Introduction to privacy

OCBC Cycle Singapore and Spectrum Worldwide are committed to the right to privacy and the protection of personal information.

About our Privacy Policy

This privacy policy (”Policy”) outlines how we manage personal information. It also describes the sorts of information we hold and why, as well as how that information is collected, held, used and disclosed. Depending on the organisation with which an individual deals, further information may apply in addition to the matters discussed in this Policy.

Dealing with us anonymously

Where it is lawful and practicable to do so, individuals may deal with us anonymously (e.g. when enquiring about our products and services generally).

Collecting personal information If an individual is acquiring or has acquired a product or service from, or wishes to participate in an event organised by Spectrum Worldwide, we will collect and hold their personal information to:

• provide the required services or event
• administer and manage those services or event, including (as applicable) charging, billing and collecting debts
• inform the individual of the ways the services provided could be improved or provide information pertaining to the event
• conduct appropriate checks for credit worthiness
• research and develop our services or events
• gain an understanding of the individual’s service needs so we may provide them with better service, including contacting you in future about this and other services, products or events we provide; and
• maintain and develop our business systems and infrastructure, including testing and upgrading these systems

What personal information do we collect?

The information collected may include an individual’s:

• name
• date of birth
• occupation, title, roles and responsibilities
• current and previous address (postal and email)
• telephone number, email address, or other point of contact
• financial details, including credit card or other payment details,
• tax reference number; and,
• other information that we consider necessary

How do we collect personal information?

We will, if reasonable and practicable to do so, collect personal information directly from the individual concerned. This may take place when the individual fills out documents such as an application form or an administrative form or when the individual gives us personal information in person, over the telephone or through our website.

In certain circumstances, we will collect personal information from third parties. For example, we may need to collect personal information from:

• a credit reporting agency, credit card company or bank
• an individual’s financial advisers
• an individual’s representatives (e.g. authorised representatives or legal advisers)
• an individual’s employer
• publicly available sources of information or
• any other organisation identified below (see ‘Disclosing personal information’ below).

Collecting sensitive information

Unless we have consent, we will not collect information that reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a political trade union, details of their health, disability, sexual orientation or criminal record (save and except that a health declaration may be requested in respect of an individual’s application, registration or consent form in respect of his/her participation in a sporting event organised by Spectrum Worldwide).

This is subject to some exceptions including if:

• the collection is required by law or
• the information is necessary or deemed necessary by us to provide a service.

Consequences of not providing personal information

Failing to provide Spectrum Worldwide with certain personal information means that, potentially, we may not be able to provide the relevant service to the individual concerned or allow the individual’s participation in an event organised by Spectrum Worldwide.

Disclosing personal information

In line with modern business practices and to meet individuals’ specific needs, we may disclose personal information to the organisations described below.

Where personal information is disclosed, we will seek to ensure that the information is held, used and disclosed consistently in accordance with any applicable privacy laws in Singapore.

The relevant organisations include:

• outsourced service providers who manage the services we provide (e.g. mailing services, registration providers, billing and debt recovery functions and marketing services)
• credit reporting agencies
• our advisers (including our accountants, auditors and lawyers)
• government and regulatory authorities and other organisations or agencies, as required or authorised by law
• organisations involved in marketing our products and services
• organisations jointly participating in, or assisting us to manage a promotion, activity, event, conference, seminar or competition
• organisations involved in a transfer or sale or our assets or business
• organisations involved in managing our corporate risk and
• our related companies

Also, we may need to disclose an individual’s personal information to their representatives (e.g. their authorised personal representatives or their legal advisers) or to medical staff or regulatory authorities.

In addition, and notwithstanding anything in this privacy policy, we reserve the right to disclose personal information to:
(a) conform to legal requirements or comply with legal process (including any request from a regulatory authority);
(b) protect and/or defend our rights, property and/or our users; and/or
(c) protect the interests of the public and/or any of our users, employees or content on our website.

Transborder data flows

Some disclosures (refer to “Disclosing personal information” above) may occur outside of Singapore and/or an individual’s country of residence.

Marketing our products and services

We will seek consent to use or disclose personal information for the purposes of informing individuals about:

• OCBC Cycle Singapore products and services that may be of interest and which suit their requirements and
• promotions or other opportunities in which they may be interested.

We assume we have consent to use service providers to assist us with marketing (e.g. mailing services or advertising agencies) unless we are told otherwise (see ‘Contacting us’ below).

Storing personal information

We store personal information in different ways, including in paper and electronic form. The security of personal information is important to us and we take reasonable steps to protect it from misuse or loss and from unauthorised access, modification or disclosure. Some of the ways we do this include:

• requiring our staff and service providers to maintain confidentiality
• implementing document storage security policies
• imposing security measures for access to our computer systems (see ‘Privacy on the internet’ below)
• providing a discrete environment for confidential discussions
• only allowing access to personal information where the individual seeking access has satisfied our identification requirements and
• ensuring there is access control into our offices.

Privacy on the internet

We take care to ensure that the personal information given to us on our websites is protected. Our networks and our partner networks have electronic security systems, including firewalls and data encryption. Depending on the system with which an individual deals, user identifiers, passwords and other access codes for our staff and third parties may be used to control access to personal information.

Also individuals may access third-party websites by clicking on links we have provided on our websites. These external websites are not subject to our privacy standards. Individuals need to review those websites to ascertain how the relevant organisation manages personal information.

Cookies

OCBC Cycle Singapore stores a small text file called a cookie on your computer to track session data and persist your login for your convenience. A session cookie expires when you exit your browser. A persistent cookie stays on your computer until it is deleted. You can remove persistent cookies by following the directions provided in your browser's "help" files.

Even if you reject cookies, you may still use the OCBC Cycle Singapore website.

The cookies are set to expire after one year.

Keeping personal information accurate and up to date

We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. However, the accuracy of that information largely depends on the quality of the information provided to us. We therefore suggest that individuals:

• let us know if there are any errors in their personal information and
• keep us up to date with changes to their personal information (e.g. their name and address).

Individuals may do this by mail or email (see ‘Contacting us’ below).

Accessing personal information

Individuals have a right to access their personal information, subject to any exceptions under applicable laws.

Individuals can contact us to obtain a form to request access (see ‘Contacting us’ below). We may charge a fee for collating and providing access to personal information.

Contacting us

Individuals may ask any questions about privacy and the way we manage personal information, or obtain a form requesting access to personal information by emailing us at: info@cyclesingapore.com.sg.