DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets
out the basis which ODE CONSULTING PTE. LTD. (“we”, “us”,
or “our”) may collect, use, disclose or otherwise process personal data
of our customers in accordance with the Personal Data Protection Act (“PDPA”).
This Notice 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.
PERSONAL DATA
1. As
used in this Notice:
“customer”
means an individual who (a) has contacted us through any means to find out more
about any goods or services we provide, or (b) may, or has, entered
into a contract with us for the supply of any goods or services by us;
and
“personal data” means data, whether true
or not, about a customer who can be identified: (a) from that data; or (b) from
that data and other information to which we have or are likely to have access.
2. Depending
on the nature of your interaction with us, some examples of personal data which
we may collect from you include name, business email address, business
telephone number, nationality, gender and
employment information.
3. Other
terms used in this Notice shall have the meanings given to them in the PDPA
(where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We
generally do not collect your personal data unless (a) it is provided to us
voluntarily by you directly or via a third party who has been duly authorised
by you to disclose your personal data to us (your “authorised representative”)
after (i) you (or your authorised representative) have been notified of the
purposes for which the data is collected, and (ii) you (or your authorised
representative) have provided written consent to the collection and usage of
your personal data for those purposes, or (b) collection and use of personal
data without consent is permitted or required by the PDPA or other laws. We
shall seek your consent before collecting any additional personal data and
before using your personal data for a purpose which has not been notified to
you (except where permitted or authorised by law).
5. We
may collect and use your personal data for any or all of
the following purposes:
(a) performing
obligations in the course of or in connection with our provision of the goods
and/or services requested by you;
(b) verifying
your identity;
(c) responding
to, handling, and processing queries, requests, applications, complaints, and
feedback from you;
(d) managing
your relationship with us;
(e) processing
payment or credit transactions;
(f) sending
you on marketing information about our goods or services including notifying
you of our marketing events, initiatives and programmes, membership and other promotions;
(g) complying
with any applicable laws, regulations, codes of practice, guidelines, or rules,
or to assist in law enforcement and investigations conducted by any
governmental and/or regulatory authority;
(h) any
other purposes for which you have provided the information;
(i) transmitting
to any unaffiliated third parties including our third party
service providers and agents, and relevant governmental and/or regulatory
authorities, whether in Singapore or abroad, for the aforementioned purposes;
and
(j) any
other incidental business purposes related to or in connection with the above.
6. We
may disclose your personal data:
(a) where
such disclosure is required for performing obligations in the
course of or in connection with our provision of the goods and services
requested by you; or
(b) to
third party service providers, agents and other organisations we have engaged
to perform any of the functions with reference to the above
mentioned purposes.
7. 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
a contract with you).
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
8. In
compliance with the PDPA, we may collect, use or
disclose your personal data without your consent for the legitimate interests
of ODE Consulting® Pte. Ltd. or another person. In
relying on the legitimate interests exception
of the PDPA, ODE Consulting® Pte. Ltd. will assess
the likely adverse effects on the individual and determine that the legitimate
interests outweigh any adverse effect.
9. In
line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following
purposes:
(a) Fraud
detection and prevention;
(b) Detection
and prevention of misuse of services;
(c) Network
analysis to prevent fraud and financial crime, and perform credit analysis; and
(d) Collection
and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause 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.
WITHDRAWING YOUR CONSENT
10. The
consent that you provide for the collection, use and disclosure of your
personal data will remain valid until such time it is being withdrawn by you in
writing. You may withdraw consent and request us to stop collecting, using
and/or disclosing your personal data for any or all of
the purposes listed above by submitting your request in writing or via email to
our Data Protection Officer at the contact details provided below.
11. 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 your request within thirty (30) business days of
receiving it.
12. Whilst
we respect your decision to withdraw your consent, please note that depending
on the nature and scope of your request, we may not be in a
position to continue providing our goods or services to you and we
shall, in such circumstances, notify you before completing the processing of
your request. Should you decide to cancel your withdrawal of consent, please
inform us in writing or via email to our Data Protection Officer at the contact
details provided below.
13. 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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If
you wish to make (a) an access request for access to a copy of the personal
data which we hold about you or information about the ways in which we use or
disclose your personal data, or (b) a correction request to correct or update
any of your personal data which we hold about you, you may submit your request
in writing or via email to our Data Protection Officer at the contact details
provided below.
15. Please
note that a reasonable fee may be charged for an access request. If so, we will
inform you of the fee before processing your request.
16. We
will respond to your request as soon as reasonably possible. In general, our
response will be within thirty (30) business days. Should we not be able to
respond to your request within thirty (30) days after receiving your request,
we will inform you in writing within thirty (30) days of the time by which we
will be able to respond to your request. If we are unable to provide you
with any personal data or to make a correction requested by you, we shall
generally inform you of the reasons why we are unable to do so (except where we
are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
17. To
safeguard your personal data from unauthorised access, collection, use,
disclosure, copying, modification, disposal or similar risks, we have
introduced appropriate administrative, physical and technical measures such as
minimised collection of personal data, authentication and access controls to
facility and company’s systems (such as good password practices, need-to-basis
for data disclosure, etc.), up-to-date antivirus protection, regular patching
of software and web security measures against risks to secure access.
18. You
should be aware, however, that no method of transmission over the Internet or
method of electronic storage is completely secure. While security cannot be
guaranteed, we strive to protect the security of your information and are
constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
19. We
generally rely on personal data provided by you (or your authorised
representative). In order to ensure that your personal
data is current, complete and accurate, please update us if there are changes
to your personal data by informing our Data Protection Officer in writing
or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
20. We
may retain your personal data for as long as it is necessary to fulfil the
purpose for which it was collected, or as required or permitted by applicable
laws.
21. 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 purpose for which the
personal data was collected, and is no longer necessary for legal or business
purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
22. 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 we 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.
DATA PROTECTION OFFICER
23. You
may contact our Data Protection Officer if you have any enquiries or
feedback on our personal data protection policies and procedures, or if you
wish to make any request, in the following manner:
Name
of DPO : Ng Tzeh Huey
Contact
No. : 9126 6399
Email Address : dpo@odeconsulting.com
EFFECT OF NOTICE AND CHANGES TO NOTICE
24. This
Notice applies in conjunction with any other notices, contractual clauses and
consent clauses that apply in relation to the collection, use and disclosure of
your personal data by us.
25. We
may revise this Notice 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 use of our services
constitutes your acknowledgement and acceptance of such changes.
Effective date : 22/03/2023
Last
updated : 15/07/2023
Version 1.1