1. INTRODUCTION
1.1. We take our responsibilities in relation to protecting your personal data and compliance with the personal data Protection Act 2012 (“PDPA”) seriously. We are committed to properly managing, protecting and processing your personal data in accordance with this Policy, which shall apply to all personal data we collect from you through our Platforms.
1.2. The purpose of the PDPA is to govern the collection, use and disclosure of personal data by organisations in a manner that recognises both the right of individuals to protect their personal data and the need for organisations to collect, use or disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances.
1.3. Please read and review this Policy, which will inform you how we collect, use, process and disclose your personal data. We may also collect and process your personal data under any exceptions to Applicable Laws, which are not set out in this Policy
1.4. For the purpose of this Policy,
1.4.1. “Platforms” means collectively our Website and our pages and accounts on third party social media platforms such as Instagram, Facebook, Pinterest, Tiktok, Twitter, Youtube;
1.4.2. “we”, “us” or “our”, unless otherwise indicated, means Miles Nixon Media Pte Ltd;
1.4.3. “Website” means the website accessed at the address www.CherylMiles.com
1.5. By (1) browsing our Website, or (2) ordering any of our products and services, or (3) providing us with personal data, you are agreeing to the terms of this Policy.
1.6. We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.
2. What is personal data?
2.1. Personal data is personal information, whether true or not and whether in electronic or other form, about an individual who can be identified:
2.1.1. from the types of data, we collect may include, but is not limited to:
- Full name
- Mobile or residential telephone number
- Personal email address
- Residential address
- Nationality
- Date of Birth
2.1.2. from that data and other information to which we have access to or are likely to have access to.
3. When is personal data collected from you?
3.1. We collect personal data from you when:
3.1.1. you use any of our related services, such as subscribing to our newsletter, product notifications;
3.1.2. you purchase any of our products or services on our Website;
3.1.3. you interact with our customer experience team or other representatives, for example, via our webform, emails, telephone calls, letters, or face-to-face meetings;
3.1.4. you interact with us on our Platforms, such as liking our posts, commenting on our posts, private messaging us on our social media pages and accounts;
3.1.5. you browse our products and services or otherwise interact with our Platforms;
3.1.6. you accept our cookies on your device;
3.1.7. your authorized representative submits your personal data to us for any purpose reasonably authorized by you, for example if such representative is purchasing our product or service to be delivered to you or as a gift;
3.1.8. you participate in our promotions, lucky draws, contests, initiatives or any request for additional personal data such as customer surveys;
3.1.9. we receive references from business partners and third parties, for example, where they referred you to us to enjoy the benefits of a joint promotion or collaboration or to redeem a voucher you purchased through them;
3.1.10. our third-party analytics and other service providers provide your personal data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
3.1.11. when you voluntarily submit your personal data to us for any reason.
3.2. We do not collect your credit card details, whether to process your payment or for customer service purposes. Your credit card details are collected, processed and stored directly by our third-party payment processors pursuant to their terms of use and privacy policies. None of your credit card details are stored with us.
3.3. We may also collect your personal data in circumstances where such collection does not require consent under the applicable laws.
3.4. If you provide us with personal data relating to a third party by submitting such personal data to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes and that the third party agrees to be bound by the terms of this Policy.
3.5. Please ensure that the personal data that you provide is accurate. We encourage you to update us of any change in your personal particulars as soon as possible. Failure to do so may result in our inability to provide you with the products and services you have requested.
4. How will your personal data be used?
4.1. We may use and disclose your personal data (a) for purposes which are reasonably to provide you with our products and services, (b) where we have obtained and maintain related consent, and/or (b) in circumstances where such use does not require consent under applicable laws, including to:
4.1.1. process your order for our products or services, process or collect your payment for the order;
4.1.2. deliver or perform the products or services you purchased, including our couriers calling or messaging you to obtain your delivery instructions;
4.1.3. communicate with you in relation to (i) your queries, orders, requests and feedback, and (ii) material changes to our Website;
4.1.4. send you marketing communications in relation to our sales, products, services, promotions or the Platforms;
4.1.5. send you marketing communications in relation to the sales, products, services or promotions of business partners, including promotional mail together with your order;
4.1.6. process your participation in our promotions, lucky draws, initiatives or any request for additional personal data such as customer surveys;
4.1.7. conduct market and customer research, analysis or tracking;
4.1.8. promote our products and services on our Platforms;
4.1.9. personalise and improve your customer experience when you visit the Website;
4.1.10. deliver ads which are related to our products and services which may be of interest to you on the Platforms;
4.1.11. enable businesses to deliver ads on the Platform which are related to their products and services which may be of interest to you;
4.1.12. comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law;
4.1.13. ensure our Website functions properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website;
4.1.14. improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
4.1.15. any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;
(collectively, the “Purposes“)
5. Who will your personal data be shared with?
5.1. In relation to our use of your personal data, we may disclose your personal data to our:
5.1.1. payment processors, who process your payment on the Website and the Apps;
5.1.2. logistics providers, such as courier services which will deliver your order to you;
5.1.3. business partners or vendors in connection with the processing of any promotion, event or service organised by us;
5.1.4. agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your personal data; and
5.1.5. any other party whom you authorize us to disclose your personal data to.
5.2. We may also disclose your personal data (a) for other purposes which are reasonably related to the Purposes or (b) in circumstances where such disclosure does not require consent under the applicable laws.
6. How do I withdraw my consent?
6.1. If you wish to withdraw your consent for us to send you sales, marketing or promotional information by email, you may click on the “unsubscribe” button or link in our marketing emails.
6.2. If you wish to withdraw your consent for the collection, use and/or disclose of your personal data for other Purposes. You may do so by submitting a written request to the email address listed at Section 12 below. Within a reasonable time after we receive the notice of withdrawal of your consent, we will inform you of the consequences of your withdrawal of consent and when it will take effect.
7. How do I get access to or correct my personal data?
7.1. You may request to access or correct your personal data which we have collected and stored at any time by submitting a written request to the email address listed at Section 12 below. We will respond to your request as soon as possible and, at the latest, within 30 days of receipt of your request. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide or correct the information.
7.2. We may charge a reasonable fee for handling your request to access your personal data. Your right to view your personal data is limited to your personal data only. We are not permitted to reveal any personal data about any other individual to you. We reserve the right to refuse access to your personal data if it will reveal or lead to the revelation of another individual’s personal data, cause harm to you or another individual or is contrary to the national interest.
8. Is my personal data secure?
8.1. We put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your personal data. However, we will not be responsible for any unauthorized use of personal data by third parties which is attributable to factors beyond our control.
8.2. If personal data is transferred out of Singapore, we will comply with the applicable laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under applicable laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the personal data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.
9. How long do you retain my personal data?
9.1. When personal data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such personal data is either destroyed or anonymised.
10. Third-party cookies
10.1. We use the services of third-party vendors, who may implement cookies on our Website. Advertisements on our Website may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including personal data, collected by such third-party cookies are subject to the privacy and data protections policies of the third-party vendors and are not under our control.
10.2. You may reject third-party cookies through the settings on your browser. However, this may result in the loss of the Website functionality, restrict your use of our Website, or delay or affect the way in which our Website operates.
11. Google Analytics
11.1. We may use Google Analytics features, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.
11.2. We work with third-party vendors, including Google, to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) to inform, optimize, and serve ads based on visitors’ past visits to our Website, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Website.
12. Who can I contact about my personal data or this policy?
12.1. If you have any queries or doubts about the policies set out in this statement or about your personal data that we obtain, maintain, process, use and disclose or if you would like to access or correct your personal data, you may contact our Data Protection Officer at admin @ cherylmiles.com (without spaces).
12.2. For more information about the PDPA, please visit personal data Protection Commission’s website at http://pdpc.gov.sg.
13. Governing law
13.1. This Policy and your use of this Website shall be governed in all respects by the laws of Singapore.
14. Updates on privacy policy
14.1. We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.
14.2. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Website. Any amended Policy will be posted on our website. By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.
14.3. You are encouraged to visit our Website from time to time to ensure that you are well-informed of our latest policies in relation to personal data protection.
