Privacy Policy

1. Information We Collect

1.1 Information You Provide

• Name, email address, company name, and job title
• Country and contact preferences
• Service inquiry details and message content
• Billing and payment information (for subscriptions)

1.2 Information Collected Automatically

• IP address and browser type
• Pages visited, referral source, and session duration
• Device type and operating system
• Cookie identifiers (see Section 7)

2. How We Use Your Information

We use the information we collect to:

• Respond to inquiries and provide services you request
• Process transactions and send related confirmations
• Send operational communications (service updates, invoices)
• Send marketing communications (with your consent, where required)
• Improve our website, products, and services
• Comply with legal obligations under Japanese and Singapore law
• Prevent fraud and maintain platform security

3. Legal Basis for Processing (PDPA / APPI)

Under Singapore's PDPA, we collect, use, and disclose personal data with your consent, where required, or under one of the legitimate exceptions (e.g., business improvement, legal obligations).

Under Japan's APPI, we handle personal information based on the specified purpose of use communicated at the time of collection and do not use it beyond that purpose without your consent.

4. How We Share Your Information

We do not sell your personal information. We may share your data with:

• Service providers who process data on our behalf (hosting, CRM, email platforms) under contractual data protection obligations
• Business partners with your explicit consent for co-delivery of services
• Legal authorities when required by law, court order, or regulatory requirement in Japan or Singapore
• Successor entities in the event of merger, acquisition, or asset transfer, with advance notice

5. International Data Transfers

TNG operates in Japan and Singapore. Your personal information may be transferred between these jurisdictions. Both countries maintain personal data protection regimes. We implement contractual safeguards for any transfers outside Japan and Singapore.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purpose for which it was collected or as required by law. Client data is retained for the duration of the service relationship plus a minimum of 7 years for legal and accounting compliance. Marketing consent records are retained until consent is withdrawn.

7. Cookies and Tracking

We use cookies and similar tracking technologies to operate our website and improve your experience. These include:

• Essential cookies: Required for site functionality
• Analytics cookies: Help us understand how visitors use the site
• Marketing cookies: Used to serve relevant advertising (with consent)

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

8. Your Rights

Depending on your location, you may have the following rights:

• Access and obtain a copy of your personal data
• Correct inaccurate or incomplete data
• Request deletion of your data (subject to legal holds)
• Withdraw consent for marketing communications
• Lodge a complaint with the relevant authority (PPC in Japan; PDPC in Singapore)

To exercise your rights, email: privacy@thenewgate.com

9. Security

We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit (TLS), access controls, and regular security reviews.

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Privacy Policy periodically. When we make material changes, we will notify you by updating the “Last Updated” date and, where appropriate, by email or prominent notice on our website.

12. Contact Us

For privacy-related inquiries or to exercise your rights: