OEL (Holdings) Limited (Reg No:198403368H) and its subsidiaries (collectively “OEL”, the “Company” , “we”, “us”
or “our”) respects an individual’s right to privacy and has based its privacy policy in accordance with the Personal
Data Protection Act 2012 (“PDPA”).

This Data Protection Policy (“Policy”) sets out the basis upon which the Company may collect, use, disclose or
otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). This Policy
applies to personal data in our possession or under our control, including personal data in the possession of
organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

1. Application of this Policy
1.1 This policy:
a) sets out the principles OEL follows when collecting, using, disclosing, retaining, and removing personal
data; and
b) describes other important topics relating to an individual’s privacy.
1.2 By purchasing goods from OEL, communicating with OEL through email, by telephone, in writing or by
using any of OEL’s other services, including the OEL website, or by providing personal data to us, you agree to
the collection, use and disclosure of your personal data in the manner described in this policy.
2. Collection Use and Storage of Personal Data
2.1 The type of personal data that OEL may collect from individuals will depend upon the particular
transaction and the dealing. Normally the personal data collected by OEL may include an individual’s:
a) name or alias, gender, date of birth, nationality, country and city of birth;
b) mailing address, email address, telephone numbers and other contact details;
c) personal identification and/or passport number;
d) records of communications with OEL;
e) responses to market surveys and contests conducted by OEL or on OEL’s behalf;
f) credit card or debit card information;
g) camera or video footage that identifies individuals (including CCTV footage);
h) website usage information.
2.2 OEL only collects, uses, and discloses personal data with an individual’s consent or deemed consent or
as otherwise permitted under the PDPA or other applicable laws and regulations. The Company processes
personal data about individuals such as its personnel (past and present), client contacts, supplier contacts,
website users, and shareholders. The Company will generally process such personal data for a number of
business purposes, including but not limited to:
a) Provide services, customer support and responding to the User’s requests;
b) to enable OEL ’s subcontractors, third-party agents and service providers, to fulfil obligations/services
as stipulated in contracts with OEL ;
c) feedback after a sale of a product or service;
d) sending service updates, promotional offers and other forms of communications;
e) resolving any problems or disputes encountered in relation to our products and services;
f) marketing, publicity and business development purposes;
g) complying with legal and regulatory obligations and requirements;
h) enforcing obligations owed to the OEL Group;

i) accounting, risk management, compliance and record keeping purposes;
j) government and other regulatory reporting;
k) recruitment, including evaluation of an individual for suitability of employment;
l) employee management and administration (including payroll and leave);
m) for security and access controls, safety surveillance and monitoring purposes;
n) staff training.
2.3 The purposes listed in the above clauses may continue to apply even in situations where your
relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a
reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any
contract with you).
2.4 OEL takes reasonable steps to ensure the individual is aware of:
a) conducting, improving, maintaining, and developing a business relationship.
b) processing, servicing or enforcing transactions and sending related communications;
c) identification and verification purposes in connection with any of the services or products that may be
supplied to individuals;
d) responding to individual’s queries;
e) administering contests or market surveys conducted by OEL or on OEL’s behalf
f) marketing (such as providing individuals with information about our products and promotional notices
and offers); and
g) improving the OEL’s website.
h) the likely use of the information;
i) the means of requesting OEL on the provision of personal data that is in the possession of OEL;
j) the means of withdrawing any consent in respect of the collection, use or disclosure of the personal
data that is in the possession of OEL;
k) the identity and contact details of the organisation;
l) any law requiring collection of the information; and
m) the main consequences of failure to provide the information.
3. How OEL will disclose your Personal Data?
3.1 OEL discloses personal data:
a) for the primary purpose for which it was collected; or
b) for purposes that a reasonable person will consider appropriate in the circumstances; or
c) where the individual has consented; or
d) for direct marketing by OEL where consent has been given but giving individuals the opportunity to opt
out of such direct marketing. OEL includes its contact details in any direct marketing; or
e) where permitted under the PDPA or other applicable law or if required by law.
3.2 OEL does not disclose your personal data for any secondary purposes unless your consent has been
given or if so permitted or required under the PDPA or other applicable laws and regulations.

4.4 If OEL disagrees with any request to correct an individual’s personal data on reasonable grounds, OEL
shall annotate the personal data with the correction that was requested but not made.
5. Withdrawal of Consent
5.1 An individual may withdraw his consent for the collection, use or disclosure of personal data by giving
OEL reasonable notice by sending a written request (a) by email to the Data Protection Officer at
dpo@ohldg.com or (b) to the address below. OEL shall inform the individual of the likely consequences of the
withdrawal of the consent. OEL will cease to collect, use or disclose the personal data upon such withdrawal
unless otherwise permitted or required by the PDPA or other applicable laws and regulations.

5.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time
(depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal
consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within thirty (30) days of receiving it.

5.3 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose
personal data where such collection, use and disclose without consent is permitted or required under applicable
laws.

6. Using our Website
6.1 As with most websites, when you visit the OEL website or use an application on the OEL website, OEL
may record anonymous information such as IP address (where not used to identify a specific individual), time,
date, referring URL, pages accessed and documents downloaded, type of browser and operating system.
6.2 OEL also uses “cookies”. A cookie is a small file that stays on your computer until, depending on
whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and
store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled, you
may still use the OEL website but may be limited in the use of some of the features.
6.3 The OEL websites may contain links to or from other websites. OEL is not responsible for the privacy
practices of other websites. This privacy policy applies only to the information we collect on the OEL website. We
encourage you to read the privacy policies of other websites you link to from OEL’s website.
7. Security of your Personal Data
7.1 OEL will take reasonable steps to ensure that personal data is securely stored.
7.2 OEL protects personal data from misuse or loss by restricting access to the information in electronic
format and by appropriate physical and communications security.

7.3 Any data destroyed is disposed of in a manner that protects the privacy of personal data in an
appropriate manner.
8. Dealing with Unsolicited Information
8.1. Any unsolicited personal data that OEL receives from individuals will be assessed to determine whether
it is necessary to retain any of this data to provide the individual with any services that they have requested.

3.3 OEL will not sell or license any personal data that it collects from an individual.
3.4 There may be other situations where we may collect and use personal data, which are outside a
person’s reasonable expectation. When this occurs, OEL is committed to providing the individual with an
explanation for the possible use of the personal data when asking for the individual’s consent.
4. Accuracy and Correction of Personal Data
4.1 OEL takes steps to ensure information is accurate and up to date by updating its records whenever
changes to information come to its attention. OEL disregards information which seems, on a reasonable basis, be
inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other
information in its possession.
4.2 OEL generally relies on the information provided by you. In order to ensure that your personal data is
current, complete and accurate, please update us if there are changes to your personal data. If you would like it
corrected, please submit a written request to the Data Protection Officer at dpo@ohldg.com or to the address
below.
4.3 OEL will comply with an individual’s request to correct their personal data as soon as practicable.

12.1 We generally do not transfer your personal data to countries outside of Singapore. However, if we do
so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data
continues to receive a standard of protection that is at least comparable to that provided under the P DPA.
12.2 Any personal data provided to OEL may be transferred to, stored by or disclosed to an overseas
recipient. For example, OEL may use a server hosted overseas to store data, which may include your personal
data.
12.3 Your personal data may also be processed by employees or by other third parties operating outside of
Singapore, who work for OEL, or by the representatives and employees of OEL related companies.
12.4 OEL will take reasonable steps, in the circumstances, before your personal data is disclosed to an
overseas recipient, to ensure that the overseas recipient provide a standard of protection to personal data so
transferred that is comparable to the protection under the PDPA.
13. Sensitive Information
13.1 OEL does not collect sensitive information without the individual’s consent and unless it is specifically
relevant and necessary for OEL’s primary purposes of conducting, improving, maintaining and developing a
business relationship. All sensitive information is collected and used in accordance with this privacy policy. OEL
does not use government identifiers (e.g. tax file numbers) to identify individuals.
14. DNC Registry
14.1 OEL complies with all provisions regarding the DNC Registry under the PDPA.
15. Other Important Information
15.1 OEL welcomes your comments regarding this Privacy Policy. If you have any queries or concerns about
OEL’s privacy policy, please contact us at:

Attn: OEL Data Protection Officer
OEL (Holdings) Limited (Reg. No: 198403368H)
8 Temasek Boulevard, #23-02 Suntec Tower 3
Singapore 038988
Email: dpo@ohldg.com
16. Effect of policy and changes to policy
16.1 OEL reserves the right to modify this privacy policy at any time. A current version of this policy will be
published on OEL’s website or may be obtained free of charge upon request.
16.2 We may revise this Policy from time to time without any prior notice. You may determine if any such
revisio n has taken place by referring to the date on which this Notice was last updated. Your continued
involvement, association and participation in our business constitute your acknowledgement and acceptance of
such changes.

9. Access to Personal Data
9.1 If an individual wishes to be provided with information regarding their Personal Data that is in the
possession or under the control of OEL or the ways in which such Personal Data has been used or disclosed by
OEL in the year preceding such request, then that person needs to send a written request by email to the Data
Protection Officer at dpo@ohldg.com or to the address as detailed below. OEL will handle such requests as soon
as reasonably possible in accordance with the PDPA.
10. Retention of Personal Data
10.1 We may retain your personal data for as long as it is necessary to fulfil the purposes for which they
were collected, or as required or permitted by applicable laws.
10.2 We will cease to retain your personal data, or remove the means by which the data can be associated
with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the
personal data were collected, and are no longer necessary for legal or business purposes.
11. Anonymity when dealing with OEL
11.1 OEL allows individuals the option not to identify themselves when dealing with it, where practicable.
12. Cross Border Disclosure