We are committed to protecting your Personal Data. We want to ensure that you are fully informed about how we manage your Personal Data. This means we must be clear about how we collect, use, and disclose your Personal Data. Providing your Personal Data to us is voluntary. If you do not provide your Personal Data to us, we may not be able to provide you with our products and services.

We have a data protection management program in place to protect your Personal Data. This includes:

• implementing strong security measures;
• conducting data protection impact assessments;
• regularly training our staff;
• ensuring that recipients of Personal Data protect it;
• helping you exercise your rights;
• answering your questions on the use of your Personal Data; and
• helping you control marketing messages from us. 

What is Personal Data?

Personal Data is any data about an individual that identifies the individual, or that can identify the individual when combined with other information. Examples include your:

• name;
• contact information; and
• financial details.

Collecting your Personal Data

We will only collect your Personal Data when we have a legal or valid reason to do so. Examples of how we collect your Personal Data include when you:

• use our banking and digital services; 
• speak with our staff at our branches; or
• attend our events.

Using your Personal Data

We may use your Personal Data for various purposes, such as:

• confirming your identity;
• improving our products and services;
• contacting you about our services or products; and
• when we have a legitimate interest (such as detecting and preventing fraud or crime).

Disclosing your Personal Data

We take the disclosure of your Personal Data seriously. We will only share your Personal Data with responsible persons and organisations. If necessary, we may transfer your Personal Data overseas. When we share your Personal Data, we ensure that the recipients can keep it confidential. Examples of entities with whom we may share your Personal Data include:

• other OCBC Group companies; 
• our partners and vendors; and
• government agencies.

We have an ongoing responsibility to protect your Personal Data. We will update this Data Protection Policy from time to time. We will inform you of changes to this Data Protection Policy through appropriate means.

For more details, please refer to our Data Protection Policy below. If you have any questions, please contact our Data Protection Office at dpo@ocbc.com.

Depending on your relationship with us, the following Data Protection Policies may apply:

1. Personal Banking Data Protection Policy; and
2. Business Banking Data Protection Policy.

Data Protection Policy
Effective: 04 June 2024

The purpose of this document ("Data Protection Policy") is to inform you of how Oversea-Chinese Banking Corporation Limited and its related corporations (collectively, the "Companies"), and their respective representatives and agents ("Representatives") (the Companies and Representatives collectively referred to as "OCBC", "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.ocbc.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 and the OCBC products and services you use. Some examples of Personal Data include:

1.1. your full name;

1.2. NRIC, passport or other identification number;

Employee email address;

1.4. your location;

1.5. customer information (e.g. deposit information);

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. The provision of your personal data is voluntary. If you do not provide your personal data to us, we may not be able to provide you with requested products and services. 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 (including customer service officers, relationship managers, and our automated systems for example, via telephone calls (which may be recorded), letters, online 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 marketing representatives and agents and other service providers;

2.8. when you send an employment 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 (including for banking products, insurance policies or job applications) 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 use our Electronic Banking Services, such as OCBC Phone Banking Service, OCBC ATM Service or OCBC Internet Banking Service. For more information, refer to https://www.ocbc.com/personal-banking/terms-and-conditions/terms-and-conditions-governing-electronic-banking-services.page;

2.14. when you use our mobile and digital applications (“Digital Services”). These Digital Services include STACK and HealthPass by OCBC and;

2.15. when you give us consent to collect your Personal Data from your mobile device (e.g. location information); and

2.16. 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 customers, 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. OCBC collects, uses and discloses your Personal Data for the following purposes:

3.1. managing and responding to 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 CCTV surveillance 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, assisting law enforcement or investigations by relevant authorities, and complying with listing and other requirements or directions of the Singapore Exchange Limited and/or any other relevant securities exchange;

3.18. responding to an emergency; and

3.19. any other reasonable purpose relating to the above.

Relationship with OCBC

In addition, depending on the nature of our relationship, OCBC collects, uses and discloses your Personal Data for the following purposes:

4. Prospective Customers

4.1. evaluating your financial and banking needs and providing recommendations to you;

4.2. assessing and processing any applications or requests made by you for products and services offered by OCBC; and

4.3. any other reasonable purpose relating to the above.

5. Retail Banking Customers, Private Investors, Beneficial Owners, Guarantors, Security Providers, or Appointed Representatives (including a Mandate Holder or a Power of Attorney)

5.1. opening, maintaining or closing your accounts, and establishing or providing banking services to you;

5.2. if an account or relationship manager, or agent has been assigned to service your account or portfolio, using your telephone number to contact you to take your instructions, and provide you with information, updates, or recommendations per the terms and conditions of our agreement with you;

5.3. facilitating the continuation or termination of the banking relationship, the daily operations of services and credit and trading facilities, and providing client servicing (including responding to requests by customers, providing mailing, conveyancing, reporting, clearing and reconciliation services, investigating discrepancies, errors or claims, and providing customer satisfaction);

5.4. conducting client reviews (for example, annual reviews of your portfolio);

5.5. to establish your financial situation, risk profile, investment experience and investment goals, and help you consider the suitability of the products you have invested or intend to invest;

5.6. providing Electronic Banking Services;

5.7. facilitating the transfer of funds within OCBC banking accounts or from OCBC accounts to external banking accounts and vice versa;

5.8. ensuring the ongoing creditworthiness of customers;

5.9. administering exceptional approvals, fee adjustments or waivers;

5.10. managing investment products (including unit trusts, treasury products, shares, commodities, foreign exchange, Supplementary Retirement Scheme, initial public offerings or CPF investment accounts, and other investment products which OCBC may make available from time to time) and providing custody services;

5.11. customer outreach and relationship management;

5.12. 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 but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and customer due diligence);

5.13. archival management (including warehouse storage and retrievals);

5.14. administering credit, debit, charge, ATM and other cards (including processing card applications, transactions, credit limit approvals and enquiries);

5.15. providing cheque deposit and issuance services;

5.16. providing loans and overdraft facilities (including the evaluation of credit risks and enforcement of repayment obligations);

5.17. administering bancassurance products (including the maintenance, management and operation of the products and services, communication with policyholders, and processing of any claims and payments arising under the respective policies);

5.18. administering fund services (including maintaining, managing and operating the services, and communicating with investors);

5.19. administering and facilitating any offer of or other transactions dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and

5.20. any other reasonable purpose relating to the above.

6. Bancassurance Customers

6.1. processing your insurance application;

6.2. administering, maintaining, managing and operating the products and services offered to you, including reinsured products by other companies and government-driven schemes;

6.3. sending updates and administrative notices to you regarding the products and services used by you, including notification of maturity of payments and maturity of policies;

6.4. underwriting of policy risks;

6.5. assessing and processing any claims arising under your policy;

6.6. collecting premiums and debt collection; and

6.7. any other reasonable purpose relating to the above.

7. Employees, Business Partners, Sole Proprietors, Investors, Proxy Voters, Corporate Shareholders, Guardians, Directors, Nominee Directors, Chargors, Sureties or Guarantors, Agents or Representatives of an Organization that is a Business Banking Customer or has a corporate relationship with OCBC

7.1. opening or continuation of accounts, and establishing or providing banking services;

7.2. facilitating the daily operation of services, and credit and trading facilities (including providing loans, gathering deposits, transferring funds, processing trades, reporting and clearing of trades, updating contact details of investors and investees, corporate action processing and entering into related ancillary arrangements);

7.3. facilitating the continuation or termination of the banking relationship (including the closing of accounts);

7.4. managing investment banking (including capital markets, corporate finance services and financing by mezzanine capital services);

7.5. managing investment products (including unit trusts, treasury products, shares, commodities, foreign exchange, and other investment products which OCBC may make available) and providing custody services;

7.6. networking to maintain customer relationships;

7.7. providing client servicing (including providing customer satisfaction, proxy voting and merchant servicing);

7.8. facilitating and conducting due diligence checks;

7.9. administering fund services (including the maintenance, management and operation of the services, and communication with investors);

7.10. processing commissions and remuneration for sales representatives;

7.11. administering corporate or business credit, debit, and other cards (including processing card applications, transactions and credit limit approvals);

7.12. providing loans and overdraft facilities (including evaluating credit risks and enforcement of repayment obligations);

7.13. administering and facilitating any offer or other transaction dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and

7.14. any other reasonable purpose relating to the above.

8. Employees, Agents or Owners of a Referrer or other similar intermediaries

8.1. marketing and leads management;

8.2. processing commissions and remuneration; and

8.3. any other reasonable purpose relating to the above.

9. Employees, officers or owners of an external service provider or vendor outsourced or prospected by OCBC, or an independent contractor

9.1. managing project tenders or the supply of goods and services;

9.2. processing and payment of vendor invoices; and

9.3. any other reasonable purpose relating to the above.

10. OCBC shareholders

10.1. maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars;

10.2. providing shareholding listings for preference shares, subordinated debt and senior term issuances;

10.3. facilitating the implementation of projects (including seeking approvals for new investments, additional fundraising exercises or bonuses);

10.4. processing claims (including processing claims for unclaimed cash distribution); and

10.5. any other reasonable purpose relating to the above.

11. Parties or counterparties to a transaction (for example, a beneficiary of a fund transfer or payment)

11.1. providing cash, payment and transactional services (including the execution, settlement, reporting and/or clearing of the relevant transaction); and

11.2. any other reasonable purpose relating to the above.

12. 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.

12.1 conducting interviews;

12.2. processing your application which includes pre-recruitment or pre-engagement checks involving your qualifications and facilitating interviews;

12.3. providing or obtaining employee references and for background screening;

12.4. assessing and evaluating your suitability for employment or engagement in any current or prospective position;

12.5. processing staff referrals;

12.6. verifying your identity and the accuracy of your personal details and other information provided; and

12.7. any other reasonable purpose relating to the above.

13. Employees, independent contractors, temporary staff, interns and trainees of OCBC

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.

13.1. performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;

13.2. reviewing salaries, remuneration and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluations, as well as recognising individuals for their services and conferring awards;

13.3. assessing and evaluating your suitability for employment or appointment, or continued employment or employment in any position in OCBC, and conducting appraisals and evaluations;

13.4. 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;

13.5. investigating any acts or defaults or infringements of our internal or external compliance obligations (including managing insider trading risks);

13.6. providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;

13.7. ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;

13.8. to understand risks in our workplaces, and ensure the safety, health and welfare of persons in our workplaces;

13.9. managing corporate social responsibility projects;

13.10. conducting analytics and research for human resource planning and management, and reviewing and developing work-related practices, environment and productivity;

13.11. ensuring that OCBC’s operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed within OCBC, your activities on such computer software and hardware, your internet access, your work e-mails and personal digital and storage devices);

13.12. performing obligations in connection with the provision of our goods or services to our clients;

13.13. responding to an emergency;

13.14. administering cessation processes; and

13.15. any other reasonable purpose relating to the above.

14. OCBC Board of Directors

14.1. facilitating appointments to the Board (including managing the publication of directors' statistics on annual reports and circulars);

14.2. administrative matters (including the maintenance of statutory registers and lodgement of directors' fees);

14.3. managing insurance programmes; and

14.4 any other reasonable purpose relating to the above.

15. Users of Digital Service

Our Digital Services and their respective data protection policies are listed below:

1. STACK

When you use our Digital Services, you may also be subject to the Data Protection Policies of our various ecosystem partners. Please read those Data Protection Policies carefully. OCBC collects, uses and discloses your Personal Data for the following purposes:

15.1. to provide, personalise, facilitate and improve your use of our Digital Services. ;15.2. to authenticate and verify your identity;

15.3. to market OCBC and our ecosystem partners’ services, events and products; and

15.4. any other reasonable purpose relating to the above.

16. Users with multiple relationships with OCBC

This paragraph applies if you have multiple relationships with us (for example, if you use our Digital Services and Electronic Banking Services).

16.1. Combining your Personal Data with other personal data in our possession; and

16.2. Linking the Personal Data collected across your various relationships with OCBC to facilitate your use of our various products and services.

16.3 Depending on your relationship with OCBC, the following data protection policies may also apply:

• Business Banking Data Protection Policy
• China - Privacy Policy (Retail Banking) 
• China - Privacy Policy (Corporate Banking) 
• Hong Kong - Privacy Policy and Personal Information Collection Statement 
• Malaysia – Security and Privacy
• Thailand – Personal Data Protection Notification
• US Agencies – CCPA/CPRA Compliance Privacy Policies
• Vietnam - Data Protection Annex

17. 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).

17.1. 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;

17.2. 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 OCBC or other third parties;

17.3. administering contests and competitions,

17.4. personalising your experience at our various touchpoints, including our branches;

17.5. sending you information about products, services, offers and rewards; and

17.6. 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 specific products or services, or in your interactions with us. If so, we will also collect, use and disclose your Personal Data for these purposes.

18. 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:

18.1. OCBC’s related corporations, their respective employees, and our Representatives;

18.2. any person or Organisation providing electronic or other services to us;

18.3. counterparties and their respective banks concerning fund transfers, payments, drawing of cheques, and other transactions;

18.4. third-party recipients of bank reference letters;

18.5. companies providing services relating to insurance and reinsurance to OCBC;

18.6. 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 OCBC;

18.7. vendors or other third-party service providers in connection with marketing promotions and services offered by OCBC;

18.8. analytics, search engine providers or other third-party service providers that help us deliver, improve and optimise our products, services, websites and platforms.

18.9. credit reporting agencies;

18.10. 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;

18.11. other banks, financial institutions, credit agencies, credit card companies and their respective service providers;

18.12. third party referrers;

18.13. our co-brand, ecosystem partners and other business partners;

18.14. our professional advisers such as our auditors and lawyers;

18.15. 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;

18.16. surveyors, auctioneers, valuers or other third parties concerning loans and other credit facilities such as mortgages;

18.17. universities for tuition fee loan reporting;

18.18. hotels, travel agents and foreign embassies for overseas travel arrangements for staff;

18.19. the Central Provident Fund Board ("CPF") and its agent banks for CPF investment products, payment schemes and processing excess payment refunds;

18.20. 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;

18.21. Credit Counselling Singapore and collection and repossession agencies - to enforce repayment obligations for loans and other credit facilities;

18.22. foreign embassies and foreign credit reporting agencies - for credit reviews and the enforcement of repayment obligations for loans and other credit facilities;

18.23. external business and charity partners for corporate promotional events;

18.24. 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;

18.25. commercial shops and retailers – to provide staff welfare benefits;

18.26. 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;

18.27. any other party to whom you authorise us to disclose your information or Personal Data; and

18.28. where 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.

19. 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.

20. 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, OCBC may also collect, use and disclose your Personal Data without consent:

20.1. for our or a third-party’s legitimate interests such as:

1. improving anti-money laundering and financial crime risk management;
2. detection and prevention of fraud, financial crime, and other illegal activities;
3. detection of threats to safety and security (including IT and network security);
4. prevention of misuse of products and services;

20.2. performing credit analysis and other necessary due diligence checks;

20.3. 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); and

20.4 Pursuant to exceptions, or when required or authorised to under applicable laws.

21. Use of Cookies and Related Technologies

Our websites and platforms use cookies, web beacons and related technologies. Cookies are files stored on your web browser or electronic device. They are used to enable certain functions on our website, such as remembering your preferences and other information. The next time you visit our website or platform, your browser will read the cookie and relay the information back to the website or platform that set the cookie.

Web beacons are unobtrusive graphics that monitor your interactions with our websites and platforms. Our websites or platforms may also use tracking links to help us understand your preferences. 

These technologies can 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 related technologies for the following purposes:

21.1. to run our websites and platforms, such as enabling you to log in and navigate our websites and platforms;

21.2. understanding and remembering your preferences;

21.3. enhancing the use, effectiveness and performance of our website and platforms;

21.4. displaying advertising that is relevant to you and understanding the effectiveness of our advertisements; and

21.5. collating information on a user’s browsing history on OCBC’s websites and platforms.

Some cookies we use are from third-party web analytics and intelligence providers. We use such information to compile statistics about visitors who interact with our websites, platforms and online content, to gauge the effectiveness of our communications, and to provide better 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 the cookies or change the settings on your browser accordingly. For information on configuring your web browser, please refer to:

• Chrome
• Safari
• Edge

Please note that this may affect your user experience and you may be unable to enter certain parts of our websites or platforms. 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.

22. Artificial Intelligence

We’re constantly innovating to enhance your banking experience, ensuring that it is seamless and secure. Our use of various technologies, like artificial intelligence, actively guards against fraud, streamlines our communications with you, tailors our offerings to fit your needs and ensures that we offer you suitable products and services.

For in-depth insights into our use of artificial intelligence, please refer to our Artificial Intelligence Policy.

23. Security

OCBC 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.

While we strive to protect your Personal Data, there are risks when electronic services are used. For tips on securing your Personal Data, please refer to the Online Banking Security and Malware Notification sections.

24. 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 OCBC logo, even if we do not operate or maintain them.

25. 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 contact us:

• email: dpo@ocbc.com;
• phone: 1800 363 3333; or
• talk to our staff at any of our branches.

You may withdraw your consent for collecting, using and disclosing your Personal Data. If you withdraw your consent, OCBC 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 OCBC 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 (e.g. The Central Depository (Pte) Limited), you should contact such third party directly to make any queries, feedback, and access and correction requests to us on your behalf.

26. Governing Law

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

1. Introduction

   The purpose of this document is to detail the Best Execution policy (“BE Policy”) of Oversea-Chinese Banking Corporation Limited (“OCBC Bank”) when executing orders in respect of certain financial instruments within the scope of requirements imposed by applicable laws and regulations in the locations we operate in.

2. Scope

   The BE Policy applies to all OCBC Bank offices where they conduct regulated activities under the Securities and Futures Act (“SFA”) or their staff are appointed representatives under the SFA, and excludes subsidiaries of OCBC Bank.

   The BE Policy will set the guiding principles for OCBC Bank’s best execution processes. In case of conflicts or inconsistencies, local regulatory requirements would prevail.

3. Governance & Management Supervision

   We will monitor best execution arrangements on an on-going basis (at least annually) to identify and implement any appropriate enhancements.

   OCBC Bank reserves the right to amend this document from time to time as it deems necessary. Any material changes to the BE Policy shall be updated here.

4. Applicability of best execution

   This document applies with respect to all financial instruments within the scope of “best execution” as prescribed by the regulators in the locations we operate.

   We have in place a policy and framework which are designed for OCBC Bank to try deliver the best possible execution for our clients, subject to the financial instrument and taking into account the nature of the client’s orders, the execution venues available for such financial instruments and the priorities the client places upon us to execute those orders. While OCBC Bank will take all reasonable steps to achieve best execution, OCBC Bank does not guarantee that it will be able to achieve best execution for every transaction or confirm that every transaction will be executed in full.

5. Policy requirements

   OCBC Bank shall take into account the following factors when executing your order:

   1. Price;
   2. Costs;
   3. Speed;
   4. Likelihood of execution;
   5. Likelihood of settlement;
   6. Size of the order(s);
   7. Nature of the order(s);
   8. Other aspects of the order(s).

   Notwithstanding this, there are certain situations in which these factors will change. These may include, but are not limited to, the following:

   1. Type of order;
   2. Type of product;
   3. Specific instructions that the customer provides;
   4. General prevailing conditions in the market at the time of the order.

6. Specific instructions

   Where specific instructions are given by you regarding the execution of an order or a part of the order, OCBC Bank will ensure to execute your order in accordance with those instructions. In this circumstance, OCBC Bank will consider itself as having satisfied its best execution obligations with respect to the part of your order to which the instruction relates, when those instructions have been carried out as specifically requested.

   In circumstances where specific instructions are given, these instructions may result in an execution that is less satisfactory than what may have been achieved in the absence of the instruction.

   Where you provide specific instructions covering only part of an order, OCBC Bank will not consider itself released from its best execution obligations for the parts of the order which are not covered by the instructions. In this case, OCBC Bank will comply with our BE policy in respect of that part of the trade not covered by the instructions.

   Where specific instructions given by you cannot be followed, OCBC Bank will inform you of the reasons before executing your order(s).

7. Order handling

   We have further procedures in place to ensure we execute and allocate your orders promptly and fairly, taking into account the need to manage any potential conflicts of interest that may exist between you, ourselves and our other clients.

   We will execute your order in line with other comparable client orders sequentially and promptly, unless (i) the characteristics of your order or prevailing market conditions make this impracticable; or (ii) your interests require otherwise.

   Where you do not provide specific instructions, we will execute and allocate the order as soon as reasonably practicable.

   When executing your order, we may decide to aggregate the order with a transaction for our own account or that of another client. Such aggregation will be taken, for example, to provide a better price to you or to reduce transaction costs by allowing us to execute in a larger size. We will only aggregate your order if it is unlikely that the aggregation will work overall to your disadvantage. Where we are unable to fill an aggregated order in full, we will allocate the executed notional on a fair and equitable basis.

   We will endeavour to communicate the order execution and allocation status of the order to you as soon as reasonably practicable.

8. Matters outside of the Bank's control

   In some cases, whether as a result of system failures, disrupted markets or otherwise, it may be necessary to execute client orders in a different manner as documented for the financial instrument in question. In such circumstances, the transacting unit will still seek to achieve the best possible result available in the prevailing circumstances.

9. Contact details for your questions

   For queries, please contact your Relationship Manager.

Effective 1 January 2017

1. Definitions and Interpretation

In this CRS Policy, the following capitalised terms have the following meaning:

"Account Information" means any information relating to any account of a Customer with OCBC Bank including without limitation (and if applicable):

1. the account number;
2. account balance or value;
3. currency denomination;
4. gross receipts;
5. withdrawals and payments to or from the account;
6. the total gross amount of interest paid or credited to the account;
7. the total gross amount of interest, dividends and other income generated with respect to the assets held in the account, in each case paid or credited to the account or with respect to the account;
8. the total gross proceeds from the sale or redemption of property paid or credited to the account; and
9. the total gross amount paid or credited to the Customer with respect to the account, including the aggregate amount of any redemption payments made to the Customer.

"Applicable Laws and Regulations" mean any of the following that currently or in the future apply to OCBC Bank (i) local or foreign laws, ordinances, regulations, demands, guidance, orders, guidelines, rules and codes of practice, including whether or not relating to an intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions; and (ii) any agreement between OCBC Bank and any government or taxation authority in any jurisdiction; and including but not limited to the CRS.

"Authority" means any national, state, or local government, any political subdivision thereof, any agency, authority, instrumentality, whether judicial or administrative, regulatory or self-regulatory organisation, law enforcement body, court, central bank or tax or revenue authority in any jurisdiction whether within or outside of Singapore.

"Controlling Person" means any natural person who exercises control over a legal person or a legal arrangement, such as a corporation, partnership, trust or foundation. In the case of a trust, such term means the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control over the trust, and in the case of a legal arrangement other than a trust, such term means persons in equivalent or similar positions. The term "Controlling Person" must be interpreted in a manner consistent with the Financial Action Task Force Recommendations. Where no natural person or persons is or are identified as exercising control of the entity through ownership interests, the controlling person of the entity is deemed to be the natural person who holds the position of senior managing official.

"CRS" means the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the Organisation for Economic Co-operation and Development and any associated similar or analogous legislation, treaty, regulation, instruction or other official guidance of any Authority in any jurisdiction.

"Customer" means the Person who has a relationship with OCBC Bank in connection with the Services, whether alone or jointly with any other Person and, in the case of a corporation, shall include its successors and in the case of a partnership or other unincorporated entity consisting of two or more Persons, its successors, executors and personal representatives.

"OCBC Bank" means Oversea-Chinese Banking Corporation Limited and shall include its successors and assigns.

"Person" means an individual, corporation, company, partnership, joint venture, trust, estate, limited liability company, unincorporated organisation or other entity.

"Personal Information" in respect of a Customer and any Controlling Person, means: (i) where the Customer and any Controlling Person is an individual, his/her full name, date and place of birth, residential address, mailing address, hold mail instruction or in-care-of address, contact information (including telephone number), and any taxpayer identification number (or functional equivalent), (if applicable) social security number, citizenship(s), standing instructions to transfer funds to an account, power of attorney or signatory authority granted to any person, residency(ies) and tax residency(ies) or (if applicable) such other information as OCBC Bank may reasonably require regarding such Customer and any Controlling Person; (ii) where the Customer and any Controlling Person is a corporate/entity, its full name, date and place of incorporation or formation, address, registered address, address of place of business, tax identification number (or functional equivalent), , tax status, tax residency, financial statements, registered address, address of place of business, certification of its CRS status/classification, whether it is a passive NFE (as that term is defined by Applicable Laws and Regulations) with one or more Controlling Persons, or (if applicable) such other information as OCBC Bank may reasonably require regarding each of its substantial shareholders and controlling persons.

"Services", in relation to a Customer, means, without limitation, (i) the opening, maintaining and closing of bank accounts; (ii) the issuing, maintaining, administering and terminating of insurance policies; (iii) the provision of any banking or financial services and products (including without limitation, private banking services, credit facilities, credit card services, loans, brokerage, investment banking services, corporate finance services, provision of mezzanine capital, capital market services, services in respect of treasury products and financial derivatives transactions); (iv) relationship maintenance between OCBC Bank and the Customer (including without limitation marketing and promoting banking or financial services or products); and (v) any other acts or materials of OCBC Bank ancillary to, in furtherance of or in connection with any of the (i) to (iv) above (including without limitation research and analysis).

"Tax Information" in respect of a Customer and any Controlling Person, means: (i) any documentation or information (and accompanying statements, forms, representations, waivers and consents as OCBC Bank may from time to time require or as the Customer and any Controlling Person from time to time give) relating, directly or indirectly, to the tax status of the Customer and any Controlling Person; (ii) Personal Information of the Customer and any Controlling Person; (iii) Account Information; and (iv) any other information received by OCBC Bank in relation to the Customer, including (but not limited to) information collected and maintained pursuant to AML/KYC procedures.

2. Tax Compliance Provisions

2.1 Provision of Information

1. The Customer must provide OCBC Bank with the Customer's Personal Information, and where reasonably required by OCBC Bank, the Personal Information of any Controlling Person, in such form and within such time, as OCBC Bank may from time to time require.
2. When there is a change or addition to the Personal Information of the Customer and (where applicable) any Controlling Person, the Customer must update OCBC Bank promptly (and in any event no later than 30 days from the date of the change or addition) of the change or addition if the Customer has not done so already.
3. The Customer must, and, where applicable, procure such Controlling Person to, complete and sign such documents and do such things as OCBC Bank may reasonably require from time to time for purposes of OCBC Bank's compliance with Applicable Laws and Regulations.
4. The Customer agrees that OCBC Bank may directly require any Controlling Person to provide or confirm the accuracy of their Personal Information without involving the Customer if OCBC Bank reasonably considers it appropriate.

2.2 Disclosure of Information

1. The Customer agrees that OCBC Bank may disclose the Customer's Tax Information and the Tax Information of any Controlling Person to any Authority in any jurisdiction for the purpose of ensuring OCBC Bank's compliance with Applicable Laws and Regulations.
2. The Customer waives, and, where reasonably required by OCBC Bank, agrees to procure any Controlling Person to waive, any applicable restrictions that would otherwise hinder OCBC Bank's ability to disclose Tax Information to comply with Applicable Laws and Regulations, and in particular, to disclose Tax Information in the manner described in 2.2a.
3. The Customer agrees that OCBC Bank may directly require any Controlling Person to agree to the disclosure described in 2.2a and/or waive any otherwise applicable restrictions on such disclosure, if OCBC Bank reasonably considers it appropriate.

2.3 Failure to Provide Information

The Customer agrees that:

1. where the Customer fails to comply with its obligations under 2.1 or 2.2 above; or
2. where any Controlling Person fails to comply with OCBC Bank's requirements set out in 2.1 or 2.2 above; or
3. where the Personal Information (regardless of whether such Personal Information is in relation to the Customer or any Controlling Person) is inaccurate, incomplete, misleading or is not promptly updated; or
4. for whatever reason OCBC Bank is prevented (under Singapore law or otherwise) from disclosing the Tax Information of the Customer and/or any Controlling Person(s) to the relevant Authority as may be required by Applicable Laws and Regulations,

OCBC Bank may take one or more of the following actions at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations:

1. refuse to provide new Services to the Customer;
2. terminate the Customer's account(s) with OCBC Bank;
3. discontinue entirely or in part OCBC Bank's relationship with the Customer;
4. provide (whether before or after taking actions as described in items 2 and 3 of this section) the Tax Information relating to the Customer and/or any Controlling Person to an Authority in any jurisdiction.

3. Customer Confirmations

By using or accepting the Services, the Customer confirms and agrees that:

1. without prejudice to the applicable terms and conditions governing the relationship between OCBC Bank and the Customer, the Customer confirms that the Customer has read this CRS Policy, has received adequate explanation, and understands the implications of this CRS Policy by which the Customer irrevocably agrees to be bound;
2. any agreement, waiver, representation and/or confirmation given in, or to be given pursuant to, this CRS Policy is irrevocable;
3. OCBC Bank is not liable for any costs or loss that the Customer (or any Controlling Person) may incur because of OCBC Bank taking any actions permitted by or exercising any powers under this CRS Policy;
4. any withdrawal or payment amount made by OCBC Bank pursuant to any Services shall be subject to this CRS Policy;
5. the Customer must obtain or, as the case may be, have obtained the requisite consent from each Controlling Person for the provision of his or her Tax Information to OCBC Bank and the disclosure of any of such Tax Information by OCBC Bank under this CRS Policy and the Customer must inform each Controlling Person of OCBC Bank's powers under this CRS Policy;
6. this CRS Policy is without prejudice, and in addition, to OCBC Bank's rights or powers under the terms and conditions governing the relationship between the Customer and OCBC Bank.

4. General

1. In the event of any conflict or inconsistency between any of the contents of this CRS Policy and other terms and conditions that govern the Customer relationship with OCBC Bank, this CRS Policy shall prevail.
2. Notwithstanding any other terms and conditions that govern the Customer's relationship with OCBC Bank (including but not limited to amendments or modification provisions of such terms and conditions), OCBC Bank may amend, update, and revise this CRS Policy unilaterally at any time as may be required by OCBC Bank to ensure its compliance with Applicable Laws and Regulations.
3. If all or any part of this CRS Policy is illegal, invalid or unenforceable in any respect under the law of any jurisdiction, that shall not affect or impair the legality, validity or enforceability of such provision in any other jurisdictions or the remainder of this CRS Policy in that jurisdiction.
4. It is the Customer's and each Controlling Person's responsibility to obtain independent professional advice from adequately qualified legal or tax advisors on its obligations under and the consequences of this CRS Policy. OCBC Bank do not provide tax or legal advice and are unable to advise Customers and/or Controlling Persons regarding the US federal income tax or other tax consequences that may be applicable to them in the Customer's (or the relevant Controlling Person's) particular circumstances.