Privacy Policy
- Who we are
1.1 This
is the Privacy Policy (“Policy” or “Privacy
Policy”) of Oro Solutions Pte Ltd (“ORO Redemption”).
1.2 You
have been directed to this Policy because a company within the ORO Redemption
is collecting, using or disclosing your personal data.
1.3 In this Policy, when we use “we”, “us” or “our”,
we refer to the company which is collecting your personal data, or which is
operating the website which you are accessing or using.
1.4 We own and/or operate website(s) such
as https://www.ororedemption.com/ and/or any mobile apps that may be
published by us (the said website and mobile apps may be collectively or
individually referred to as the “Website”).
1.5 ORO Redemption is a limited company registered
in Singapore (Co. Reg. 201729486W) at Singapore Post Ltd, 1 Rochor Canal Road,
Sim Lim Square, #04-13, Singapore 188504.
2
What is the purpose of this Policy?
2.1 The
purpose of this Privacy Policy is to inform you and provide you with an
understanding of how we, our affiliates, related corporations and associated
companies globally, handle, collect, use, disclose and deal with personal data
about you that you give us, that we receive through third parties or that is in
our possession. Please read this Privacy Policy carefully.
2.2 We
are committed to safeguarding the privacy and security of your personal data.
We take our responsibilities under Singapore’s Personal Data Protection Act
(the “PDPA”) seriously. We also recognise the importance of the personal data
you have entrusted to us and believe that it is our responsibility to properly
manage, protect and process your personal data.
2.3 The
contents of this Privacy Policy may change over time so please check back
frequently. Any changes to this Privacy Policy will be posted on and can be
viewed at our Website.
2.4 The
Website is not intended for use by any person below the age of 18. We do not
and do not intend to, transact through the Website directly with anyone we know
to be under the age of 18.
2.5 By
providing any personal data to us, you declare and affirm that you are at least
18 years of age and above and agree to the terms set out in this Privacy
Policy.
2.6 This
Policy applies to all personal data that you may provide to us and the personal
data we hold about you. By providing us with your personal data or by
accessing, using or viewing the applicable Website or any of its services,
functions or contents (including transmitting, caching or storing of any such
personal data), you shall be deemed to have agreed to each and all the terms,
conditions, and notices in this Policy. If you do not agree, please cease use
of the relevant Website(s) and/or service(s) and DO NOT provide any
personal data to us.
3
What personal data is collected
3.1 “Personal
data” is defined under the PDPA to mean data, whether true or not,
about an individual who can be identified from that data, or from that data and
other information to which an organisation has or is likely to have access.
3.2 When
you use our Website, any service we provide or in your interaction with us, the
personal data we may collect include but is not limited to :-
a. Data collected directly
from you. This may be done through our Website, over the phone, by
email, or in person when you meet our staff or representatives. The personal
data collected may include, but is not limited to:
your contact information,
including your (first and last) name, (billing and/or delivery) address,
birthdate and email address and/or your telephone number. We need your e-mail
address and/or telephone number so that we may contact you if we have questions
or information for you regarding your order or the service that we are
providing or will provide to you;
other information required to be
able to process your order or to provide you with the service, such as
information concerning the products you have ordered or the service we are
providing to you, the billing and/or delivery address, banking and/or credit/debit
card details;
if you have created an online
profile or account, the preferences and interests stored in such profile or
account (please see below for further information concerning the profiles);
and/or
if you have contacted customer
service, the details of this contact and the contact history.
b.
Data collected by automated means. Various
technologies may be used on our Website and our mobile and web-based
applications in order to make them more user-friendly, effective and secure.
Such technologies may lead to data being collected automatically by us or by
third parties on behalf of us. This data does not always, but may, contain a
user’s personal data or comprise of personal data. Examples of such
technologies include:
- Click-stream
data. A visit to one of our Websites results in data that is
transmitted from your browser to our server being automatically
collected and stored by us or by third parties on behalf of us. This
data can include, in particular, the following:
– the visitor’s IP address
– the date and time of the visit
– the referral URL (the site from which the visitor has come)
– the pages visited on our website
– information about the browser used (browser type and version,
operating system, etc).
- Cookies. A
number of places on our Website and our mobile and web- based
applications make use of cookies. These are essentially small text
files that are stored on your computer’s hard drive or your user device
by your web browser. We can use cookies to identify the owner of a user
account and to store articles in a shopping basket during the
purchasing process. In other words, cookies help to make our website or
our (mobile and web-based) applications more user-friendly, more
effective and more secure. The cookies usually used by us are so-called
“session cookies”, which are automatically deleted at the end
of the visit to the relevant website. By default, web browsers enable
the use of cookies but this function can also be disabled. However,
this will result in some services not being available. It is also
possible to manually delete cookies after their use via the web
browser. More information may be available from your web browser
provider.
- Flash
cookies. A particular form of cookie is the flash cookie. In
contrast to normal cookies, these cookies are not created and saved by
the web browser but are governed by the Adobe Flash plug-in. These can
contain more information than normal cookies and cannot be deleted or
disabled via the browser; this is only possible if you follow
instructions available from the Adobe Flash Player website. You can
also obtain more information about these cookies on that website.
- Web
beacons and tracking links. Web beacons (also known as pixel
tags and clear GIFs) involve graphics that are not apparent to the
user. Tracking links and/or similar technologies consist of a few lines
of programming code and can be embedded in our website or our (mobile)
applications. In conjunction with cookies, these are primarily used for
statistical analysis purposes. This technology can also be used for
tracking traffic patterns on websites, as well as finding out if an
e-mail has been received and opened and to see if there has been any
response.
- Web
analytics. Web analytics is the term given to a method for
collecting and assessing the behaviour of visitors to websites and
(mobile) applications. This includes the analysis of traffic patterns
in order, for example, to determine the frequency of visits to certain
parts of a website or (mobile) application, or to find out what
information and services our visitors are most interested in. For these
purposes, we primarily make use of click-stream data and the other
techniques listed above. Web analytics are carried out by Google
Analytics and/or other selected parties. You can find out more
information about the processing of web analytics data by Google
Analytics in paragraph 9 below.
3.3 Hence,
depending on the circumstances or the nature of the transaction with you, the
personal data we may collect from you includes :
- name
- home
address - age
- gender
- birthdate
- identification
number (such as national ID, passport details etc.)(collection of this
will be in compliance with the PDPA and depends on the circumstances or
transaction at hand) - image
and/or photograph - credit/debit
card information - location
Information of yourself and/or your computer or device - contact
Information - transactional
information - usage
and preferences - bank
account number - your
purchase and/or your transactions with us - your
signature (such as when you sign off on a parcel delivery)
We will
collect your personal data in accordance with the PDPA.
3.4 We
may receive information about you from third parties such as if you use any
websites or social media platforms operated by third parties (for example,
Facebook, Instagram, Twitter etc.) and, if such functionality is available, you
have chosen to link your profile on our Website with your profile on those
other websites or social media platforms.
4
The purposes for which we collect, use or
disclose your personal data
4.1 ORO Redemption, will/may collect, use,
disclose and/or process your personal data for one or more of the following
purposes :
a.
processing and/or dealing with your interest in
our products and/or services;
b.
considering, processing, dealing with and/or
managing, your booking, reservation, request/application for, of or your
purchase of, our products and/or services (the “Transaction”);
c.
facilitating, processing, dealing with,
administering and/or managing Transaction(s) by or with you;
d.
administering, facilitating, managing,
processing and/or dealing with your relationship with us, your transaction(s)
with us, your being our loyalty card member or rewards member, any transactions
or activities carried out by you on the Website or at our
premises/establishments or with us, your requests, including but not limited to
dealing with your adhoc queries, requests or bookings, dealing with your
preferences, dealing with your membership needs, dealing with your delivery
needs, processing orders and payment transactions, implementing transactions
and the supply of products and/or services to you that you have requested.
Without limiting the generality of the foregoing, should you make a reservation
or transaction that includes third party individual(s) or on behalf of third
party individual(s) or for third party individual(s), you consent to us
disclosing personal data that identifies you, to the said third party
individual(s) (such as but not limited to your name);
e.
administering, facilitating, processing and/or
dealing in any matters relating to your use or access of the Website, including
identifying you for login to the Website, our portals and other online services
provided by or on behalf of us. Without limiting the generality of the
foregoing, if you:
I. gain access to or sign in to the Website, using your login credentials
of a Social Networking Site, or
II.use any features of a Social Networking Site such as its widgets,
plug-ins and browser push notifications, made available to you on our Website,
it may result in information or your personal data being collected or shared
between us and the third party. For example, if you use Facebook’s “Like”
feature, Facebook may register the fact that you “liked” a product and may post
that information on Facebook. (“Social Networking Site” refers to
an online or digital platform owned or operated by a third party, that is used
by people to build social networks or social relations, or to interact, with
other people, such as but not limited to Facebook, Instagram, Twitter). By your
proceeding pursuant to (i) or (ii) above, you consent to such collection, use
or disclosure of your personal data;
f.
monitoring, processing and/or tracking your use
of the Website in order to provide you with a seamless experience, facilitating
or administering your use of the Website, and/or to assist us in improving your
experience in using the Website;
g.
administering, facilitating, processing and/or
dealing in any transactions, payments, debt collection, or activities carried
out by you on the Website or at our premises or with us;
h.
providing services to you as our customer, as a
member of our loyalty programme(s)/ card programme(s)/ rewards programme(s) or
when requested by you; dealing with or administering your participation in
contests, gamification, social events organised by us;
i.
registering you as a customer of any of our
products or services, and/or to deal with, process and/or administer the
account that you may open with us, whether a membership account or otherwise,
including to facilitate your transactions or activities at our premises, the
Website, or your transactions or activities with us;
j.
carrying out your instructions or responding to
any enquiry or complaint given by (or purported to be given by) you or on your
behalf including responding to your enquiries and complaints; or responding to
or dealing with your interactions with us or your requests; or responding to or
dealing with your feedback, comments or reviews. If you have contacted us with
any complaints, feedback, comments, suggestions, we will use and disclose your
personal data (including your contact history) to respond to you and provide
you with the best service possible. If you are the complainant and you do not
want us to disclose your identity to the party you are complaining about, you
must let us know immediately. However, it may not always be possible to handle
your complaint on the basis of anonymity;
k.
contacting you or communicating with you via
phone/voice call, text message and/or fax message, email and/or postal mail for
one or more of the Purposes stated herein. You acknowledge and agree that such
communication by us could be by way of the mailing of correspondence, documents
or notices to you, which could involve disclosure of certain personal data
about you to bring about delivery of the same as well as on the external cover
of envelopes/mail packages;
l.
sharing or disclosing (at our discretion) your
suggestions, comments, feedback or content (including audio, video etc.)
(collectively “Feedback”) that you provide through Social Networking
Sites, to the Website or to us (including at our premises), with other users of
the Website or with the public, for publicity and/or promotion purposes with a
view to marketing or showcasing the business, products or services of ORO
Redemption, and/or to acquiring customers, and/or for the purpose of providing
the public with your Feedback which may be useful for the public’s patronage
decision or for the public’s information or otherwise. This includes us disclosing
your name together with your Feedback. Without limiting the generality of the
foregoing, in the above regard, your Feedback and name may/will be published or
shared by us on public media platforms such as the newspaper, the Internet, in
our (including our affiliates’) annual reports (if any) etc., and/or
incorporated as part of ORO Redemption marketing collaterals/materials or
corporate video to be disclosed to the public, and you hereby consent to the
same. Do not provide us with Feedback if you do not wish for such Feedback to
be disclosed to the public. If you wish to give us your Feedback without it
being disclosed to the public, please separately contact our Customer
Department at https://www.ororedemption.com/visit-us
and head the subject of your feedback content with the word “Confidential”;
m.
understanding and/or managing your interests,
concerns and preferences;
n.
carrying out due diligence, statutorily required
activities or other screening activities (including background checks,
anti-money laundering checks, know your client checks) in accordance with legal
or regulatory obligations applicable to us or any ORO Redemption (whether
Singapore or other countries), the requirements or guidelines of governmental
authorities which we determine are applicable to us (whether Singapore or other
countries) or any ORO Redemption, and/or our risk management procedures that
may be required by law (whether Singapore or other countries) or that may have
been put in place by us or our affiliates/associated companies;
o.
to prevent or investigate any fraud, unlawful
activity or omission or misconduct, whether or not there is any suspicion of
the aforementioned; dealing with conflict of interests; or dealing with and/or
investigating complaints;
p.
complying with or as required by any applicable
law, governmental or regulatory requirements of any jurisdiction applicable to
us or our affiliates/associated companies, including meeting the requirements
to make disclosure under the requirements of any law binding on us or our
affiliates/associated companies, and/or for the purposes of any guidelines
issued by regulatory or other authorities (whether of Singapore or other
countries), with which we or our affiliates/associated companies are expected
to comply;
q.
complying with or as required by any request or
direction of any governmental authority (whether Singapore or other countries)
which we are expected to comply with; or responding to requests for information
from public agencies, ministries, statutory boards or other similar
authorities. For the avoidance of doubt, this means that we may/will disclose
your personal data to the aforementioned parties upon their request or
direction;
r.
conducting research, (including customer
research), surveys, market surveys, analysis and development activities
(including but not limited to data analytics, and/or profiling), obtaining your
feedback to our products, services or facilities, to :
I.improve
or develop our products, services and/or facilities in order to enhance any
continued interaction between yourself and us connected or in relation to your
relationship with us, the Website, or your Transaction(s);
II.improve
any of our products or services or facilities, whether now or in the future; or
III.improve
our understanding of your interests, concerns and preferences.
Without
limiting the generality of the foregoing, we may/will in this regard send you
surveys or request a face to face interview survey or request your feedback, by
way of email or postal mail.
In order for
us to market products and services which are of special interest and relevance
to you, we may analyse and rely on your overall interaction with us (such as
but not limited to your shopping behaviour in e-shops, your use of loyalty
programmes, your ratings and reviews of products, your contact history with our
customer service, your newsletter clicks/ opening results, your surfing
behaviour (web tracking), the newsletter types you are subscribed to, your
participation in promotions or events, your interactions with us and your use
of (mobile) applications);
s.
the conduct of training or training purpose, so
as to develop or improve our products or services and/or our staff’s and
agents’ services and/or service quality. Without limiting the generality of the
foregoing, such training may involve collection, use, disclosure or processing
of your personal data including your feedback or comments or reviews;
t.
to facilitate and/or ensure the safety and
security of our premises, our customers, our staff and/or visitors to our
premises; to deal with, handle and/or conduct disciplinary, security, crime
prevention and/or quality assurance processes, matters and/or arrangements.
Without prejudice to the generality of the aforesaid, we wish to bring to your
attention that there are surveillance cameras installed throughout our premises
and/or our offices, for security, crime prevention, safety and training reasons
and you acknowledge that your personal data will be collected by such cameras
and processed by us consequently;
u.
for marketing purpose and in this regard, ORO
Redemption would be providing you with marketing, advertising and promotional
information, materials and/or documents relating to products, contests,
services and/or events (including products, services and/or events of third
party organisations with which ORO Redemption may collaborate with) that we or
such third party organisations may be selling, marketing, offering, organising,
involved in or promoting, whether such products, services and/or events exist
now or are created in the future, :
I.by way of postal mail,
electronic transmission to your email address(es), push notifications, other
forms of in-app notifications or harnessing other technologies (such as
geo-location technology) for our mobile application(s) on your mobile device(s)
or other technologies on your computers, and/or through other modes of
communication that is not the 3 DNC Modes in compliance with the PDPA. You may
opt out of this or withdraw from this at any time by sending a request to our
Data Protection Officer. For the avoidance of doubt, unlike (ii) below, the
application of or your acceptance of or your consent to, this Privacy Policy,
constitutes your consent to this subparagraph (i);
II.if you have separately
expressly consented to one or more of the following 3 DNC Modes, by way of the
3 modes of communications of voice calls, text messages or faxes (the “3 DNC
Modes”) to your Singapore telephone number, in compliance with the
requirements of the PDPA; and/or
III.Notwithstanding (ii) above,
regardless that you have not separately provided express consent as
aforementioned in (ii) above, ORO Redemption, as the case may be, reserves its
right to send a specified fax message (as defined in Singapore’s Personal Data Protection
(Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a
specified text message (as defined in the Exemption Order) (i.e. a marketing
fax message or marketing text message) to your Singapore telephone number, if:
For the avoidance of doubt, this subparagraph is without prejudice to
subparagraph (r) above for which you have hereby consented to us contacting you
for a survey, which you may subsequently opt out of by sending our Data
Protection Officer notice;
1.
there is an ongoing relationship between ORO
Redemption, and you, and the purpose of the message is related to the subject
of the ongoing relationship, pursuant to the requirements and conditions of the
Exemption Order; or
2.
the law permits.
v.
Storing, hosting, backing up (whether for
disaster recovery or otherwise) of your personal data, whether within or
outside Singapore;
w.
maintaining and/or developing our IT or business
systems and infrastructure including testing and upgrading of these systems;
x.
creating reports with respect to your
Transaction(s) and/or transactions that we have with our customers;
y.
facilitating, dealing with and/or administering
external audit(s) or internal audit(s) of the business of ORO Redemption,
Transaction(s), and/or our transactions with our customers;
z.
anonymisation of your personal data. In this
regard, you acknowledge that personal data that has been anonymised is no
longer personal data and the requirements of the PDPA would no longer apply to
such anonymised data;
aa. dealing
with and/or facilitating a business asset transaction or a potential business
asset transaction, where such transaction involves ORO Redemption as a
participant or involves only a related corporation or affiliated company of ORO
Redemption as a participant or involves ORO Redemption and/or any one or more
of ORO Redemption related corporations or affiliated companies as
participant(s), and there may be other third party organisations who are
participants in such transaction. “business asset transaction” means the
purchase, sale, lease, merger or amalgamation or any other acquisition,
disposal or financing of an organisation or a portion of an organisation or of
any of the business or assets of an organisation;
ab. record-keeping purposes and
producing statistics and research for internal and/or statutory reporting
and/or record-keeping requirements, of ORO Redemption or of its
affiliates/related corporations;
ac. ORO
Redemption’s reporting purposes including but not limited to reporting on ORO
Redemption’s business performance; and
ad. to deal
with the or as part of a bankruptcy, winding up, reorganisation, restructuring,
insolvency, receivership or an assignment for the benefit of creditors, of ORO
Redemption.
(the purposes set out in this paragraph 4.1 above shall be
collectively referred to as the “Purposes”)
4.2 You
may withdraw your consent for us to process your personal data for marketing
purpose mentioned at paragraph 4.1.21 above at any time via
one the following relevant methods:
- clicking
the Unsubscribe button located at the bottom of our emailers
- contacting
us or our Data Protection Officer through the contact details below
4.3 We
may/will need to disclose your personal data to third parties, whether located
within or outside Singapore, for one or more of the above Purposes, as such
third parties, would be processing your personal data for one or more of the
above Purposes. In this regard, you hereby acknowledge, agree and consent that
we may/are permitted to disclose your personal data to such third parties
(whether located within or outside Singapore) for one or more of the above
Purposes and for the said third parties to subsequently collect, use, disclose
and/or process your personal data for one or more of the above Purposes.
Without limiting the generality of the foregoing or of paragraph 4.1,
such third parties include:
a.
our associated or affiliated organisations or
related corporations, or any member of the ORO Redemption;
b.
any of our agents, contractors or third party
service providers that process or will be processing your personal data on our
behalf including but not limited to those which provide administrative or other
services to us such as mailing houses, telecommunication companies, information
technology companies, data centres, hosting and maintenance service providers,
analysis services service providers, e-mail messaging services service
providers, delivery service provider, handling of payment transactions service
providers, marketing service providers, delivery services, handling of payment
transactions and debt collection, solvency check and address check;
c.
our professional advisers, for example, our
auditors and lawyers, as well as our insurers;
d.
third parties to whom disclosure by us is for
one or more of the Purposes and such third parties would in turn be collecting
and processing your personal data for one or more of the Purposes. Without
limiting the generality of the foregoing, such third parties to which we
may/will disclose your personal data include payment, debt collection, finance
companies or banks including credit card companies; and
e.
any actual or proposed assignee or transferee of
the business of ORO Redemption, or a merged entity in the event ORO Redemption is
merged to create the said merged entity.
4.4 We
may share your information with any member of the ORO Redemption, which may be
based in countries other than Singapore, from time to time for one or more of
the Purposes.
4.5 Should
you provide us with personal data of your child or children, you confirm,
declare and agree that you are the parent and/or legal guardian of such
child/children, and that we may collect, use and/or disclose your child’s or
children’s personal data for the Purposes set out at paragraph 4.1 above
and in the manner as set out at paragraphs 4.1 to 4.4 above.
4.6 You
may withdraw your consent for the collection, use and/or disclosure of your
personal data in our possession or under our control by contacting us at here. We will
process your request within a reasonable time from such a request for
withdrawal of consent being made, and will thereafter not collect, use and/or
disclose your personal data in the manner stated in your request, unless an
exception under the law or a provision in the law permits us to. However, your
withdrawal of consent could result in certain legal consequences arising from
such withdrawal, including us being unable to perform the transactions
requested by you or the termination of your relationship with us (depending on
the extent of your withdrawal), as the case may be.
4.7 We
may collect, use, disclose or process your personal data for other purposes
that do not appear above. However, we will notify you of such other purposes at
or before the time of obtaining your consent, unless processing of your
personal data without your consent is permitted by the PDPA or by law.
4.8 To
the extent permitted by law, we may/will also be collecting from sources other
than yourself, personal data about you, for one or more of the above Purposes,
and thereafter using, disclosing and/or processing such personal data for one
or more of the above Purposes. We may combine information we receive from other
sources with information you give to us and information we collect about you.
We may use this information and the combined information for the Purposes set
out above (depending on the types of information we receive).
4.9 Our
Website may have the functionalities to allow you to share your personal data
with other third parties such as other users of our website. You are
responsible for your choice(s) and are deemed to have provided consent for any
sharing of your personal data in the manner provided by the Website.
4.10
We take reasonable steps to ensure that any
personal data we collect, disclose and use is accurate and complete, if your
personal data is likely to be used by us to make a decision that affects you,
or disclosed to another organisation. However, it is important that you advise
us of any changes to your personal data or if there are any errors in the
personal data we hold about you. We will not be responsible for relying on
inaccurate or incomplete personal data arising from you not updating us of any
changes in your personal data that you had initially provided us with.
5
Provision of third party personal data by
you
5.1 Should
you provide us with personal data of any individual other than yourself, you
represent, undertake and warrant to us that :
a. for any
personal data of individuals that you disclose to us, you would have prior to
disclosing such personal data to us obtained consent from the individuals whose
personal data are being disclosed, to :
I.permit you
to disclose the individuals’ personal data to ORO Redemption for the Purposes;
and
II.permit ORO Redemption to collect, use, disclose and/or process the
individuals’ personal data for the Purposes;
b.
at our request, you will use such form(s) or
document(s) provided by us in obtaining such consents from the individuals in
question (for the avoidance of doubt, we are under no obligation to you to
create any such form(s) or document(s))
c.
any personal data of individuals that you
disclose to us are accurate; and
d.
for any personal data of individuals that you
disclose to us, that you are validly acting on behalf of such individuals and
that you have the authority of such individuals to provide their personal data
to ORO Redemption to collect, use, disclose and process such personal data for
the Purposes.
6
Third Party websites
6.1 This Policy only applies to
our Website and information that we collect from you. Our Websites may contain
links to other websites which are not owned or maintained by us. When visiting
these third party websites or disclosing your personal data to third parties
(including buyers or sellers on our website), you should read their privacy
policies, or ask relevant questions before you disclose your personal data. We
are not responsible for the collection, use or disclosure of your personal data
by such third parties.
7
Social Networks
7.1 Our
Website and mobile or web-based applications may provide you with social plug-
ins from various social networks (such as Facebook and Twitter). If you choose
to interact with a social network, your activity on our Website or via our
mobile or web- based applications will also be made available to social
networks such as Facebook and Twitter.
7.2 If
you are logged in on one of the social networks during the visit of one of our
Websites or mobile or web-based applications, the social network might add this
information to your profile. If you are interacting with one of the social
plug-ins, this information will be transferred to the social network. In case
you do not wish such a data transfer, please log off on your social network
before you enter one of our Websites or mobile or web-based applications.
7.3 We
cannot influence this data collection and data transfer via the social
plug-ins. Please read the privacy policies of those social networks for
detailed information about the collection and transfer of personal data, what
rights you have and how you can achieve satisfactory privacy settings.
8
Geo-location Services
8.1 Our
Website and mobile or web-based applications may offer location-enabled
services, such as Google Maps and Bing Maps. If you use those mobile or
web-based applications, they may receive information about your actual location
(such as GPS signals sent by a mobile device) or information that can be used
to approximate a location. You will/may be asked if the geo-location service
can be activated and you can also object to this geo-location service within
the respective mobile or web-based application.
9
Web analytics by Google Analytics
9.1 Our
Website and mobile or web-based applications may contain web analytic services
provided by Google Analytics. This means that when you visit our Website or use
any mobile or web-based applications, a cookie will be stored on your computer
or mobile device, except when your browser settings do not allow for such
cookies.
9.2 This
further means that when you visit our Website or use any mobile or web-based
applications, the personal data described above in paragraph 3.1 – including
the “click- stream data”, the data from “web beacons and
tracking links” and information stored in Google Analytics cookies will be
sent to Google Analytics for analysis for and on behalf of us. Please note that
if you have created an online profile at our Website or mobile or web-based
application and if you are logged on in this profile, a unique number
identifying this profile will also be sent to Google Analytics in order to be
able to match the web analytics data to this profile.
9.3 Google
Analytics acts as our agent, which means that we solely determine the purposes
for which the data is being used. You can find out more about the relationships
between Google Analytics and us in the Google Analytics’ privacy policy.
9.4 If
you do not wish information about your behaviour at our Website or any mobile
or web-based applications being collected and assessed by Google Analytics, you
can install the Google Analytics opt-out browser add-on. This add-on instructs
the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) to not send
your site visit information to Google Analytics. The browser add-on is
available for most modern browsers. The Google Analytics opt-out browser add-on
does not prevent information from being sent to the website itself or in other
ways to web analytics services.
10
Retargeting Technologies
10.1
Our Website and mobile or web-based applications
may use retargeting technologies within the internet. This enables us to show
our visitors, who were already interested in our shop and our products,
advertisement from us on partner websites.
10.2
We also work with other companies who use
tracking technologies to serve advertisements on our behalf across the
Internet. These companies may collect non- personally identifiable information
about your visits to our websites or mobile or web- based applications and your
interaction with our communications, including advertising.
10.3
Retargeting technologies analyse your cookies
and display advertisement based on your past surfing behaviour. For further
information on cookies, please refer to paragraph 3 of this
Policy.
10.4
We do not store any personal data about you with
this technology.
11
Security & how do we store data?
11.1
Security of your personal data is important to
us. We will put in place reasonable security arrangements to ensure that your
personal data is adequately protected and secured. Appropriate security
arrangements will be taken to prevent any unauthorised access, collection, use,
disclosure, copying, modification, leakage, loss, damage and/or alteration of
your personal data. However, we cannot assume responsibility for any
unauthorised use of your personal data by third parties which are wholly
attributable to factors beyond our control.
11.2
We will put in place measures such that your
personal data in our possession or under our control is destroyed and/or
anonymised as soon as it is reasonable to assume that (i) the purpose for which
that personal data was collected is no longer being served by the retention of
such personal data; and (ii) retention is no longer necessary for any other
legal or business purposes.
12
Your Rights
12.1
If you have any questions about the processing
of your personal data or about our Policy, if you do not accept the amended
Policy, if you wish to withdraw any consent you have given us at any time, or
if you wish to update or have access to your personal data, you are welcome to
contact us. The contact details are :
Attention to
: The ORO Redemption Data Protection Officer
Mailing address : 1 Rochor Canal Road, Sim Lim Square, #04-13,
Singapore 188504
Customer Care Hotline : 87829380
Online feedback form : https://www.ororedemption.com/visit-us/
12.2
You have the right to access and/or correct any
personal data that we hold about you, subject to exceptions under the law. This
right can be exercised at any time by contacting us through the contact URL at paragraph 12.1. We
will need enough information from you in order to ascertain your identity as
well as the nature of your request, so as to be able to deal with your request.
All requests for correction or for access to your personal data must be in
writing. We will endeavour to respond to your request within 30 days, and if
that is not possible, we will inform you of the time by which we will respond
to you.
12.3
We may be prevented by law from complying with
any request that you may make. We may also decline any request that you may
make if the law permits us to do so.
12.4
In many circumstances, we need to use your
personal data in order for us to provide you with products or services which
you require or have requested. If you do not provide us with the required
personal data, or if you do not accept an amended Policy or withdraw your
consent to our use and/or disclosure of your personal data for these purposes,
it may not be possible for us to continue to serve you or provide you with the
products and services that you require or have requested.
12.5
We may charge you a fee for responding to your
request for access to the personal data which we hold about you, or for
information about the ways in which we have (or may have) used your personal
data. If a fee is to be charged, we will inform you of the amount beforehand
and respond to your request after payment is received.
13
Complaints
13.1
You may send complaints regarding our handling
of personal data in the following ways:
a.
in writing.
Such complaints must:
– be addressed to the ORO Redemption Data Protection Officer at:
(i) Online feedback form : https://www.ororedemption.com/visit-us ;
or
(ii) Mailing address : 1 Rochor Canal Road,
Sim Lim Square, #04-13, Singapore 408600
– provide the name, contact number and address of the person submitting the
feedback
– provide the relevant details required such as the relevant time period, our
employees or who involved, or copies of relevant documents.
b.
by telephone.
Such complaints must:
– be made to the ORO Redemption Data Protection Officer at:
Customer Care Hotline: 1605 (This is a recorded line. The caller is
advised that their call will be recorded.)
13.2
All complaints will be evaluated by ORO
Redemption in a timely manner. After ORO Redemption has completed its
evaluation, the ORO Redemption Data Protection Officer (or a duly appointed
representative) will respond to the person who submitted the complaint or
feedback, with the results of the evaluation.
14
Governing Law
14.1
This Policy is prepared pursuant to the PDPA and
governed by the laws of Singapore.
15
General
15.1
Your consent that is given pursuant to this
Privacy Policy is additional to and does not supersede any other consent that
you had provided to ORO Redemption with regard to processing of your personal
data.
15.2
For the avoidance of doubt, in the event that
Singapore personal data protection law permits an organisation such as us to
collect, use or disclose your personal data without your consent, such
permission granted by the law shall continue to apply.
Last Updated on 8 August 2024