This Data Protection Notice (“Notice”) sets out the basis which Oversea-Chinese Banking Corporation Limited and its related corporations (collectively, the “Companies”), and their respective representatives and agents (“Representatives”) (the Companies and Representatives collectively referred to as “OCBC”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of OCBC Cycle participants (“Participants”, each, a “Participant”) in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) in relation to OCBC Cycle (the “Event”). 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:
   
   “Participant” means an individual who has registered to participate in the Event. For the purposes of this Notice, Participants shall also include individuals who may have contacted us to enquiry about the Event.
   
   “personal data” means data, whether true or not, about a Participant 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, last 4 character of NRIC, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, financial information, emergency contact’s details (e.g., name, relationship and telephone number) and health-related information (e.g., existing medical conditions and blood type).

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) managing and facilitating the Event;
   (b) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you, associated with the Event;
   (c) verifying your identity;
   (d) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   (e) managing your relationship with us;
   (f) processing payment or credit transactions;
   (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) facilitating order processing with authorised merchants;
   (i) publishing race results and photos;
   (j) for public relations and future marketing efforts concerning this Event;
   (k) providing complimentary insurance for Participant riders participating in physical rides;
   (l) facilitating any related contests, promotions and promotional campaigns;
   (m) usage of photographs, videos, motion pictures, images, recordings, or any other recording of the Event for any commercial advertising and other promotional purposes linked to the Event, or future cycling-related Events organised or held by OCBC; and
   (n) such other purposes as may be related to the above, or otherwise specified by you.

6. We may disclose your personal data:
   (a) where such disclosure is required for performing our obligations in the course of or in connection with the managing and facilitating of the Event, or otherwise, our provision of the goods and services requested by you as related to the Event;
   (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 set out in paragraphs 5 and 6 of this Notice; or
   (c) where such disclosure to healthcare service providers is required in case of a medical emergency occurring during the Event.

7. The purposes listed in the above clauses may continue to apply even after the Event has concluded, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

8. 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 official Event email address provided below.

9. 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 ten (10) business days of receiving it.

10. 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 retract your withdrawal of consent request, please inform us in writing in the manner described in paragraph 8 above.

11. 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

12. 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 to our official Event email address provided below.

13. 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.

14. 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

15. 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 (such as password protection, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password (OTP) / 2 factor authentication (2FA) / multi-factor authentication (MFA) to secure access, and security review and testing performed regularly.

16. 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

17. 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 contacting our official Event email address provided below.

 RETENTION OF PERSONAL DATA

18. 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.

19. 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

20. 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

21. You may contact us at our official Event email address at enquiry@ocbccycle.com if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. 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.

23. 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  :           28/02/2024
Last updated   :           28/02/2024