in the improvement and optimisation of our website.
  • Our affiliates and companies in the same group of companies as us: our affiliates and subsidiaries (ie., any organization or brand we own or control or any organization that owns or controls us and any subsidiaries it owns). These companies may use your personal information in the same way as we can under this Privacy Policy.
  • Third parties at your request: any third party you ask us to share your personal information with.
  • Purchasers and third parties in connection with a business transaction: personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of NMG assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliated NMG entity or third party, or in the event of a bankruptcy or related or similar proceedings
  • Law enforcement, regulators and other parties for legal reasons: third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our client contractual terms or to protect the security or integrity of our service; and/or (c) exercise or protect the rights, property, or personal safety of NMG, our visitors, or others.

Our website may, from time to time, contain links to and from the websites of advertisers and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We will never sell your personal information to any other organisation or individual.

 

Storing Your Personal Information

Security of your information. We maintain appropriate security measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information you register on our website is transmitted across the Internet in an encrypted state and is stored in a secure data centre.

 

Retention of your information: We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests, observing our contractual obligations as data processor in respect of our engagements with clients, and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

 

ENFORCEMENT

NMG uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with any applicable standards that govern international transfer of protected data.

 

AMENDMENTS

Our Privacy Policy may be amended from time to time consistent with the regulations and law surrounding the international movement of data. We will post any revised policy on our website or notify you by sending a notice to the email address you provided to us or by placing a prominent notice on our website or on our surveys.

 

CONTACT INFORMATION

Questions, comments or complaints regarding our compliance or data collection and processing practices can be addressed as described below.

 

TO CONTACT US WITH A COMPLAINT OR INQUIRY

If you have any questions, complaints or problems related to the way we collect or use your information, if you wish to opt out of any contact list, or have a concern with our privacy policy in general, please contact us though our website or write to us at:

 

Chief Operating Officer
NMG Consulting Limited
#03-02A
30 Hill Street
Singapore 179360