Privacy Policy

Welcome to the privacy policy of Obeden PTE Ltd (collectively referred to as "Obeden", “we“, “us” or “our” throughout).

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete the information from our database and terminate the corresponding account, if any.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

‍Controller

‍Obeden is the controller and is responsible for your personal data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

‍Contact details

‍If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer:

If you have any questions about our information practices, please contact us by writing or email at:

‍Data Protection Officer
Obeden PTE
20 Cecil Street
05-03
Singapore
049705
‍Email: obeden-dpo@obeden.com

‍You have the right to make a complaint at any time to the Personal Data Protection Commission Singapore (PDPC), the Singaporean supervisory authority for data protection issues (www.pdpc.gov.sg), the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), the European country based Data Protection entity which can be located via the European Data Protection Protection Board (edpb.europa.eu) or the appropriate Data Protection Institution within your country base. We would, however, appreciate the chance to deal with your concerns before you approach the data protection body, so please contact us in the first instance.

‍Changes to the privacy policy and your duty to inform us of changes

‍We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

‍Third-party links

‍This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It is personal data which you provide directly to us through voluntary submission, and does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender, picture, social security number and/or tax identification number, copies of ID cards or other forms of identification.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Professional Background Data includes about workers/employees.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct Interactions

You may give us your Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources

We will receive personal data about you from various third parties, as set out below:

Technical Data from analytics providers such as Google based outside your country or jursidiction (such as the UK or the EU); and
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside your country or jurisdiction (such as the UK or the EU).

4. How we use your personal data

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

The types of lawful basis that we will rely on to process your personal data include:

Legitimate Interest: the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

‍Performance of Contract: processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

‍Compliance with a legal obligation: processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

‍Purposes for which we will use your personal data

‍We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Type of data

To register you as a new customer

(a) Identity
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(b) Contact

Performance of a contract with you

To process and deliver your order including:
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(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity
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(b) Contact
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(c) Financial
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(d) Transaction
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(e) Marketing and Communications

(a) Performance of a contract with you
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(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
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(a) Notifying you about changes to our terms or privacy policy
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(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

‍We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will be able to view and make certain decisions about your personal data use once you sign up to our site.

‍Promotional offers from us

‍We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

‍Third-party marketing

‍We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

‍Opting out

‍You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or while logged into our website under your profile and/or the organisation for main users or by contacting us at any time via email at obeden-optout@obeden.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

‍Cookies

‍You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the certain parties for the purposes set out in the table above. Third parties include:

Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Accounting and HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, the EEA and other countries in which we are regulated who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Your personal data is securely held and processed by us in Singapore. If you are in the United Kingdom or European Economic Area (“EEA”) this will involve transferring your data outside of the United Kingdom and EEA to our servers in Singapore.

Recipients of your Personal Data may be located outside Singapore. You agree that we may transfer your Personal Data within the OBEDEN group, to our affiliates, subsidiaries and/or other authorised third parties (such as service providers e.g. cloud service providers, data processor, etc) located outside of Singapore, as long as the Personal Data is handled in accordance with this Policy and all applicable laws. We will ensure recipients of your Personal Data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA, GDPR, UK GDPR (DPA2018) and/or the data protection laws of the relevant jurisdiction.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?
‍We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the following rights under this Policy, and by law if you are within the EU, to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer in writing to: obeden-dpo@obeden.com.

Please note that certain rights provided in the above paragraph are available to you if you are within the EU in accordance with the GDPR. Under GDPR you have inalienable rights to (i) be informed about your right to complain through this Policy, (ii) make an actual complaint to your relevant supervisory authority depending on where you live (such as the European Data Protection Supervisor), and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.

Please note that certain rights provided in the above paragraph are available to you if you are within the UK in accordance with the UK GDPR (DPA2018). Under UK GDPR (DPA2018) you have inalienable rights to (i) be informed about your right to complain through this Policy, (ii) make an actual complaint to the Information Commissioner's Office, and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.

If the GDPR or UK GDPR (DPA2018) is not applicable to you, your rights will be governed by this Policy to the extent of complying with the PDPA.

What we may need from you

‍We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

‍Time Limit to respond

‍We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍No fee usually required

‍You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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