Privacy Policy. Federal Insurance Company, Singapore Branch Singapore Personal Data Protection Privacy Policy. 1. Introduction

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1 Privacy Policy 1. Introduction Federal Insurance Company, Singapore Branch ( we, our or us ) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal data. This document is our Privacy Policy and it tells you how we collect and manage your personal data ( Privacy Policy ). We respect your rights to privacy under the Singapore Personal Data Protection Act 2012 (the Act ) and we comply with all the Act s requirements in respect of the collection and management of your personal data. We may amend this Privacy Policy at any time and for any reason. The updated version will be available by following the Privacy Policy link on our website homepage which you should check regularly for any changes. This Privacy Policy was first issued on 18 th March What is your personal data? When used in this Privacy Policy, the term personal data has the meaning given to it in the Act. In general terms, it is any data that can be used to identify you and includes your name, address, telephone number, facsimile number, address and profession or occupation. If we can identify your identity from the data we collect or from that data and other information to which we have or is likely to have access to, the data will be considered personal data. 3. How do we collect your personal data? We collect your personal data directly from you unless it is unreasonable or impracticable to do so. When we collect personal data from you directly, we will inform you of the purpose for the collection, use or disclosure of your personal data by reference to the purposes stated in this Privacy Policy or otherwise. We may collect your personal data: through your access and use of our website; during conversations between you and our representatives; when you enquire about the products we offer; when you apply for an insurance product; when you make a claim; or when we need to provide services to you and offer various services and products which may interest you. We may also collect personal data from third parties including: third party companies such as credit reporting agencies, law enforcement agencies and other government entities; or our associations of insurance companies and their members. insurance intermediaries handling your insurance coverage. Page 1

2 4. What personal data do we collect and hold? We may collect the following types of personal data from you: name; identity card number; mailing address; address; telephone contact number; facsimile number; age or birth date; profession, occupation or job title; the products and services you have purchased or which you have enquired about, together with any additional data necessary to deliver those products and services and to respond to your enquiries; and any additional data relating to you that you provide to us directly through our websites or indirectly through use of our websites, through our representatives or otherwise. We may also collect some data that is not personal data because it does not identify you or anyone else. For example, we may collect aggregated data about how users use our website or anonymous answers to surveys. 5. What happens if we cannot collect your personal data? If you do not provide us with the personal data described above, some or all of the following may happen: we may not be able to provide the requested products or services to you, either to the same standard or at all; we may not be able to provide you with information about products and services that you may want, including information about discounts or special promotions; or we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful. 6. For what purposes do we collect, hold, use and disclose your personal data? We collect personal data about you so that we can perform our business activities and functions and to provide the best possible quality of customer service. We collect, hold, use and disclose your personal data for purposes including: to administer your insurance policy so as to provide the relevant products and services to you and to send communications requested by you; to process and evaluate your application and any future application you make; to investigate, process and make payment for claims under your insurance policy; to answer enquiries, and provide information or advice about existing and new products or services; for identification and verification purposes; for our own internal records; to provide you with access to protected areas of our website; Page 2

3 to assess the performance of the website and to improve the operation of the website; to conduct business processing functions including providing personal data to our related bodies corporate, contractors, service providers or other third parties; for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes; to provide your updated personal data to our related bodies corporate, contractors or service providers; to update our records and keep your contact details up to date; to process and respond to any complaint made by you; to commence or defend any legal proceedings made by or against us, our directors, officers, employees, subcontractors, agents and/or related bodies corporates; and to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country). 7. To whom may we disclose your data? Generally, we may disclose your personal data as necessary for: the purpose for which you have provided the personal data to us; purposes which are directly related to the purpose for which you provided it to us; and any other purposes to which you have consented. We may disclose your personal data to: our related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants; in the event of a claim, loss adjudicators, claims investigators and medical advisers; any person in connection with claims made by or against or otherwise involving you in respect of any products or services provided by us; any reinsurers, brokers or agents for the purposes of underwriting or administering your policy; to suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; to our associations of insurance companies and their members; and another organisation for any authorised purpose with your express consent. We may combine or share any data that we collect from you with data collected by any of our related bodies corporate. 8. Direct marketing materials We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications are sent in various forms, including mail, SMS, fax, telephone calls and , in accordance with applicable marketing laws, such as the Spam Control Act and the Do Not Call registry rules under the Act. If you indicate a preference in regards to a method of communication, we will endeavour to use that method whenever practical to do Page 3

4 so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see details below) or by using opt-out facilities provided in the marketing communications and we will ensure that your name is removed from our mailing list. We do not provide your personal data to other organisations for the purposes of direct marketing. 9. Do we disclose your personal data to anyone overseas? We may disclose personal data to our related bodies corporate and third party service providers located overseas for some of the purposes listed above. We will take reasonable steps to ensure that the overseas recipients of your personal data will provide a standard of protection to personal data at a level comparable to the level of protection prescribed by the Act. We may disclose your personal data to entities located outside of Singapore, including our related bodies corporate located globally as members of the Chubb Group of Insurance Companies. 10. Security We will take all practicable steps to ensure that your personal data is protected against misuse and loss and from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. We may hold your data in either electronic or hard copy form. Personal data will be destroyed or de-identified when no longer needed. We have in place appropriate physical, electronic and managerial measures (including firewalls and encryption) to safeguard and secure your personal data from unauthorised access. However, complete confidentiality and security is not guaranteed, especially in relation to electronically held information and against unauthorised access by third parties. You are aware that your personal data is disclosed at your own risk and we are not responsible for any damage which may arise from your provision of personal data to us. As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of data you communicate to us. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal data or other information which you transmit to us is transmitted at your own risk. 11. Cookies We may place electronic cookies in the browser file of your computer when you access our website. Cookies are pieces of information that our website transfers to your computer to enable our system to recognize your browser and to tailor the information on our website to your interests. For example, if you previously visited our website and accessed your account information or inquired about particular services over the website, cookies enable us to present information tailored to your account and/or those particular interests the next time you visit the website. Moreover, we may place cookies on your computer s hard drive that can be mated to other personal information we maintain about you to prepopulate certain online forms for your convenience. We also use cookies to analyse visitor s use of our Page 4

5 website. This analysis helps us better understand which areas of our website are most useful and popular so we can plan improvements and updates accordingly. We may log IP addresses (i.e. the electronic addresses of computers connected to the Internet) to analyse trends, administer the website, track users movements, and gather broad demographic information. 12. Links Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices. 13. How can you access and correct your personal data? You may request access to any personal data we hold about you by contacting us (details below). Where we hold data that you are entitled to access, we will try to provide you with suitable means of accessing it (e.g. by mailing or ing it to you). We may charge you a fee to cover our administrative and other costs in providing the data to you. We will not charge for simply making the request and do not charge for making any corrections to your personal data. If you believe that the personal data we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it. We will consider if the data requires amendment. If we do not agree that there are grounds for amendment then we will add a note to your personal data stating that you disagree with it. Please note that there are certain exemptions under the Act that may apply to personal data access and correction requests. As such, there may be instances where we cannot grant you access to the personal data we hold. For example, we may need to refuse access if granting access would reasonably be expected to threaten the safety of another individual or reveal personal data about another individual. 14. What is the process for complaining about a breach of privacy? If you believe that your privacy has been breached, please contact us (details below) and provide details of the incident so that we can investigate it. 15. Contacting us If you have any questions about this Privacy Policy, any concerns or a complaint regarding the collection, use or disclosure of your personal data or a possible breach of your privacy, please contact our Data Protection Officer via the details set out below. We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns. We will aim to ensure that your complaint is resolved in an appropriate manner Page 5

6 Please contact our Data Protection Officer at: Federal Insurance Company, Singapore Branch Attention: Data Protection Officer 18 Cross Street, #11-08 China Square Central Singapore Phone: For more information on Personal Data Protection Act, please visit The Personal Data Protection Commission (PDPC) website at Updated: 26 th November 2014 Page 6