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.
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 firstname.lastname@example.org or to the address below.
4.3 OEL will comply with an individual’s request to correct their personal data as soon as practicable.
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 email@example.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.
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 OEL takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
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 firstname.lastname@example.org 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
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 PDPA.
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
14. DNC Registry
14.1 OEL complies with all provisions regarding the DNC Registry under the PDPA.
15. Other Important Information
Attn: OEL Data Protection Officer
OEL (Holdings) Limited (Reg. No: 198403368H)
8 Temasek Boulevard, #23-02 Suntec Tower 3
16. Effect of policy and changes to policy
16.2 We may revise this Policy from time to time without any prior notice. You may determine if any such revision 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.