The purpose of this document (“Data Protection Policy”) is to inform you of how One Boston Private Limited and its related corporations (collectively, the “Companies”), and their respective representatives and agents (“Representatives”) (the Companies and Representatives collectively referred to as “OBF”, “us”, “we” or “our”) collect, use and disclose Personal Data.

We may update or change this Data Protection Policy by publishing the latest version of our Data Protection Policy on our website (www.obf.com). This ensures that our Data Protection Policy conforms with future developments, industry trends, and legal or regulatory changes. We may inform you of changes in how we process your Personal Data through appropriate means, such as by posting a notice or sending you a notification.

1. Personal Data
In this 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 we have or are likely to have access.
The Personal Data you provide us depends on the nature of your interaction with us. Some examples of Personal Data include:
1.1. your full name;
1.2. NRIC, passport or other identification number;
1.3. contact details such as telephone number(s), mailing address, email address;
1.4. your location;
1.6. account numbers and transactional data; and
1.7. information relating to any individuals which you provide to us.

2. Collection of Personal Data
We will only collect your Personal Data in a lawful manner and when we have a valid reason to do so. Generally, we collect your Personal Data in the following ways:
2.1. when you submit any form, including application, declaration, proposal or referral forms;
2.2. when you enter into any agreement, provide other documentation or information relating to your interactions and transactions with us, or when you use our services;
2.3. when you interact with us via telephone calls (which may be recorded), letters, chat, fax, face-to-face meetings and e-mail;
2.4. when you are within our premises, or attend events hosted by us;
2.5. when you use services provided through our online and other technology platforms, such as websites and apps, including when you set up any online accounts with us;
2.6. when you ask us to contact you, include you in an e-mail or other mailing list, or participate in our promotions and other marketing initiatives;
2.7. when you respond to our representatives and agents and other service providers;
2.8. when you send an employment or evaluation application, provide documents or information (such as your resume) in connection with any appointment as an officer, director, representative or to any other position, or when you attend interviews with us;
2.9. when you interact with us via our websites and platforms, or use services on our websites and platforms;
2.10. where allowed under applicable law, when we seek information about you regarding your relationship with us and receive your Personal Data (for example, from business partners, public agencies, your ex-employers and the relevant third parties);
2.11. when you respond to a request from us for additional Personal Data;
2.12. from third party sources to which you have given your consent (such as our ecosystem partners) or if the collection of your Personal Data is necessary to comply with applicable data protection laws;
2.13. when you give us consent to collect your Personal Data from your mobile device (e.g. location information); and
2.14. when you send your Personal Data to us for any other reason.
We may collect your information when you browse or use our website and platforms. Please see the section below on “Use of Cookies and Related Technologies” for more information.
If you provide us with any Personal Data of a third party (e.g. information on your referrals, spouse, children, parents, and/or employees), you represent that, by sending such information to us, you have obtained the consent of such third party for you to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data sent to us is complete, accurate, true and correct. Failure on your part to do so may prevent us from providing you with the products and services you have asked for.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data
We must be transparent in how your Personal Data is used so that you can trust us. Generally, OBF collects, uses and discloses your Personal Data for the following purposes:
3.1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
3.2. establishing and verifying your identity;
3.3. managing our administrative and business operations;
3.4. facilitating corporate restructuring processes and business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
3.5. matching any Personal Data which relates to you for any of the purposes listed in this policy;
3.6. requesting feedback or participation in surveys, conducting market research or analysis for statistical, profiling, or other similar purposes. These other purposes include the development, design and improvement of our products and services, and understanding customer behaviour, preferences, and market trends;
3.7. preventing, detecting, and investigating crime (including fraud, money-laundering and terrorist financing);
3.8. analysing and managing commercial risks;
3.9. managing the safety and security of our premises and services (including carrying out CCTV surveillance, implementing safe distancing measures and conducting security clearances);
3.10. project management;
3.11. providing media announcements and responses;
3.12. marketing offers and promotions in relation to products and services (including co-branded products and services and organising promotional events);
3.13. in connection with any claims, actions or proceedings (including drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and in protecting and enforcing our contractual and legal rights and obligations;
3.14. managing and preparing internal and external reporting;
3.15. training our employees to provide better products and services to you;
3.16. to determine service levels;
3.17. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and due diligence), internal policies, and assisting law enforcement or investigations by relevant authorities;
3.18. for or contact tracing, deployment of safe management measures and other response measures that are necessary in the event of an emergency; and
3.19. any other purpose relating to or reasonably necessary for any of the above.
Relationship with OBF
In addition, depending on the nature of our relationship, OBF collects, uses and discloses your Personal Data for the following purposes:

4. Prospective Customers
4.1. assessing and processing any applications or requests made by you for products and services offered by OBF; and
4.2. any other purpose relating to or reasonably necessary for any of the above.

5. Employees, agents or owners of a referrer or other similar intermediaries
5.1. marketing and leads management;
5.2. processing commissions and remuneration; and
5.3. any other purpose relating to or reasonably necessary for any of the above.

6. Employees, officers or owners of an external service provider or vendor outsourced or prospected by OBF, or an independent contractor
6.1. managing project tenders or the supply of goods and services;
6.2. processing and payment of vendor invoices; and
6.3. any other purpose relating to or reasonably necessary for any of the above.

7. Parties or counterparties to a transaction (for example, a beneficiary of a fund transfer or payment)
7.1. providing cash, payment and transactional services (including the execution, settlement, reporting and/or clearing of the relevant transaction); and
7.2. any other purpose relating to or reasonably necessary for any of the above.

8. Persons who apply for positions with us
This paragraph applies to candidates who send in applications for employment or representative positions, and independent contractors, interns and trainees who apply for (or are put forward for) positions with us.

9.1 conducting interviews;
9.2. processing your application which includes pre-recruitment or pre-engagement checks involving your qualifications and facilitating interviews;
9.3. providing or obtaining employee references and for background screening;
9.4. assessing and evaluating your suitability for employment or engagement in any current or prospective position;
9.5. processing staff referrals;
9.6. verifying your identity and the accuracy of your personal details and other information provided; and
9.7. any other purposes relating to any of the above.

10. Employees, independent contractors, temporary staff, interns and trainees of OBF

This paragraph applies to all persons engaged in a contract of service or contract for service with us (such as independent contractors), and interns and trainees attached to us.

The purposes listed below apply to you during your relationship with us. They may continue to apply even when your relationship with us has been terminated or altered in any way.

10.1. performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;
10.2. reviewing salaries, remuneration and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluations, as well as recognising individuals for their services and conferring awards;
10.3. assessing and evaluating your suitability for employment or appointment, or continued employment or employment in any position in OBF, and conducting appraisals and evaluations;
10.4. administrative, human resources related and support processes relating to your employment or relationship with us, including managing and terminating your employment or appointment, staff benefits (including travel, workforce, business continuity and logistical management or support), processing expense claims, administering insurance applications, leave administration, training, learning and talent development, resolving grievances, and planning and organising corporate events;
10.5. investigating any acts or defaults or infringements of our internal or external compliance obligations (including managing insider trading risks);
10.6. providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;
10.7. ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
10.8. to understand risks in our workplaces, and ensure the safety, health and welfare of persons in our workplaces;
10.9. managing corporate social responsibility projects;
10.10. conducting analytics and research for human resource planning and management, and reviewing and developing work-related practices, environment and productivity;
10.11. ensuring that OBF’s operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed within OBF, your activities on such computer software and hardware, your internet access, your work e-mails and personal digital and storage devices);
10.12. performing obligations in connection with the provision of our goods or services to our clients;
10.13. contact tracing, operationalising safe management measures and other necessary measures in the event of an emergency;
10.14. administering cessation processes; and
10.15. any other purposes relating to any of the above.

11. OBF Board of Directors
11.1. facilitating appointments to the Board (including managing the publication of directors’ statistics on annual reports and circulars);
11.2. administrative matters (including the maintenance of statutory registers and lodgement of directors’ fees);
11.3. managing insurance programmes; and
11.4 any other purpose relating to or reasonably necessary for any of the above.

12.1. Combining your Personal Data with other personal data in our possession; and
12.2. Linking the Personal Data collected across your various relationships with OBF to facilitate your use of our various products and services.

13. Additional Purpose
Where allowed under applicable law, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data).
13.1. providing or marketing services, products and benefits to you (including promotions, loyalty and reward programmes) through various channels including direct marketing, e-mails, voice calls and phone number-based text messaging;
13.2. matching Personal Data with other data collected for other purposes and from other sources (including from our related corporations, business partners and third parties) in connection with the customisation, provision, improvement or offering of products, services, marketing or promotions, whether by OBF or other third parties;
13.3. administering contests and competitions,
13.4. personalising your experience at our various touchpoints, including our branches;
13.5. sending you information about products, services, special offers and rewards, either to our customers generally, or which we have found to be of interest to you; and
13.6. developing and enhancing existing and future products and services through testing, research, and analysis (including analysing behaviour, needs, preferences, location and demographics), and marketing, offering and providing those products and services to you.
We may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data in relation to particular products or services or in your interactions with us. If so, we will also collect, use and disclose your Personal Data for these purposes.

14. Disclosure of Personal Data
We take the confidentiality and disclosure of your Personal Data seriously. We will only share your Personal Data with selected third parties. When we disclose your personal data to such third parties, we require them to ensure that your personal data is kept confidential and secure. Your Personal Data may be disclosed for the purposes listed above (where applicable) to the following entities or parties, whether they are located overseas or in Singapore:
14.1. OBF’s related corporations, their respective employees, and our Representatives;
14.2. any person or Organisation providing electronic or other services to us;
14.3. counterparties and their respective banks concerning fund transfers, payments, drawing of cheques, and other transactions;
14.4. third-party recipients of bank reference letters;
14.5. companies providing services relating to insurance and reinsurance to OBF;
14.6. any person or Organisation (including agents, contractors, and third party service providers) to whom we outsource certain operational functions or activities, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to OBF;
14.7. vendors or other third party service providers in connection with marketing promotions and services offered by OBF;
14.8. analytics, search engine providers or other third party service providers that help us deliver, improve and optimise our products, services, websites and platforms.
14.9. credit reporting agencies;
14.10. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
14.11. other banks, financial institutions, credit agencies, credit card companies and their respective service providers;
14.12. third party referrers;
14.13. our co-brand, ecosystem partners and other business partners;
14.14. our professional advisers such as our auditors and lawyers;
14.15. relevant government regulators, ministries, statutory boards or authorities, law enforcement agencies and public officers, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, the Singapore Police Force, and the Insolvency and Public Trustee Office;
14.16. surveyors, auctioneers, valuers or other third parties concerning loans and other credit facilities such as mortgages;
14.17. universities for tuition fee loan reporting;
14.18. hotels, travel agents and foreign embassies for overseas travel arrangements for staff;
14.19. the Central Provident Fund Board (“CPF”) and its agent banks for CPF investment products, payment schemes and processing excess payment refunds;
14.20. brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles for asset management and investment product settlement processing;
14.21. Credit Counselling Singapore and collection and repossession agencies – to enforce repayment obligations for loans and other credit facilities;
14.22. foreign embassies and foreign credit reporting agencies – for credit reviews and the enforcement of repayment obligations for loans and other credit facilities;
14.23. external business and charity partners for corporate promotional events;
14.24. payee corporations, including telecommunications companies, the National Trades Union Congress, Singapore Press Holdings, local town councils and any other entities for processing the payment of bills;
14.25. commercial shops and retailers – to provide staff welfare benefits;
14.26. any swap repository, trade data repository, reporting agent, clearing house, centralised clearing party (including any clearing member of such clearing house or centralised clearing party), clearing broker, multilateral or other trading facility, system or platform or such other communication network or auction facility;
14.27. any other party to whom you authorise us to disclose your information or Personal Data; and
14.28. where reasonably necessary, to any person, Organisation, corporation, firm, partnership, limited partnership, limited liability partnership, society, association, trade union, institution or other business concern, whether local or foreign.

15. Retention of Personal Data
Your Personal Data will be retained if a purpose for which it was collected remains reasonable and for other legal or business purposes for which retention of your Personal Data may be necessary.

16. Other Bases for Handling or Processing your Personal Data
In addition to the consent you have provided to our collection, use and disclosure of your Personal Data, where permitted by applicable law, OBF may also collect, use and disclose your Personal Data without consent:
16.1. for our legitimate interests or a third party’s legitimate interests, such as:
improving anti-money laundering and financial crime risk management;
detection and prevention of fraud, financial crime, and other illegal activities;
detection of threats to safety and security (including IT and network security);
prevention of misuse of products and services;
16.2. performing credit analysis and other necessary due diligence checks; and
16.3. to improve the Companies’ products, services, processes or business, understand your preferences, and personalise experiences and recommendations (regardless of whether you are an existing or prospective customer of any of the Companies).

17. Use of Cookies and Related Technologies
Our websites and platforms use cookies, web beacons and other technologies. Cookies are small text files that a web server sends to a web browser and are stored by a browser, computing or other electronic devices. Your browser or device stores cookies, and the next time you visit our website or platform, your browser will read the cookie and relay the information back to the website, platform or element that initially set the cookie. Depending on the cookie type, user preferences and other information may be stored.
Web beacons (also known as pixel tags and clear GIFs) involve the use of unobtrusive graphics. Our websites or platforms may also use tracking links and similar technologies, which consist of a few lines of programming code. We may use web beacons in conjunction with cookies. This technology can also be used to track traffic patterns on websites and platforms, find out if an e-mail has been received or opened, and see if there has been any response.
We may employ cookies, web beacons and other technologies for the following purposes:
17.1. when it is necessary to run our websites and platforms, such as identifying you when you log in and navigate our websites and platforms, and determining your login status;
17.2. customising our website, personalising content for you, and understanding and remembering your interests and preferences;
17.3. enhancing, analysing and optimising the use, effectiveness and performance of our website and platforms;
17.4. displaying advertising that is as relevant to you as possible and understanding the effectiveness of our advertisements; and
17.5. collating information on a user’s browsing history on OBF’s websites and platforms.
Some cookies we use are from third-party service providers that provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and other OBF online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors. For more information, please refer to the following links:
Facebook Pixel
Adobe Analytics
If you do not agree to such use of cookies, you may delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may be unable to enter certain parts of our websites or platforms. This may also affect your user experience while on our websites or platforms. Unless you have adjusted your browser settings to block cookies, our system will issue cookies when you visit our websites or platforms or click on a link in a targeted e-mail we send, even if you have previously deleted our cookies.

18. Security
OBF has put in place safeguards to protect your Personal Data. This includes an organisation-wide data protection management programme to ensure data protection compliance and risk management. As part of this programme, we have ensured that all our staff have been trained to protect Personal Data. Regular internal and external audits of our data protection compliance are also conducted. A breach of our data protection policies could result in disciplinary action.

19. Third-Party Sites
Our website may contain links to third-party websites. We are not responsible for the privacy practices of such websites. If you visit these third-party websites, you should review their privacy policies. Some of these third-party websites may be branded with the OBF logo, even if we do not operate or maintain them.

20. Contacting Us
To contact our Data Protection Office regarding your Personal Data, our Data Protection Policy (including our reliance on legitimate interests), withdrawal of your consent, or obtaining access and making corrections to your Personal Data records, please get in touch with us:
email: dpo@obf.com;
You may withdraw your consent for collecting, using and disclosing your Personal Data. If you withdraw your consent, OBF may not be able to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may result in the termination of any agreements you have with OBF and your breach of contractual obligations or undertakings. In such an event, we reserve our legal rights and remedies.
Please note that if a third party provided your Personal Data to us, you should contact such third party directly to make any queries, feedback, and access and correction requests to us on your behalf.

21. Governing Law
This Data Protection Policy and your use of this website shall be governed by the laws of Singapore.