ORAPI ASIA – Personal Data Protection Act & Online Data Privacy Policy




1. Personal Data Protection Act and Online Data Privacy Protection


The Statement set forth below outlines the Personal Data that ORAPI may collect, how ORAPI uses and safeguards that data, and with whom we may share it. This Statement is intended to provide notice to individuals regarding Personal Data in an effort to be compliant with the Personal Data Protection Act (PDPA), data privacy laws and regulations of the jurisdictions in which ORAPI operates as well as compliance with its own Data Privacy Compliance Manual.

ORAPI encourages its customers, suppliers, commercial visitors, business associates, investors and other interested parties to read this Statement. By using our website or submitting Personal Data to ORAPI by any other means, you acknowledge that you understand and agree to be bound by this Statement, and agree that ORAPI may collect, process, transfer, use and disclose your Personal Data as described in this Statement.

2. General Data Privacy Principles


ORAPI is committed to the goal of adhering to these Privacy Principles in all processing of Personal Data.

Notice
: ORAPI will notify individuals at the time of collection of data, or a reasonable time thereafter based on the laws and regulations of the relevant jurisdiction, the purposes for which it is collecting and using information about them. This notice shall include information about who can be contacted about inquiries or concerns, the type of third parties that the information may be disclosed to, and choices available for use and disclosure of that data.

Choice: ORAPI provides all individuals the opportunity to opt out of information disclosure to a Third Party not provided in initial notice or use in a manner not provided in initial notice. If the information is considered Sensitive Personal Data as defined by the Government, ORAPI assumes the Data Subject has opted out of having such information disclosed to Third Parties, and a Data Subject must expressly opt in to consent such disclosure.

Onward Transfer (Transfer to Third Parties): The Notice and Choice Principles defined in these principles shall be applied to all onward transfers of personal data. ORAPI will not transfer Personal Data to a Third Party without notice unless one of the following applies:
• ORAPI can ensure the Third Party is in compliance with the Personal Data Protection Act(PDPA) and/or Privacy Shield Principles;
• The Third Party is subject to the PDPA and/or EU Data Protection Directive;
• The Third Party has certified via agreement that it provides a level of protection equivalent to the PDPA and/or Privacy Shield Principles.

Access: ORAPI provides Data Subjects access to their Personal Data and opportunity to correct, amend, or delete that Personal Data when inaccurate, except in certain circumstances allowed in the Privacy Shield Principles.

Security: ORAPI takes reasonable precautions to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, and destruction.

Data Integrity: ORAPI only holds information relevant for the purpose for which it is to be used, as described in this Statement. ORAPI takes reasonable steps to ensure that information is reliable for its intended use, accurate, complete, or current.

Enforcement: ORAPI provides recourse mechanisms to resolve individual concerns or disputes regarding Personal Data. ORAPI provides the procedures as outlined in this Statement for providing verification to individuals that PDPA 2012 and/or Privacy Shield Principles have been implemented. ORAPI is committed to providing a prompt remedy for any failure to comply with the PDPA 2012 and/or Privacy Shield Principles, the laws or regulations of other jurisdictions, and/or its own privacy policies and procedures.

3. How We Collect Your Personal Data


The PDPA defines personal data as “data, whether true or not, about an individual who can be identified
a.) from that data; or
b.) from that data and other information to which the organisation has or is likely to have access.”
c.) We collect the personal data through the following methods/channels:
• When you make payment
• When you respond to a marketing call for new product or service
• When you call in to request for information or enquiry
• When you submit an application form
• When you request for technical support
• When you wish to preview a product or service
• When you send in your job application form
• When you sign in as a visitor
• When you register as a participant
• When you indicate you wish to have follow-up from salesperson
• When you sign up for a service
• When you leave your contact details
• When you respond to a marketing call
• When you agree to a site survey

4. Personal Data


ORAPI is committed to maintaining all reasonable precautions to assure the privacy and security of Personal Data gathered by ORAPI. During your use of our website or through other communications with ORAPI, Personal Data may be collected and processed by ORAPI. In general, ORAPI collects personal contact information (e.g. name, company, address, telephone number and e-mail address), which you knowingly provide either by registration, survey, answering questions or otherwise for use in our commercial relationship. At times we may collect additional Personal Data that you voluntarily provide, including, but not limited to, job title, additional contact information, date of birth, hobbies, areas of interest, and professional affiliations.

4a. Types of Personal Data We Collect About You
The types of personal data we collect about you may include:
• Academic History
• Criminal Background/Past Offences
• Education & Professional Qualifications
• Employment Details & History
• Family Background & Details
• Medical Details/Health Information
• Personal Contact Information
• Personal Details
• Photos & Video Footage
• Purchase Information/History
• Customer Feedback
• Site Survey Information

4b. Use of Personal Data
ORAPI’s website is intended to be used by ORAPI customers, commercial visitors, business associates, investors, and other interested parties for business purposes. Personal Data collected by ORAPI through its website or by other means is used in support of our commercial relationship with you, including, but not limited to, the processing of customer orders, orders from vendors, managing accounts, learning about customers’ needs, responding to inquiries, and providing access to information. Also, in compliance with the laws and regulations of the PDPA 2012 and/or relevant jurisdiction to support our relationship with you:
• we may share Personal Data with our worldwide affiliates to better understand your business needs and how we can improve our products and services;
• we may use third party service providers to assist us in collecting, assembling or processing Personal Data in connection with services related to our business relationship;
• we (or a third party on our behalf) may use Personal Data to contact you about an ORAPI offer in support of your business needs or to conduct online surveys to understand better our customers’ needs; and
• we may use Personal Data for marketing and promotional activities.
If you choose not to have your Personal Data used to support our customer relationship (especially direct marketing or market research), we will respect your choice. We do not sell your Personal Data to Third Parties, nor share it with third parties except as set forth in this Statement.

4c. Accuracy of Your Personal Data

We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we will do a verification exercise for you to update us on any changes to your personal data. If you are a client or customer, it is important that you update us if there are any changes in your personal information such as your home address.

4d. Protection of Personal Data
We have implemented Personal Data Protection Act and Information Security Policy that governs how personal data and confidential information are protected within our organisation. We will take the necessary security arrangements to protect your personal data that is under our charge or control to prevent unauthorised access, collection, use, disclosure, or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
External data intermediaries who process and maintain your personal data on our behalf will be bound by contractual data security arrangements we have with them.

5. Third Party Service Providers


ORAPI is the commercial operator of its website and uses service providers to assist in hosting or otherwise acting as data processors, to provide software and content for our sites and to provide other services. ORAPI may disclose Personal Data supplied by you to these Third Parties who provide such services under contract to protect your Personal Data. In addition, where consistent with the laws and regulations of the relevant jurisdiction, ORAPI may disclose Personal Data if such disclosure:

• is a use of the Personal Data for an additional purpose that is directly related to the original purpose for which the Personal Data was collected;
• is necessary to prepare, negotiate and perform a contract with you;
• is required by law or the competent governmental or judicial authorities;
• is necessary to establish or preserve a legal claim or defense;
• is part of a corporate restructuring, sale of assets, merger or divestiture; or,
• is necessary to prevent fraud or other illegal activities, such as willful attacks on ORAPI information technology systems.

5a. Who We Disclose Your Personal Data To?

We disclose some of the personal data we have collected about you to the following parties or organisations outside ORAPI:

• Accounting Firms
• BCA – Building and Construction Authority
• Branch Office(s)
• Complainants
• Credit Reporting Agencies
• Customers / Clients
• Data Analysis & Analytics Firms
• Database Companies
• Debt Collection Agencies
• Delivery Services
• Email Vendors
• EMAS – Environmental Management zzAssociaton of Singapore
• Employees / Staff
• Government accredited training centres
• Head Office
• Information Technology Service Providers
• Insurance Companies (Group Insurance for zzEmployees)
• Legal Services
• Mailing Houses, Freight and Courier Services
• Marketing & Communications Agencies
• Medical Practitioners
• MOH – Ministry of Health
• MOM – Ministry of Manpower
• NEA – National Environment Agency
• Newspapers & Publications
• Next-of-Kin / Guardians
• Other Contracted Service Providers
• Payroll Processing Services
• Print Processing Services (e.g. statements)
• Recruitment Agencies
• Survey Firms
• Visitors

6. How We Manage the Collection, Use and Disclosure of Your Personal Data


We take our responsibilities under the PDPA seriously. We are committed to implementing policies, practices and processes for data protection that comply closely with the PDPA obligations.

a. Obtaining Consent:
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purpose.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you enter into a sales agreement.

b. Third-Party Consent:
If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.

c. Withdrawal of Consent:
If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted.
Your request for withdrawal of consent can take the form of an email or letter to us.

7. Non-Personal Data Collected Automatically


When you access ORAPI’s website, we may automatically (i.e., not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of our websites and improve their performance or content. In this case, processing is performed on an anonymous basis and at ORAPI’s discretion.

8. Other Online Data


In addition, certain online technical applications or other interactions you have with ORAPI may require the entry of business and technical data. By providing the requested information, you are consenting to the processing and storage of such information by ORAPI. Unless ORAPI is advised that you want this information removed from ORAPI’s server, such information may be retained by ORAPI and used for future commercial communications. A request for removal of this information can be made at the contact information provided below. ORAPI will take all reasonable precautions to assure that no such information will be provided or divulged to other Third Parties, except, if applicable, those Third Parties performing site hosting, maintenance, and related site service activities.

9. Minors / Children


ORAPI will not knowingly collect Personal Data from children under the age of 18. ORAPI’s website(s) is not intended for individuals under 18 years of age.

10. Security and Data Integrity


ORAPI will take reasonable precautions to protect Personal Data in its possession secure against the risk of loss, misuse, unauthorized access, disclosure, alteration and destruction. ORAPI periodically reviews its security measures in an effort to ensure the privacy of Personal Data.

ORAPI will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. While ORAPI will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current, ORAPI is also relying upon each individual to assist in providing accurate updates of his or her Personal Data.

11. Links to Other Websites


Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third-party websites that visitors are able to access through ours. When a visitor to our website links to these third-party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

ORAPI website(s) may contain “links” to websites owned and operated by Third Parties. By accessing these links, which are provided for your convenience, you will leave our site and will be subject to the privacy practices of the other website. This Statement does not apply to any personal information you provide to unrelated Third Parties.

12. Data Retention


In general, ORAPI will retain Personal Data for as there is a need for the data, plus 10 years, or as otherwise required by the laws and regulations of a particular jurisdiction. For example, data will be retained during the time period that you are authorized to use ORAPI website(s), including any ORAPI tools accessible through our website(s). Upon termination of such authorization, your Personal Data related to use of ORAPI website(s) will be removed.

13. Retention of Personal Data


We will not retain any of your personal data under our charge or control when it is no longer necessary for any business or legal purposes. We have a Document Retention Policy that spells out how long we ought to retain each type of confidential document or personal data. Certain retention periods are based on statutory or regulatory requirements.

We will ensure that your personal data that no longer has any business or legal use will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in databases.

14. Privacy & Use of Cookies on Our Websites.


This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Read our Cookies Policy here:
https://orapiasia.com/cookiespolicy/

15. Do-Not-Call (DNC) Provisions and Telemarketing Activities


We do not make unsolicited telemarketing call to promote our goods or services. In the event ORAPI need to send any marketing messages, ORAPI shall check that:

– the message it is sending contains clear and accurate information identifying the organisation, as well as its contact details; and
– if making a phone call, the telephone number it is making the call from is not concealed;
– telephone number is not registered with the DNC Registry;

ORAPI fully comply with Personal Data Protection Act, full disclosure can be found here:
https://sso.agc.gov.sg/Act/PDPA2012#P1IX-

16. Data Access and Correction


Upon request, ORAPI will grant individuals reasonable access to Personal Data that it holds about them. In addition, ORAPI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. ORAPI also relies upon each individual to assist in providing accurate updates of his or her Personal Data. In order to access, correct, amend, or delete the Personal Data ORAPI holds about an individual, the individual should contact the following:
TEL: +65 6265 2888 | EMAIL: sin.marketing@orapiasia.com

17. PDPA Dispute Resolution and Arbitration


The Ministry of Communications and Information has jurisdiction regarding investigation and enforcement of ORAPI’s compliance with the PDPA 2012.

In compliance with the PDPA 2012 and Safe Harbor Principles, ORAPI commits to resolve complaints about our collection or use of your personal information. Employees with inquiries or complaints regarding ORAPI’s privacy policy and compliance with PDPA should first contact your human resources manager or ORAPI’s general data privacy contact at:

TEL: +65 6265 2888 | EMAIL: sin.marketing@orapiasia.com

In addition, personal data subjects may submit a complaint to an independent recourse mechanism. ORAPI commits to cooperate with the Personal Data Protection Commission (PDPC) and comply with the advice given by the panel with regard to personal data transferred from ORAPI. The following link may assist you in finding the appropriate DPA: https://www.pdpc.gov.sg/Guideline-and-Consultation-Menu

Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding PDPA compliance not resolved by any of the other Privacy Shield mechanisms. Information regarding arbitration can be found here: https://sso.agc.gov.sg/Act/PDPA2012

18. Changes to this Statement


ORAPI reserves the right to modify this Statement from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Statement, ORAPI will post the revised Statement on our website.

18a. Liability
If a third party service provider providing services on ORAPI’s behalf processes personal data from the EU or EEA in a manner inconsistent with the Privacy Shield Principles, unless ORAPI can prove that we are not responsible for an event giving rise to damages claimed by any claimant or regulatory body, ORAPI will be liable to such claimant or regulatory body for such damages

19. Contacting Us


If you have any questions about our collection, use, and/or disclosure of your personal data; feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer at:

Contact Number: 6265 2888
Email Address: sin.marketing@orapiasia.com

Any query or complaint/feedback should include, at least, the following details:
• Full name and contact information of the data subject
• Brief description of the query or complaint
We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.