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Orchid Country Club
1 Orchid Club Road, Singapore 769162
Tel: 6755 9811 Fax: 6755 8874

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The following terms shall form part of Orchid Country Club’s (“OCC”) Personal Data Protection Policy:

Collection, use and disclosure of personal data

1. To process, administer and/or manage your relationship with OCC, and to provide you with the services and products of OCC, OCC will necessarily need to collect, use, disclose and/or process your personal data or personal information about you, including your transactions.

2. By submitting information to OCC, or signing up for any services and products offered by OCC, you hereby agree and consent that OCC may collect, use, disclose and process your personal information for one or more of the following purposes:
   • Processing your enquiries and application for services and products by OCC;
   • Providing you with the services and products of OCC;
   • Administering and/or managing your relationship with OCC;
   • Carrying out your instructions or responding to any enquiries by you;
   • Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures (including but not limited to those designed to combat 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 OCC;
   • Dealing in any matters relating to the services and/or products which you are entitled to under this Agreement (including the printing of membership cards and the printing and mailing of correspondence, statements, invoices, confirmations, advises, information, reports or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages);
   • The recovery of any and all amounts owed to OCC;
   • The process of reviewing and approving your application(s) for OCC’s services and products, and the conduct of initial and anticipatory credit checks and assessments, relevant checks, ongoing assessment and verification of ongoing creditworthiness and standing;
   • Preventing, detecting and investigating fraud, misconduct, any unlawful action or omission, whether relating to your application or any other matter relating to your application for OCC’s services and products, and whether or not there is any suspicion of the aforementioned;
   • Managing OCC’S infrastructure and business operations, and complying with policies and procedures that may be required by law or that may have been put in place by OCC, including those relating to auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing, business continuity, and records, document and print management;
   • If consented by you via your registration or participation in any contest, lucky draw, campaign, promotion, event, survey or questionnaire, to administer and provide you with such activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your personal data, so we suggest that you read these carefully;
   • Complying with applicable law in administering and managing your relationship with OCC; and/or
   • Unless you have indicated your preference to opt-out, provide for the dispatch of marketing information relating to services or products offered by OCC and OCC’S affiliates, business partners and related companies which OCC thinks is of benefit or interest to you via postal mail, electronic transmission to your email address(es), and/or voice call or phone call, SMS/MMS (text messages), and/or fax to your telephone number(s).
     (collectively, the “Purposes”)

3. In carrying out one or more of the above Purposes, OCC may need to disclose your personal data to certain third parties, whether located within or outside Singapore, such as :
   • OCC’s third-party service providers or agents including but not limited to those who provide administrative, telecommunications, computer, payment or securities clearing or other services to OCC in connection with the operation of its business, mailing houses, telecommunication companies, marketing agents, call centres, data processing companies and information technology companies;
   • any credit reference agency, rating agency, business partner, insurer or insurance broker, direct or indirect provider of credit protection, bank or financial institution, and, in the event of default, to debt collection agencies;
   • to OCC’S auditors and professional advisors including its solicitors;
   • any person to whom OCC is under an obligation to make disclosure under the requirements of any law binding on OCC or any of OCC’S branches or under and for the purposes of any guidelines issued by regulatory or other authorities with which OCC or any of OCC’S branches are expected to comply with;
   • any person to whom disclosure is permitted or required by any statutory provision or law;
   • any permitted assigns;
   • to any local or foreign regulatory body, government agency, statutory board, ministry, departments or other government bodies and/or its officials; and/or

4. If you do not wish for OCC to use your personal data or disclose your personal data for any of the above Purposes, you may withdraw your consent at any time by written notice to OCC, pursuant to the Personal Data Protection Act 2012, however, depending on the circumstances and the nature/extent of your withdrawal, your withdrawal of consent may result in OCC’S inability to provide you with the services and products and hence may result in the termination of your relationship with OCC or other consequences of a legal nature which may arise by virtue of your legal relationship with OCC.

5. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as OCC to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

6. You agree that where your written permission is required by law or otherwise for any such disclosure by OCC, the signing of the application form as well as in any other manner permitted by law shall constitute and be deemed to be sufficient written permission for such disclosure.

7. OCC’S rights under this clause shall be in addition to and without prejudice to OCC’S other rights of disclosures available pursuant to the Banking Act, Chapter 19 of Singapore (as may be amended or revised from time to time) or any other statutory provision and in law and nothing herein is to be construed as limiting any of these other rights.

8. Please be informed that you have the right to opt-out of receiving marketing information relating to services or products offered by OCC. Kindly note that if you do not exercise your right to opt-out of receiving such marketing information, you will be deemed to have consented to the receiving of such marketing information by OCC and OCC will continue to provide such marketing information to you.

9. All capitalised words and expressions used that are not defined in this notification shall have the same meaning given to any such words and expressions in the general terms and conditions applicable to the relevant relationship.

10. Note that the amendments set out in this notification shall be effective on and from the date written above and apart from such changes, all other terms of the [general terms and conditions] remain the same. In the event of any inconsistencies between the terms of this notification and the [general terms and conditions], the terms of this notification shall prevail.

11. If you have any questions relating to the contents of this notification and/or OCC’S policy on the collection, use and disclosure of your personal data, please contact us at dpo@orchidclub.com.

Withdrawal of Consent, Access and Correction of your Personal Data. You may make your request to withdraw your consent, access or correct your personal data by emailing to dpo@orchidclub.com