Data Protection Policy
This Data Protection Policy (“Policy”) explains how ONOW Co Ltd (“ONOW”) collects, uses, discloses and/or processes personal data you provide to us or that we may receive.
This Policy supplements but does not supersede or replace any other consents which we may have obtained. We may from time to time update this Policy to ensure it aligns with our operational practices and complies with changes in law or regulation.
Personal Data that we collect
In this Policy, “Personal Data” refers to personal data as defined in the Personal Data Protection Act 2012 (No. 26 of 2012 of Singapore) (“PDPA”) and includes any data or information (whether true or not) about you from which you can be identified, either (i) from that data; or (ii) from that data and other information to which we have or are likely to have access.
Some examples of such Personal Data that we may collect include:
Your name, national identification details such as passport or other identification number, telephone number(s), mailing address, email address, and any other information which you may have provided us;
Your photos, video and/or voice recordings of you;
Your employment history, educational background and income levels; and
Information about your usage of and interaction with our website and/or services including computer and connection information, bandwidth, statistics on page views, and traffic to and from our website.
How we collect Personal Data
ONOW may collect Personal Data that you provide to us, including but not limited to:
when you visit our website;
where your Personal Data is disclosed to or shared with us from third party social networking or social media services that you use or connect with (e.g. Facebook, LinkedIn, Instagram, Twitter, Vimeo, YouTube or Medium);
when you register or apply for any of our services e.g. for a training, mentorship programme or loan;
when you donate through our website, or register with us as volunteers, mentors or trainers;
when you register for or attend our events, trainings, forums, workshops, talks, mentorship and/or consultancy services. Photos and/or video recordings may take place at or during these events and used for publicity purposes;
when you interact with any of our employees, interns, mentors, volunteers, sponsors, board and committee members e.g. via meetings, emails or telephone calls;
when you submit your details in the Connect With Us field on our website, request that we contact you, or be included in an email or other mailing list;
when you participate in our research, surveys, initiatives and programmes e.g. via online, face to face or pen and pencil, conducted by us or our partners/vendors;
when you apply for employment or an internship with ONOW; and/or
when you visit any of our premises (where closed circuit television ‘CCTV’ recording may be in operation).
We do not target or intend to collect any Personal Data of minors below the age of thirteen (13), save with the consent of their parents or legal guardians. You must consult your parent or guardian before providing us with your Personal Data if you are under the age of thirteen (13).
Accuracy of Personal Data
ONOW will make reasonable efforts to ensure that the Personal Data we collect is accurate and complete. Please help ONOW by ensuring that all Personal Data that you submit is complete and accurate. You may update us when there are any changes to the Personal Data which you have provided to us by emailing the updates to our teams. We will correct or complete your Personal Data as soon as reasonably practicable.
ONOW 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. Failure to provide complete, accurate, true and correct information may result in our inability to provide you with services you have requested and/or to process the necessary administration.
Purposes of processing Personal Data
ONOW may collect, use and/or disclose Personal Data for one or more of the following purposes, to which you agree and acknowledge, and consent to:
Administering and/or delivering our services in training, mentoring and/or providing loans;
Contacting you about or otherwise informing you about ONOW’s and/or ONOW-related organisations’ products and services, or other information which may be of interest to you. We may also invite you to participate in ONOW events and activities;
Carrying out your instructions or responding to your queries;
Assessing and/or processing requests to ONOW;
Processing any third party interactions through ONOW;
Processing and/or administering financial and/or debt recovery matters including payments, funds, loans, sponsorships, billings, accounts, benefits and entitlements, or carrying out credit and reference checks;
Processing and/or administering employment, internship and/or volunteering related assignments or arrangements with ONOW;
Computing and/or compiling statistics, data analytics and other research findings for ONOW;
Providing information on product enhancements, services and policies;
For compliance monitoring and audit reviews;
Investigating and responding to allegations or suspicion of fraud, misconduct, any unlawful action or omission;
Complying with any applicable laws and regulations, codes of practice or guidelines, or to assist in law enforcement and/or respond to any investigations by relevant authorities and agencies;
Complying with applicable internal policies and procedures;
Archiving, backing-up, storing or destroying Personal Data;
Informing you of changes and updates to our services, policies, terms and conditions and other administrative information.
Where you provide us with Personal Data of another individual, you confirm that you have their consent to do so and for the purposes specified above.
ONOW may also collect, use, disclose and/or process Personal Data where an exception to consent under the PDPA applies; and/or where required or authorised to do so by any written law.
If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving upcoming events and updates from ONOW via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s), including via voice calls, text, fax or other means with our updates.
If you have provided us with your Myanmar telephone number(s) and have indicated that you consent to receiving upcoming events and updates from ONOW via your Myanmar telephone number(s), then from time to time, we may contact you using such Myanmar telephone number(s), including via voice calls, text, fax or other means with our updates.
Disclosure of Personal Data
We will endeavour to keep Personal Data protected and where appropriate, confidential. However we may disclose, subject to applicable law, such Personal Data for the purposes listed above, to the following parties:
Our employees, interns, mentors, volunteers, sponsors, board and committee members;
ONOW-related organisations and third party organisations with whom we may partner or collaborate with for research and development and/or to deliver on any of our services;
Third party service providers who provide services to ONOW, e.g. event organisers, marketing consultants, courier services, payroll, mailing, information technology, data processing and storage, insurance, and professional advisers such as auditors and lawyers;
Banks, credit card companies and other financial institutions for the processing of loans, funding or any monies receivable or payable;
Any liquidator, receiver, official assignee/trustee, judicial manager or any other person appointed under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other analogous process in respect of any individual, company or business
Any judicial, administrative or regulatory body, any government or public or government agency, or any parties thereof having jurisdiction over ONOW, or to comply with applicable laws or regulations or upon their request; and
Any other party to whom we are authorised or required, or that you may authorise us, to disclose your Personal Data.
Transfer of Personal Data across borders
Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes ensuring that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.
Withdrawal of consent
If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may contact the ONOW Data Protection Officer (“DPO”) (whose details are found under the section titled ‘Contacting us’ below).
If you withdraw your consent to our collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be able to continue providing our services or performing our contractual obligations to you. Such withdrawal may also result in the termination of any agreements or arrangements you may have with us. ONOW’s legal rights and remedies are expressly reserved in such a situation.
ONOW will strive to process your withdrawal of consent within 14 working days of your withdrawal and will notify you if more time is required.
Access to Personal Data
You may request access to or make corrections to your Personal Data that ONOW holds. If you wish to make either request, you must submit your request to ONOW’s DPO identifying yourself and the Personal Data to which your request relates. Our DPO’s details are found under the section titled ‘Contacting us’ below.
ONOW will strive to respond to each request for access or correction as soon as reasonably practicable, in accordance with applicable law. We may deny your request under certain circumstances as set out in the PDPA. We may also charge you a reasonable fee for processing your request for access pursuant to the PDPA. We will provide you with a written estimate of such fee in advance of granting you access.
Our response time to your request is between 14 to 20 working days. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. If more than 20 working days are required, we will inform you within the first 20 working days of the time when we would be able to respond to your request.
Protection of Personal Data
We will make reasonable security arrangements to protect Personal Data in our possession or control, including having in place appropriate physical, technical and administrative procedures to safeguard against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction of that data.
Notwithstanding this, you acknowledge that no data transmission over the internet is completely secure and by providing your Personal Data over the internet, you are transmitting information at your own risk.
Retention of Personal Data
We will only retain your Personal Data for as long as you use our services, or which is required or relevant for us to meet a business or legal purpose.
We may collect or analyse aggregated information on an anonymous basis (i.e. from which individuals cannot be identified) (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites/applications and common entry and exit points into our websites/applications.
We use “cookies” where a small data file is sent to your browser to store and track Aggregate Information about you when you visit our website. The cookie is used to track information such as the number of users, their frequency of use, profiles of users, and their preferred sites. Such information is used to assist us in analysing the usage of our websites/applications and improving our website and services.
If you wish to disable the cookies associated with these technologies, you can do so by changing the setting on your browser. However, you may not be able to access certain part(s) of our website or services.
Third party sites
Should you have any questions, feedback or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Lead at firstname.lastname@example.org.
Updates to Policy
We are committed to ensuring that we manage and protect Personal Data in accordance with applicable laws and regulations, which may change from time to time, as well as in line with best practices. As such, will be reviewing our policies and practices from time to time, and we reserve the right to amend the terms of this Policy at our discretion. Any amendments to our Policy will be posted on our website.
This Policy shall be governed in all respects by the laws of Singapore.