Data Protection Policy

This Stack Data Protection Policy applies to individuals (“Individuals”) who access and use the loyalty coalition programme branded as “Stack” (including any e-commerce platforms, websites and/or mobile applications in connection therewith) (the “Platform”) and/or sign up for an account on the Platform (“Account”). Please take a moment to read this Stack Data Protection Policy so that you know and understand the purposes for which OCBC collects, uses and discloses your Personal Data.

By accessing the Platform and/or signing up for an Account, you agree and consent to each of the following:

Oversea-Chinese Banking Corporation Limited and its related corporations, as well as their respective representatives and/or agents (collectively “OCBC”); and

respectively collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to OCBC’s authorised service providers and relevant third parties in the manner set forth in this Stack Data Protection Policy.

You also agree to:

the terms of OCBC’s Data Protection Policy, available at www.ocbc.com/policies or upon request; and

Notwithstanding anything in this Stack Data Protection Policy, your consents hereunder are provided independently to OCBC respectively, and you agree and understand that OCBC is responsible for its own compliance with any obligations or undertakings arising in connection with the collection, use, disclosure or other processing of your personal data, whether under this Data Protection Policy or otherwise, which obligations and undertakings are independent (and not joint and several) as between OCBC and its strategic partners.

This Stack Data Protection Policy is supplementary to and does not supersede OCBC’s Data Protection Policy, which will continue to apply. This Stack Data Protection Policy sets out additional terms relating to the collection, use and disclosure of the Individual’s Personal Data.

This Platform is an additional platform that supplements the existing loyalty point redemption programmes that you are enrolled with and does not affect your privileges under each such programme. Your participation and use of this Platform is voluntary and supported by advertising, promotional and other activities referenced herein.

OCBC may from time to time update this Stack Data Protection Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Stack Data Protection Policy as updated from time to time on the Platform’s website ([url]). Please check back regularly for updated information on the handling of your Personal Data.

Personal Data
1. In this Stack Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which OCBC has or are likely to have access, including data in OCBC’s records as may be updated from time to time. It includes, but is not limited to, Personal Data that is collected due to your use of the Platform.
2. Examples of such Personal Data you may provide to OCBC include (depending on the nature of your interaction) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transaction data, usage patterns, product preferences and any other information relating to any individuals which you have provided in any forms you may have submitted to OCBC (including in the form of biometric data), or via other forms of interaction with you.
Purposes for the Collection, Use and Disclosure of Your Personal Data
1. By interacting and transacting via the Platform, you consent to OCBC collecting, using and disclosing your Personal Data for the following purposes:
  - responding to, processing and handling complaints, queries, requests, feedback, customer service requests and/or suggestions relating to the Platform or the products/services offered thereon;
  - verifying your identity;
  - processing your application for an Account;
  - maintaining and administering your Account;
  - providing you with, or facilitating the provision of, goods and services which you have requested;
  - processing payment requests (including payment by loyalty points) in relation to transactions for goods and services which you may be entitled to or which you may have requested for;
  - checking and ensuring that the amount of each loyalty point associated with your Account is accurate;
  - processing conversion requests in relation to your loyalty points;
  - tailoring and providing information, product and service offerings (whether offered by OCBC, or some other third party) to you in accordance with your preferences and purchase history on the Platform and/or other transactions with OCBC and its respective business partners;
  - matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of information, products and services, whether by OCBC or other third parties;
  - conducting market research, understanding and analysing customer behaviour, location, preferences and demographics;
  - combining Personal Data about you and/or your use of the Platform with data that OCBC has (including any personal data provided to OCBC independently of your use of the Platform in the course of your dealings with OCBC (e.g. as part of your banking relationship with OCBC), whether obtained from you or from third parties) to obtain insights on and profile your preferences and activities;
  - helping each of OCBC’s partners conduct statistical, profiling and/or behavioural analysis for market research or other purposes by providing them with aggregated [and/or individualised] information about you and other users (including server logs, metrics, time stamps, clickstream data and other device and technical data relating your use of the Platform);
  - using cookies, online advertising and other technologies in connection with the above; and/or
  - any other purposes which are reasonably related to any of above.
Disclosure of Personal Data
1. OCBC will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above, in OCBC’s Data Protection Policy (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
  - the vendor in charge of operating the Platform;
  - vendors or other third party service providers in connection with promotions and goods/services offered on the Platform;
  - OCBC’s partners whose loyalty points you can use on the Platform;
  - OCBC’s business partners to whom OCBC provides data for the conducting of statistical, profiling and/or behavioural analysis for market research or other purposes;
  - external business and charity partners in relation to corporate promotional events; and
  - any other party to whom you authorise OCBC to disclose your Personal Data to.
Data Security
1. OCBC will take reasonable efforts to protect Personal Data in their respective control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, OCBC cannot completely guarantee the security of any Personal Data they may have collected from or about you, or that for example no harmful code will enter the Platform (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and other online applications.
2. While OCBC strives to protect your Personal Data, OCBC cannot ensure the security of the information you transmit to them via the Internet. You should take every precaution to protect your Personal Data when you use such platforms. It is recommended that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform OCBC as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. OCBC is not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
Use of Cookies
1. When you interact with the Platform, OCBC automatically receive and record information on their respective server logs from your device. OCBC may employ cookies in order to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
2. Cookies are small text files stored in your computing or other electronic devices which allow OCBC to remember you or other data about you. The cookies cannot access, read or modify any other data on an electronic device.
3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser or mobile application. However, you may not be able to access certain parts of the Platform.
Third-Party Sites
1. The Platform may contain links to other websites operated by third parties. OCBC is not responsible for the privacy practices of websites operated by third parties that are linked to the Platform. You are encouraged to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with OCBC’s respective logos or trademarks, even though they are not operated or maintained by OCBC. Once you have left the Platform, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
1. If you:
  - have any questions or feedback relating to your Personal Data or the Stack Data Protection Policy;
  - would like to withdraw your consent to any use of your Personal Data as set out in this Stack Data Protection Policy; or
  - would like to obtain access and make corrections to your Personal Data records, you can approach OCBC via the following channels:
    
    Email a@a.com
    
    Phone 123
  - You may also write to the Data Protection Officer as follows:
  - Please note that if your Personal Data has been provided to OCBC by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to OCBC on your behalf.
  - If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, OCBC may not be in a position to continue to provide their respective products or services to you or administer any contractual relationship already in place. This may also result in the termination of any agreements you have with OCBC (e.g. termination of your Account), and your being in breach of your contractual obligations or undertakings. OCBC’s legal rights and remedies in such event are expressly reserved.
Governing Law
1. This Stack Data Protection Policy and your use of the Platform shall be governed in all respects by the laws of Singapore.

Email	a@a.com
Phone	123

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Data Protection Policy