1. Scope of This Policy
This policy covers all personal data that NMK GLOBAL LINKS PTE. LTD. handles while operating the link exchange desk. It applies to visitors of the website, to partners who open tickets or request plate builds, to engineers and coordinators who work at the desk, and to anyone who sends an email, telephones the office, or attends a splice bay session or handover evening in person.
The policy does not cover websites that we link to from a plate or shelf. Those sites are run by other organisations, and each has its own privacy notice. When a reader follows a link away from our pages, the destination is responsible for what happens next. We ask partners to keep their own notices accurate, but we do not control their practices and cannot answer for them.
The policy also does not cover information that is placed in a public directory of a partner network and is therefore visible to everyone by design. If a partner publishes a business name and a page address on a public hub plate, that publication is the partner decision, and this policy governs only the records we keep behind the plate.
We review this policy whenever the desk adds a routine, changes a supplier, or alters the way records are stored. The effective date at the top of the page tells you which version is in force. Where a change is material, we write to partners who hold an open ticket before the change takes effect.
2. Who Is Responsible for Your Information
NMK GLOBAL LINKS PTE. LTD. is the organisation responsible for the personal data described in this policy. The registered address is 10 Jalan Besar #13-04 Sim Lim Tower 208787, Singapore (SG). The desk can be reached by email at admin@nmkglobal.lol and by telephone at +14068366779 during business hours, which are Monday to Friday from 09:00 to 18:00 Singapore time, excluding public holidays.
The developer name used across the desk is NMK Global. That name appears on website pages, on ticket templates and on plate sheets, and it refers to the same operation described in this policy. When you see NMK Global on a record, the responsible organisation is NMK GLOBAL LINKS PTE. LTD.
A named coordinator is assigned to every open ticket and is the first point of contact for privacy questions about that ticket. If the coordinator is unavailable, any member of the desk can retrieve the record and answer, because every ticket is written to be read by someone other than the person who opened it.
3. Information We Collect
The desk collects information in several ways, and the amount depends on how you interact with it. A reader who only visits the website provides far less than a partner who opens a ticket and books a splice session. The categories below describe what may be collected and the normal channel through which each category arrives.
Information you give us directly
- Contact details such as your name, email address, telephone number and organisation name.
- Page addresses and subject descriptions supplied when opening a ticket or requesting a plate build.
- The content of messages sent through the contact form, by email or in a written note handed to a coordinator.
- Booking details for a visit, a splice bay session or a handover evening, including the names of people attending.
- Payment and invoicing details for partner accounts that are billed by the desk.
Information created at the desk
- Ticket notes recording decisions, reasons and the name of the coordinator who made each call.
- Plate sheets naming bays, entries and the reason each entry sits where it does.
- Schedules recording which nodes go live, which go quiet and who is on call.
- Audit logs listing links that were checked, links that were removed and the note sent to the partner.
- Test readings and signed handover sheets produced during splice sessions and handover evenings.
Information collected automatically
- Server logs recording the time of a request, the page requested and the type of browser used.
- The approximate region from which a page was requested, derived from the network address.
- Error reports produced when a page fails to load correctly.
We do not ask for identity documents, financial account numbers, health information or any other sensitive category of personal data. If such information reaches the desk by accident, it is removed from the ticket record as soon as it is noticed and the sender is asked to resend only what is needed.
4. Desk Tickets and Plate Records
A desk ticket is the core record of the link exchange. Each ticket carries two anchors, the sending page and the receiving page, along with a subject, a decision and the name of the coordinator who made it. Tickets commonly contain personal data because they name the partner contact who requested the link and record the review conversation. The desk treats a ticket as a professional record rather than a marketing list.
Plate sheets are built from tickets. They name bays, list entries and record the reason each entry sits where it does. Where a plate sheet is published on a partner website, the published version contains only the business details that the partner has chosen to make public. Internal sheets, which may carry coordinator notes, stay on desk systems and are not published.
Schedules and audit logs are working documents. They name the nodes involved and, where relevant, the person on call. They are shared with partners who are party to the week they describe, and are otherwise kept internal. A partner can ask for a copy of any schedule or audit log that mentions their own network, and the request is normally answered within one desk day.
5. Technical and Access Data
Our servers record basic access data whenever a page is requested. This data typically includes the date and time of the request, the address of the page, the referring page where one exists, the browser type and version, and the network address of the requesting device. The desk uses this data to keep pages available, to investigate faults and to understand which parts of the website are used, and it does not combine it with the ticket records described above.
Access data is kept in an aggregated or shortened form where it is used for statistics, so that the number of visits to a page can be counted without retaining a full network address. Full addresses are retained only where necessary for security investigation, such as diagnosing a repeated attack on a server, and are discarded once the investigation closes.
We do not use access data to identify individual visitors for marketing, and we do not build advertising profiles from it. The website does not embed third party advertising networks, tracking pixels or social media buttons that would follow a reader from page to page.
6. Why We Use Information
We use information for the purposes that the desk actually needs in order to operate. Each purpose below describes a normal working use rather than a speculative one, and each is limited to the records that the purpose requires.
- To open, review and close link exchange tickets, including reading the pages involved and recording a decision.
- To build plate sheets and maintain the shelves that partners publish.
- To plan uplink weeks and assign on-call engineers.
- To run audits and remove links that no longer meet the stated subject or no longer belong to the named partner.
- To schedule splice bay sessions and handover evenings, and to confirm attendance.
- To answer questions sent to the contact form, by email or by telephone.
- To issue invoices and keep the accounting records that the law requires.
- To protect the website and the desk systems against misuse, fraud and technical faults.
- To send occasional notes about the desk to partners who have asked to receive them.
We do not sell personal data, and we do not rent lists of partner contacts. Where a partner asks us to introduce them to another partner, we ask both sides before sharing contact details, and a refusal from either side ends the matter.
7. Lawful Basis for Processing
Where Singapore law requires a lawful basis, the desk relies on one of the following. Consent is used for optional messages about the desk and for any introduction between partners. Contract is used for the work of reviewing tickets, building plates and running splice sessions, because those steps are how the service is delivered. Legitimate interest is used for security monitoring, fault diagnosis and keeping the shelf accurate, because both the desk and its partners benefit from records that are correct and systems that work. Legal obligation is used for accounting, tax and record keeping duties that apply to the company.
Where consent is the basis, it can be withdrawn at any time. Withdrawing consent stops future use for that purpose but does not affect work already completed. If a partner withdraws consent for optional messages, the ticket record and the shelf entry remain in place, because those are part of the service rather than a marketing activity.
We do not rely on automated decision making to accept or reject a link. Every decision is made by a coordinator who records a reason, and a partner who disagrees can ask for a second review by a different member of the desk.
8. Sharing With Partners and Others
Some sharing is built into the idea of a link exchange. When a connection goes live, the two partners involved can see that the connection exists, because each side publishes a link to the other. Beyond that public fact, we share only what is needed for the task at hand.
- Plate sheets that a partner asks to publish contain only the business details that the partner has approved.
- Schedules are shared with the partners covered by the week they describe.
- Handover sheets are signed by both sides and a copy is given to the partner.
- Where a dispute arises, we may share the relevant ticket notes with both parties so that the record can be examined together.
- We may disclose information where required by law, court order or a lawful request from a public authority in Singapore.
- If the business is reorganised, merged or transferred, records may move to the successor organisation, which remains bound by this policy.
We do not share partner contact lists with third parties for their own marketing, and we do not publish coordinator notes. If a partner asks us to keep a specific detail confidential, we note that on the ticket and honour it in every copy of the sheet that leaves the desk.
9. Service Providers
The desk uses a small number of service providers to run the website and the records behind it. These include a hosting provider, an email provider, an accounting service and a provider that monitors the availability of pages. Each provider receives only the data needed for its function, and each is bound by a contract that requires it to protect the data and to use it only for the service provided.
Access data and server logs are held by the hosting provider for a limited period before deletion under that provider own retention terms. Email sent to admin@nmkglobal.lol passes through the email provider and is subject to that provider security measures. Accounting records are kept by the accounting service for the period that tax and company law require.
We review our providers at least once a year, and we replace any provider that cannot show adequate security practices. A partner who wants to know which providers process data related to their ticket can ask, and the request will be answered within one desk day.
10. Cookies and Local Storage
The website uses a minimal amount of browser storage. A small preference may be stored locally so that a menu state or a dismissed notice is remembered during a visit. This storage does not identify a person and is not shared with anyone. Pages that simply display information, such as the home page and the legal pages, do not set advertising cookies or tracking cookies at all.
If the desk later adds a feature that requires a cookie, this policy will be updated before the feature goes live and a notice will appear on the page that sets it. Readers can clear stored preferences at any time through their browser settings, and clearing them does not affect access to any page.
We do not run third party analytics that profile visitors across websites. Any counting of page requests happens on our own server and is described in the technical data section above.
11. How Long We Keep Records
Records are kept for as long as they serve a working purpose, and then removed or reduced to an aggregated form. The following periods describe the ordinary practice of the desk. A record may be kept longer where it is needed for a dispute, an audit or a legal obligation, and in that case the reason is noted on the file.
- Open tickets are kept for the life of the connection they describe.
- Closed tickets are kept for three years after the connection ends, so that history can be read if a partner returns.
- Plate sheets are kept for the life of the plate, and one previous version is retained when a plate is rebuilt.
- Schedules are kept for two years.
- Audit logs are kept for three years.
- Handover sheets are kept for five years.
- Server access logs are kept for a short period and then deleted or aggregated.
- Accounting records are kept for the period required by Singapore tax and company law.
When a retention period ends, the record is deleted or reduced so that individuals can no longer be identified from it. Deletion includes removal from backups on the normal backup rotation. A partner who asks for an earlier deletion will be accommodated where there is no legal obligation or open dispute that requires the record to stay.
12. Security of Records
The desk treats records as property that belongs partly to the partners who generated them. Access to ticket systems is limited to coordinators and engineers who need the record for current work, and each person has an individual account so that actions can be traced. Accounts are removed promptly when a person leaves the desk.
Records are transmitted over encrypted connections and stored on servers that require authentication. Backups are taken regularly and tested so that a lost record can be restored. Physical records, including signed handover sheets, are kept in locked storage at the Sim Lim Tower office and are retrieved only during desk hours.
If a security incident affects personal data, we investigate promptly, take steps to contain it, and notify affected partners without undue delay. Where the law requires notification to a regulator, we make that notification within the required period. We do not hide incidents to protect reputation, because a record kept on trust is worth less than a record kept honestly.
13. Your Rights and Choices
Subject to local law, you have the right to know what personal data we hold about you, to ask for a copy, to ask for corrections, and to ask for deletion where the record is no longer needed. You also have the right to object to a use of your data that is based on legitimate interest, and to withdraw consent where consent is the basis.
To use any of these rights, write to admin@nmkglobal.lol with enough detail to locate the record, such as the ticket name, the page address or the date of a visit. We may ask for a reasonable verification of identity so that we do not hand records to the wrong person. Requests are answered within thirty days, and usually much sooner.
There is no charge for a first request. Where a request is clearly unfounded or repetitive, we may explain why and, in limited circumstances permitted by law, decline it. If we decline, we tell you the reason and the route to complain.
14. Access and Correction Requests
An access request asks what we hold. A correction request asks us to fix something that is wrong. Both are handled by the coordinator who owns the ticket where one exists, or by the desk lead where the request spans several tickets. The response lists the categories of data held, the purpose of each, and the partners or providers with whom it has been shared.
Corrections are made on the live record and, where the record has been shared, notice is sent to the recipients who still hold a copy. If a correction affects a published plate sheet, the plate is rebuilt and the new sheet replaces the old one. If a correction affects a signed handover sheet, a dated amendment is attached rather than the original being altered, so that the history of the record remains visible.
If we decide that a correction is not warranted because the record is accurate, we explain the reason in writing and record the disagreement on the file. You may then ask for a second review by a different member of the desk before the matter is closed.
15. Privacy for Children
The desk serves businesses and professional networks, and its website is not directed at children. We do not knowingly collect personal data from anyone under the age of eighteen. If a message reaches us that appears to come from a young person, we do not open a ticket and we remove the message once it has been answered with a short note explaining that the desk works with organisations.
A parent or guardian who believes that a child has sent personal data to the desk can write to admin@nmkglobal.lol and ask for it to be removed. We will locate the message, delete it from the ticket system and confirm the deletion in writing. Where a copy has already been shared with a partner, we ask the partner to delete it as well and record the request.
Because the desk does not run accounts for individuals, there is no profile to close and no password to reset. The only record is the message itself, and its removal is a simple matter once it has been identified.
16. International Transfers
The desk operates from Singapore, and its records are normally held within Singapore. Some service providers store data in other countries, and when that happens we require the provider to protect the data to a standard comparable to the one described in this policy. This may include contractual clauses, regional storage options or provider certifications.
Partners who work across borders should note that a link exchange by its nature publishes a business fact in more than one place. A published plate sheet can be read anywhere in the world, and a reader who follows a link leaves our systems altogether. The transfer of public business details is inherent in the service, while private ticket notes and coordinator records are not published and are transferred only for the purposes described above.
If you object to a transfer of your data to a particular country, tell us and we will explain whether the transfer can be avoided. In some cases an alternative provider can be used; in others the nature of the service makes the transfer unavoidable, and we will say so plainly rather than quietly proceeding.
17. Messages About the Desk
We send occasional notes about the desk to partners who have asked to receive them. These notes describe new bays, upcoming splice windows and changes to the audit cycle. They are sent from admin@nmkglobal.lol and always include a way to stop receiving them. Stopping is immediate and does not affect the service you receive on an open ticket.
We do not send promotional messages to addresses collected only through a ticket unless the partner has opted in. A ticket reply is a service message and is sent because the ticket requires an answer, regardless of any marketing preference. Service messages continue for as long as the ticket is open, because they carry the record of the work.
If you receive a message that appears to come from the desk but is unexpected, do not click any link in it. Report it to admin@nmkglobal.lol and the desk will confirm whether it was genuine. We never ask for passwords or payment details by email.
18. Links to Other Websites
The website and the plate sheets it describes contain links to partner websites and to other organisations. Those links exist because a link exchange is built on them, and they are checked during audits for availability and subject fit. We do not, however, control the privacy practices of the sites we link to, and a reader who follows a link is subject to the notice published by that site.
If a partner site changes ownership or adopts a privacy practice that seems inconsistent with the stated subject of the link, the audit will flag it and the link may be removed. Partners who notice a problem with a linked site are invited to report it so that the shelf can be corrected sooner than the next scheduled audit.
A link on our pages does not imply endorsement of everything a destination site does. It means that the page was reviewed and found to fit the bay at the time of review.
19. Changes to This Policy
This policy is reviewed at least once a year and whenever the desk changes a routine or a supplier. The revised version is published on this page with a new effective date. If the change is material, partners with an open ticket receive a short note by email before the new version takes effect, and the note explains what has changed and what it means for them.
Previous versions are kept for three years and can be supplied on request, so that a partner can see what applied when a particular record was created. If you are reading this page some time after the effective date, it may be worth checking whether a newer version exists, and the page will always show the current date at the top.
Continuing to use the desk after a revised policy takes effect means that the revised policy applies to future work. It does not retrospectively change the handling of a record created under an earlier version, unless the law requires otherwise.
20. Questions and Complaints
If you have a question about this policy, write to admin@nmkglobal.lol with the word privacy in the subject line. A coordinator will reply within one desk day. If you are not satisfied with the reply, ask for the matter to be escalated to the desk lead, who will review the file and respond in writing within ten working days.
You can also telephone the office at +14068366779 during business hours, Monday to Friday from 09:00 to 18:00 Singapore time, or write to NMK GLOBAL LINKS PTE. LTD. at 10 Jalan Besar #13-04 Sim Lim Tower 208787, Singapore (SG). Please include a return address and a short description of the issue so that the letter can be routed correctly.
If a complaint cannot be resolved with the desk, you may raise it with the relevant data protection authority in your jurisdiction. We would rather resolve it with you first, and we will cooperate openly with any authority that examines the handling of a record.