Collection, Use and Disclosure of Personal Data

1. OCL and its related companies may collect and use your personal data for any of the following purposes:
2. Registering you as a customer of OCL and its related companies;
3. Performing obligations in the course or in connection with our provision of the goods and/or services requested by you;
4. Verifying your identity (including conducting credit checks);
5. Responding to, handling, and processing queries, requests, applications, complaints and feedbacks from you;
6. Managing your relationship with us;
7. Processing payment or credit transactions;
8. Sending you marketing information about our goods or services including notifications of marketing events, initiatives and promotions, lucky draws, membership, rewards and other promotions;
9. To comply with all applicable laws and regulations, or to assist in law enforcement and investigations conducted by any government and/or regulatory authority;
10. Transmitting to any unaffiliated parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities; whether in SG or abroad;
11. Any other purposes for which you have provided the information;
12. All other incidental business purposes related to or in connection with the above.
13. We may disclose your personal data:
14. Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested from you; or
15. To third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause (1) above; or
16. To other member firms in the Optima network of firms, where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary requests.
17. We collect, use or disclose these personal data when it is necessary for business purposes or to meet the purposes for which you have submitted the information, only if there is consent or deemed consent from you and information on such purposes have been notified. In OCL, we restrict the collection of personal data mostly through direct channels, such as tele-communications, e-mail, face-to-face interactions, and/or by asking you to fill up forms. Personal Data are collected from clients, customers, business contacts, partners, personnel, contractors and other individuals. OCL will not use or disclose personal data about you for any other purposes without first informing you of the additional purposes and getting your consent to us doing so for the additional purpose(s). However, do note that we are permitted by the PDPA to collect, use or disclose personal data about you without your consent in various circumstances. We may collect personal data about you from another individual or organization if you have given that other individual or organization consent that allows it to disclose personal data to us. We will use or disclose it only for the purposes for which the other individual or organization has disclosed it to us.
18. You should ensure that all Personal Data submitted to us is accurate and complete. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Withdrawing your consent

5. 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 from you in writing. You may withdraw consent and request us to stop 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. We will require you to provide proof of your identity for such request.
6. Upon receipt of your withdrawal request, we may require reasonable time to process your request and 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 30 days from the date of receiving the request. Should there be any further delays, we shall inform you within 30 days from your request.
7. Please note that in the event of your withdrawal from your consent to any or all use of disclosure of your Personal Data, depending on the nature of your request, we may no longer be able to continue to provide services to you. Also, 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 & Correction of Personal Data

8. If you wish to make 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. Likewise, we will require you to provide proof of your identity for such request.
9. 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.
10. We will respond to your request as soon as reasonably possible. 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

11. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
12. 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

13. 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 through your app profile, or by informing our Data Protection Officer in writing or via email at the contact details provided below.

Retention of Personal Data

14. 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.
15. 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.

Transfer of Personal Data out of Singapore

16. 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.

Collection, Use & Disclosure of NRIC & Other National Identification Numbers
17. From 1 September 2019, OCL will not be allowed to collect, use or disclose NRIC / FIN / Work Permit / Birth Certificate numbers or copies of the identification document containing these national identification numbers unless:

– Required under the law; or

– Necessary to accurately establish or verify the identity of the individual to a high level of fidelity

We have assessed the above ruling and will only collect NRIC and other national identification numbers which falls under the abovementioned permitted reasons. Some of the areas where we may continue to collect NRICs include, but are not limited to, the following:

–  Insurance/Motor Warranty related applications and claims

–  Rental or usage of our motor vehicles

–  Employment purposes

Data Protection Officer

18. 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:

• Email: Dpo@ow.sg
• Contact: +65 6452 6868  (Office hours: weekdays 9am to 6pm)
• Address: 600 Sin Ming Avenue #03-00, CityCab Building, Singapore 575733

Effect of Policy and Changes to Policy

19. This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
20. We may amend the terms of this Policy at any time by reasonable notice [including without limitation by posting the revised terms on our website https://www.ocleasing.sg, under “Privacy Policy”]. Your continued use of our services constitutes your acknowledgement and acceptance of the amendments, and the amended terms will thus be binding on you.

Last updated: 30 May 2024