1. What information do we collect about you?
- 1.1. We may collect and process the following data about you (“your information”):
- 1.1.1. information you provide when you register as a member of Milieu’s survey panel (the “Milieu Panel”). Information may include, but is not limited to, your name, postal address, email address and telephone number;
- 1.1.2. information you submit online when using our Platforms. This may include information relating to your opinions, attitudes, experiences and use of certain products or services;
- 1.1.3. information collected when you access your social media content via any of our Platforms;
- 1.1.4. any correspondence you send to us;
- 1.1.5. information you post on any of our Platforms;
- 1.1.6. details of your visits to any of our Platforms (and third-party services which link to our Platforms) and the resources that you access (which may include, amongst other things, traffic data and communication data);
- 1.1.7. details of transactions you carry out or orders you place through Milieu’s survey mobile application; and
- 1.1.8. all other relevant information, including your bank account details (if you win a prize draw or are entitled to receive an incentive from us).
- 1.2. We are aware that your information may be confidential and we will protect the confidentiality of your information in accordance with our normal procedures (please see section 7 headed “How do we keep your information secure”) and legal requirements.
- 1.3. We will process your information in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and the ICC/ESOMAR International Code.
2. How will we use your information?
- 2.1. Milieu is engaged in the business of consumer market, opinion and social research, so as to acquire and process such information. We use your information in the following ways:
- 2.1.1. to provide services to our clients (please see section 6 headed “Who do we share your information with”);
- 2.1.2. to analyse the data for research purposes and to incorporate it into our databases for research and analysis purposes;
- 2.1.3. to ensure that content on our Platforms is presented as effectively as possible;
- 2.1.4. to deal with any complaints, queries or technical problems you experience;
- 2.1.5. for our internal purposes, such as quality control, system administration and to evaluate the use of our Platforms and their performances, so that we can provide you with enhanced services and a better experience;
- 2.1.6. to notify you about changes to our Platforms or changes which may affect your use of our Platforms;
- 2.1.7. to provide you with information, products or services that you request from us, or which we feel may interest you;
- 2.1.8. to provide you with Milieu’s research results;
- 2.1.9. to create reports to assist with future marketing;
- 2.1.10. to send you invitations to participate on our Platforms , and to update you on issues relating to those activities;
- 2.1.11. to notify you if you win one of our prize draws (this information will also be published on our Platforms); and
- 2.1.12. to enable us to issue prizes, payments or rewards to you.
- 2.2. We may collect device information from your use of our Platforms, including, but not limited to, your email address, IP address, operating system, browser type, mobile phone number and unique device ID. This data reflects our users’ browsing actions and patterns and does not identify any individuals.
- 2.3. We may use the information we have to show you relevant advertisements on and off our Platforms and measure the effectiveness and reach of such advertisements and services. Non-personal information such as IP address, unique device ID, and browser and operating system type and version may also be used by our partners, such as online marketers and advertisers, to deliver relevant and specific marketing messages or adverts, or for the delivery of content to online users.
- 3.2. A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it.
- 3.3. Cookies are an extremely useful technology and do lots of different jobs. We use various types of cookies (including some that we place and others which we permit third parties to place on our site) for a number of purposes, including to provide you with a better browsing experience.
- 3.4. If for any reason you do not want us to track your use of our Platforms using cookies, you can opt out of this by using your browser settings.
- 3.5. In the future, we may utilise passive tracking mechanisms in the form of cookies to collect information regarding your online activities. We will seek your express permission before enabling such tracking.
- 4.1. By becoming a member of the Milieu Panel, you agree to allow us to communicate with you via mobile application notifications, email, SMS or any other means in relation to your Milieu Panel membership and opportunities to participate in any related activities.
5. Where do we transfer your information to?
- 5.1. Your information may be accessed and processed by Milieu’s staff, service providers, affiliates or agents located in any of our offices around the world, including Singapore.
- 5.2. We will take measures to ensure that when transferring any personal information outside of Singapore, a comparable level of protection to that under PDPA will be provided by any foreign recipient entity. Please do not send us your information if you do not agree to it being transferred outside Singapore (or your home country) in this way. By providing your information to us, you agree and consent to us transferring to, and storing your information, in any of our offices around the world. If you do not agree to this, then you please cease your use of our Platforms.
6. Who do we share your information with?
- 6.1. We may share your information with any of Milieu’s staff, service providers, affiliates or agents for internal reporting purposes.
- 6.2. We may share your information with other organisations:
- 6.2.1. who provide services to us that we request. This might include IT service providers who support our IT systems, for example; and
- 6.2.2. whom we provide services to so that they can benefit from our services.
- 220.127.116.11. Your information will be summarized as aggregate statistical information, and will not be used in a manner enabling personal identification of an individual. However, while we will take reasonable steps to ensure that you cannot be identified from that information, as we cannot ever fully understand what information our clients may already hold about you, it may be that they can link the anonymous information that we provide to other information, which then enables them to identify you. By way of example:
- 18.104.22.168. if you have given us your Twitter username, we may share tweets posted by you and your followers to third parties and, while we will not disclose your Twitter handle, it may be that either (a) information contained within those feeds alone could identify you or a third party or (b) those tweets could be linked with other information the third party already holds which then enables them to identify you or someone else; or
- 22.214.171.124. we may exchange what we consider to be anonymous or pseudonymised information about our panelists with third parties who will use it for analysis purposes, to enhance their own databases, to model audiences and track the efficiency of campaigns, and to gain an insight into behaviours so that they can develop strategies which add value to their, or their clients’, businesses. For this purpose, we may also collect anonymised information from third parties which we may use to identify you. As our clients and, in turn their clients, will have their own databases and other sources of information, it may be that they could link the anonymous information we provide with information they already have and therefore identify you; or
- 126.96.36.199. we may provide limited personal details to trusted third-party data processors for the purposes of combining our data with other third-party data sources. The final combined data set will be anonymised and non-attributable.
- 6.2.3. if we sell or buy any business or assets (as we may share your data with the prospective seller or buyer);
- 6.2.4. if we or substantially all of our assets are acquired by another party, in which case your information will be one of the transferred assets; or
- 6.3. Other than as listed above, we will not rent, sell or otherwise disclose your information without your consent, subject to the following circumstances:
- 6.3.1. if we have to share your information to comply with legal or regulatory requirements (or we reasonably believe that we need to disclose your information for such purposes), or where it is necessary to prevent potential threats to the life, health and physical safety of any person.
- 6.4. Please bear in mind that whenever you voluntarily disclose personal data online (for example on message boards, on a blog or chat area), that information could be viewed, collected or used by others. We are not responsible for any content you choose to submit or make public, including personal information.
7. How do we keep your information secure?
- 7.1. All your information is stored on secure servers that are owned or leased by Milieu. Once we have received your information, we will take reasonable and appropriate security measures to prevent unauthorised access, destruction, misuse, manipulation or disclosure. We will attempt to improve and revise these security measures periodically.
- 7.3. Unfortunately, the transmission of information via the Internet is not completely secure. While we will take reasonable and appropriate security measures, we cannot guarantee the security of your information when being transmitted to our Platforms, and any transmission is at your own risk.
8. Your Rights
- 8.1. Subject to certain circumstances, you have the right to access or withdraw consent for processing your personal information. Please note that a reasonable fee may be payable to meet our costs in providing you with details of the information we hold about you upon receiving an access request. It is also important to note that, while you can request your information at any time, we continuously ask our Milieu Panel members to update information about themselves and so there will be opportunities to review your details throughout the year.
8.2 You have the right to change your information (correction, addition or deletion of contents).
- 8.3 You should direct any request for your information to us at firstname.lastname@example.org. Milieu will expeditiously respond to all reasonable requests for access to personal data, notification of purpose of use or disclosure of your information.
9. Inquiries and complaints
- 9.1.1. E-Mail: email@example.com
- 9.1.2. Postal Address: Milieu Insight Pte. Ltd., 20 Cairnhill Road, Singapore 229652.