A: POLICY STATEMENT
B. CATEGORIES OF PERSONAL INFORMATION OAP COLLECTS
OAP collects Personal Information about our customers from the following sources:
• Account Application Forms and other documents and data submitted by customers, such as customer name, residential address, Government Issued Identification Number (such as social security numbers), date of birth, email address, employment information, education, investment experience, annual income, and estimated net worth;
• Customer transactions with OAP, such as account deposits and withdrawals that require customers to provide bank account and/or credit card related information;
• Consumer reports and other information OAP receives from third party agencies;
• Communications with OAP customer service representatives; and
• "Cookies" described in section N below.
We wish to assure you that OAP will not collect more Personal Information than is required to open and operate customers’ accounts, and to comply with regulatory obligations.
• Apart from personal information, we may collect other types of information which is not linked to an individual and is anonymous. For example, traffic pattern information relating to our website or services provided by OAP and/or third parties we may work with.
• We may ask for other data voluntarily from time to time (for example, through market research, surveys or promotions) to enable us to improve our service or study the wider needs of our customers or potential customers.
This is not an exhaustive list and we may collect other types of personal information from you.
C. HOW OAP USES CUSTOMER PERSONAL INFORMATION
OAP may use your Personal Information for any of the following purposes:
• positively identify and determine your eligibility for account opening, operation of your account including closing your account;
• Using the information provided for client knowledge assessments;
• complete bank deposits and withdrawals;
• effect, administer, review or enforce transactions requested or authorized by the customer,
• processing any applications or requests for new services and / or products made by you;
• delivering online or e-mail advertising or promotional messages on our products and services that may be of interest to you under any direct marketing activities undertaken by us;
• carrying out due diligence or other screening activities (including identity, reference, credit and background checks) in accordance with legal or regulatory obligations or our internal risk management policy (including but not limited to those designed to prevent financial crime, “know-your-customer”, anti-money laundering, counter-terrorist financing or anti-bribery) that may be required by law or that may have been put in place by us;
• enforcing our legal and / or contractual rights against you including but not limited to using legal advisers and debt collection agencies;
• to improve the content of the website
• to notify you about any updates such as regulatory, products, services etc that could be relevant to you and/or your account
• maintain or service your account with OAP,
Personal Information collected online may be combined with other information customers provide to OAP in hard copy or through the OAP helpdesk. OAP will not use or disclose or sell, rent or lease any Personal Information about its customers or former customers to any third parties except as stated in this Policy. Personal Information may be transferred across national and state borders for the purposes of data consolidation, storage and customer data management, including sharing your information with relevant OANDA entities.
D. DISCLOSURE OF CUSTOMER PERSONAL INFORMATION
Please note that OAP may disclose Personal Information of current and former customers to affiliated and non-affiliated third party entities in the following cases:
• to OAP’s business partners that perform services on OAP’s behalf under written agreements which restrict use of Personal Information to the limited purposes for which it is provided to them and to refrain from further use or disclosure except as permitted by law;
• to OAP’s affiliates, who are permitted to disclose and use the information only to the extent that OAP may disclose and use the information under this Policy;
• in the ordinary course of business to OAP’s attorneys, accountants and auditors;
• to persons holding a legal or beneficial interest relating to the customers’ account;
• to persons acting in a fiduciary, representative, or attorney capacity in relation to an account;
• to protect against actual or potential fraud, unauthorized transactions, claims or other liability;
• to government, regulatory or law enforcement agencies to the extent permitted or required by law, or to comply with applicable legal requirements; or
• to comply with civil, criminal or regulatory investigations or judicial process, subpoena, summons or warrant by relevant authorities.
E. DO-NOT-CALL REGISTRY
From time to time, OAP and our partners may contact you via call or SMS to inform you about our latest products, services, benefits, promotions and rewards.
If you have previously consented to receiving such calls and messages, you will continue to be updated on our promotions and marketing campaigns. However, if you no longer wish to continue to receive marketing calls or messages, you may withdraw your consent by contacting our Client Experience (“CX”) Department at +65 6579 8289 or email us at email@example.com.
For potential customers, we will only contact you via the telephone for marketing and promotional messages/calls after ascertaining that you have not registered with the national Do Not Call (DNC) Registry administered by the Personal Data Protection Commission of Singapore. However, as we may rely on the one-month validity period of our search results, you may inadvertently still receive marketing or promotional messages/calls.
If you had received a telemarketing call from someone representing OAP although you have registered with the DNC Registry or withdrawn your consent, please inform us at firstname.lastname@example.org, or contact us by calling +65 6579 8289.
The above changes will generally not affect informational and service related messages sent by OAP (e.g. messages relating to your account).
F. PERMISSION TO DISCLOSE PERSONAL INFORMATION
G. TRANSFER OF PERSONAL INFORMATION OVERSEAS
In certain circumstances, we may need to transfer your personal information outside of Singapore. Any such transfer of your personal information outside of Singapore will be carried out in accordance with the Personal Data Protection Act (“PDAP”) requirements.
You acknowledge and give consent to the transfer of your personal information to other entities within OANDA Group (for information on OANDA Group, visit our website at www.oanda.com) as well as third party service providers and agents (including lawyers / law firms) outside of Singapore for one or more of the purposes described in this document.
You are entitled to request details of such transfer from us at any time.
Generally, when we request for personal information in the course of providing you a service and / or product and you provide us with such personal information, there is implied consent that you agree to provide us with personal information in order for us to provide you with the requested service and / or product.
In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal information. For example, where there are new purposes for the use of your personal information, we will seek your fresh consent.
If you do not consent to provide the requisite personal information that we need at the point of application or in the course of maintaining your account(s) with us, we may not be able to open account(s) for you or provide the specific service or product that you require. You are entitled to withdraw your consent for the collection of personal information by contacting us. However, this may affect our ability to maintain your account(s) with us.
I. SITUATIONS NOT REQUIRING CONSENT
We may share non-personal, non-individual information in aggregate form with third parties for business purposes or we may disclose to our business partners the number of customers in certain demographic groups or who carried out certain transactions.
J. PROCEDURES TO SAFEGUARD PERSONAL INFORMATION
Safeguarding the privacy of your personal information is important to us, whether you interact with us personally, by phone, by mail, over the internet or other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.
OAP has implemented procedures to safeguard customer Personal Information. OAP protects customer account information by keeping it on the secure servers, using firewalls and other security technology to protect its network and systems from external attacks, and by requiring customers to enter a unique user ID and password to access the fxTrade and fxTrade Practice systems. OAP conducts periodic internal audits of its business practices and procedures, examining its confidentiality standards and information access in order to best protect our customers' Personal Information.
We restrict our employees’ access to your personal information on a need-to-know basis in accordance to their role’s requirement to provide services to you. Employees who handle personal information are trained to respect the confidentiality of customer details and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal.
We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is received from you or sent to you via the Internet.
K. RETENTION OF PERSONAL INFORMATION
OAP only keeps Personal Information on file for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information and retention is no longer necessary for legal or business purposes. Destruction of customer’s personal data will be done in a secure manner.
OANDA attempts to ensure the accuracy of the Personal Information collected. OANDA records the dates when Personal Information was obtained from customers and will periodically ask customers to review the Personal Information OANDA has on file and to update any Personal Information that may have changed.
We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that certain data that we hold about individuals may change more frequently, for example, residential address, phone number and email address, income, savings and net-worth, etc.
In order to ensure that your personal information is current, complete and accurate, please update us by contacting us in person through live chat, email, phone or in person at our office. We can generally update your personal information over the phone or at our discretion, may require relevant and reliable documents to verify the amendment(s) that you requested for.
M. CUSTOMER RECOURSE
Any concerns a customer may have regarding OAP’s privacy practices or specific complaints about how customer’s Personal Information has been collected, used or disclosed should be forwarded to OAP’s CX at email@example.com. OAP’s will thoroughly investigate the complaint and will take whatever actions are warranted and notify the customer once this has been done.
Under the Act, you have the right to obtain a copy of any personal information which we hold about you and to advise us of any inaccuracy that requires a correction. In addition, you are entitled to know how your personal information has been used or disclosed in the past one year.
The PDAP does set out some exceptions to this. For instance, where the amount of effort and resources needed to provide access would be unreasonable or disproportionate to your interests or if we have satisfied ourselves on reasonable grounds that the correction should not be made.
To make a request, you will need to contact our CX desk at firstname.lastname@example.org and specifying what data you require correcting. We may charge a reasonable administrative fee for this service to cover the cost of verifying the application and locating, retrieving, reviewing and amending any material requested. If the personal information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
We will acknowledge your request within 30-days and respond promptly to it. In exceptional circumstances, we reserve the right to deny you access to your personal information and may provide an explanation as required by applicable laws
O. LINKS TO NON-OAP WEBSITES
P. TECHNOLOGY IMPROVEMENTS
R. GOVERNING LAW
S. CONTACT US
Mail: OANDA Asia Pacific Pte. Ltd,
50 Collyer Quay, #04-03 OUE Bayfront, Singapore 049321