Privacy Policy

1. General

Orel One Pte Ltd and its affiliates and associates (“Orel” or “we” or “us”) is the controller of the processing of all personal data collected through this website dedicated to the Orel Group of companies (the “Website”). Orel respects your privacy and is committed to keeping your Personal Data secure and managing it in accordance with our legal responsibilities under applicable data protection laws.

Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us or that we collect otherwise in the context of the Website (“Personal Data”).

2. Data Protection Officer

Our Data Protection Officer oversees how we collect, use, distribute and secure your information to ensure your rights are respected. Our Data Protection Officer can be contacted at dpo@orel.com.

3. What Personal Data We Collect and How We Use your Personal Data

You can use the majority of our Website without being required to provide any Personal Data to us. For certain services or activities you will need to provide Personal Data for us to be able to provide you the requested service or product or for you to participate in the activity. Requested information on the Website marked with an asterisk is mandatory. If you do not provide the requested information, we will not be able to deliver the service or product to you or you cannot participate in the activity. In addition to information you are required to provide to us in order to participate in activities/campaigns, we collect certain information when you visit our Website.

3.1. Information when you contact us

We collect certain information when you visit our Website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, clicks and views. We use this Personal Data as it is necessary in our legitimate interests to do so to be able to promote our products and services to our consumers and website visitors, to enable us to attract more consumers, to improve the sale of our products and services, and to identify what companies have interacted with the website. We will retain the Personal Data for a maximum of 14 months. We use your IP address to track traffic flows and to make our websites easier for you to use and to better understand how our websites are used.

3.2. Marketing

Most of our processing is permitted by "legal grounds" other than consent. In relation to Direct Marketing, where we are required to do so, we will obtain your consent before using your Personal Information for this purpose. If you prefer not to receive our Direct Marketing communications and/or not have your Personal Information shared among the members of the Orel group for the purpose of marketing, you can have your name deleted from our Direct Marketing and/or shared information lists.

Direct Marketing means our communication with you such as mail, telemarketing or email, using your contact information, to inform you about products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.

3.3. Maintenance and optimisation of our Website

Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, to improve the availability and user experience. We log all use of our Website.
Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for a maximum period of 14 months. The logs of the use of our Website will be deleted within 14 months after creation.

4. How We Share Your Personal Data

We will only use or disclose your Personal Information for the purpose(s) it was collected and as otherwise identified in this Privacy Policy.

4.1. Sharing outside the Orel Group

Personal Information may be provided to third parties, including anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or for the protection of our assets (for example, collection of overdue accounts).

4.2. Sharing within the Orel Group

We may share your Personal Information within the Orel Group, where we do business, for marketing purposes, for legal and regulatory purposes, to manage credit risk and other business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.

4.3. Business sale or reorganization

Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with any accounts, products or services of the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganization or other change in corporate control.

4.4. Sub-contractors and agents

We may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed.

5. Security of Personal Data

We will take appropriate technical, physical and organizational measures to protect the Personal Data collected through the Website from misuse or accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, acquisition or access, that are consistent with applicable privacy and data security laws and regulations. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Our Website may contain links to other websites. We are not responsible for the privacy practices, content or security used by such other websites, which shall not be governed by this Privacy Policy. We advise you to always carefully read the privacy policies on these other websites.

6. Retention of Your Personal Data

We will retain your Personal Data for as long as legally required or for as long as necessary to provide you with any requested services or for any of the other purposes listed in this Privacy Policy. The specific retention term are listed in this Privacy Policy for each of the relevant purposes. We will take reasonable steps to destroy or de-identify Personal Data we hold if it is no longer needed for the purposes set out above or after the expiration of the defined retention term.

7. Cookies

A major part of the information referred to in this Privacy Policy is collected via our use of cookies and similar techniques. Cookies are small text files containing small amounts of information which are downloaded and may be stored on your user device, e.g. your computer, smartphone or table. Techniques we use that may be similar to cookies are tracking pixels, Java scripts, tags and web beacons. These cookies and similar techniques are sometimes necessary to remember your account settings, language and country, but also enable us to measure and analyse your behaviour on our Website and for showing you personalised advertisements on our Website or on third party websites. Where required, you will be asked for consent to our use of cookies.

8. Social Media

You may choose to share information on our Website via social media, such as Facebook, Instagram, LinkedIn and YouTube. This means that the information you share, with name and preferences, shall be visible to visitors of your personal pages. We advise you to carefully read the privacy policies of the social media parties as these are applicable to the processing of your Personal Data by these parties.

9. Your Rights to Access, Rectification, Deletion, Restriction and Data Portability

You have the right to request an overview of your Personal Data processed by or on behalf of us. You have the right to have your Data rectified, deleted or restricted (as appropriate). You can exercise this right by contacting us with a data privacy request. Please note that requests that do not meet the requirements set out by applicable law or Orel guidelines may be requested to be re-issued or ultimately denied and that certain Personal Data may be exempt from such access, rectification and deletion requests pursuant to applicable data protection laws or other laws and regulations. Please note that you can also delete Personal Data by de-activating your user, however we will retain Personal Data where it is legally required for us to do so, which applies e.g. to sales administration.

You have the right to receive the Personal Data that you have provided to us in a structured, commonly used and machine-readable format, and in certain circumstances we will, at your request, transmit your Data to another controller where this is technically feasible.

10 Your Right to Object

You also have a right, in certain circumstances, to require us to stop processing your Personal Data, but
where we have compelling legitimate grounds, we will continue processing your Personal Data. However, you have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and when you do so, we will accommodate your request. Where you have provided consent to our use of your Personal Data, you have the right to withdraw your consent without this effecting the lawfulness of our use of this Data before your withdrawal.

11. Updates

We will keep this Privacy Policy under review and make updates from time to time. Any changes to this
Privacy Policy will be posted on our Website page and to the extent reasonably possible, will be communicated to you.

12. Contact

If you have any other question, objection to our use of your Personal Data or a complaint about this Privacy Policy or about our handling of your Personal Data, please contact us via cs@orel.com. You also have the right to file a complaint with your local data protection authority.
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