Singapore Privacy Policy

(Last updated: 7th June 2018)

  1. Introduction
  2. In order to provide insurance products and services, it may be necessary for an insurer to collect personal data about you from time to time. Starr International Insurance (Singapore) Pte. Ltd. ("SIIS") and its affiliated companies (hereinafter collectively called "Starr"), recognizes its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data Protection Act (Act 26 of 2012) ("PDPA"). SIIS will only collect personal data for lawful and relevant purposes and will take all reasonable practicable steps to ensure that personal data which it holds is accurate and kept secure to avoid unauthorised access.

    This Privacy Policy is designed to assist you in understanding why and how SIIS collects and uses your personal data, to whom your personal data may be transferred to, how to access, review and amend your personal data and SIIS’ policy on the use of website cookies.

    By submitting your information to SIIS, or signing up for any products and/or services offered and/or distributed by SIIS, you agree and consent to SIIS, as well as SIIS’ respective representatives, agents, third party service providers and/or appointed distributors/business partners, collecting, using, disclosing personal data in the manner set forth in the prevailing terms of this Privacy Policy, including any future amendments.

    Please note that the purposes set forth in this Privacy Policy supplement but do not supersede any other consent(s) you may have previously provided to SIIS or which you may provide to SIIS in the future.

    SIIS reserves the right, at any time, to add to, change, update or modify this Privacy Policy. Updates and the revised Privacy Policy will be placed on SIIS’ website. If the changes are material, SIIS will notify you on this website as well as through other means (e.g. email and/or letter).

  3. Purposes for which personal data is collected, used or disclosed
  4. Under PDPA, personal data is defined as information about an individual who can be identified from that data, or from that data and other information to which the organization has or is likely to have access.

    It may be necessary for you to supply SIIS with personal data in connection with the provision of insurance or other products or services. Failure to provide such personal data may result in SIIS being unable to provide relevant products or services to you.

    SIIS collects, uses and discloses personal data for the following purposes:

    1. Offering and providing insurance or related products or services to you, and administering, maintaining, managing and operating such products or services;
    2. Processing, evaluating and verifying any applications for insurance or related products or services, as well as any changes, cancellations, renewals, reinstatements and any other relevant matters;
    3. Providing subsequent services to you, including but not limited to administering the policies issued;
    4. Processing (including but not limited to investigating and analyzing) any claim under any insurance policy or products or services issued to you by SIIS;
    5. Communicating with you via telephone, mail, e-mail, facsimile or any other electronic communications means;
    6. Evaluating your needs;
    7. Designing any insurance or related products or services;
    8. Conducting market research for statistical or other purposes;
    9. Matching any data held which relates to you from time to time for any of the purposes listed herein;
    10. Providing customer services (including but not limited to processing enquiries and complaints);
    11. Making disclosure as required by any applicable laws, rules, regulations, codes of practice or guidelines;
    12. Conducting identity, eligibility and/or other checks;
    13. Complying with the laws of any applicable jurisdiction;
    14. Carrying out other services in connection with the operation of the Starr's business;
    15. Other purposes as notified at the time of collection; and
    16. Other purposes directly relating to any of the above.

  5. How personal data (and other information) is collected
  6. SIIS may collect your personal data in one or more of the following ways:

    1. When you submit an application or registration form, or any other forms relating to any products and services offered and/or distributed by SIIS;
    2. When a policyholder takes up an insurance policy for your benefit;
    3. When you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with SIIS, or when you use SIIS’ services;
    4. When you interact with SIIS’ customer service officers, representatives, agents or appointed service providers (for example, via telephone calls, letters, face-to-face meetings and/or e-mails);
    5. When you use SIIS’ electronic services or any of SIIS’ websites or web services;
    6. When you request SIIS to contact you (whether pursuant to a request for more information, complaints, or any other purposes);
    7. When you respond to promotions, lucky draws, contests, events, initiatives, surveys organised by SIIS, its partners, representatives or service providers and/or any other request for personal data;
    8. When your images are captured by SIIS via CCTV cameras while you are within any of SIIS’ premises, or via photographs or videos taken by SIIS, its representatives or its agents when you attend SIIS’ events;
    9. When SIIS receives references from business partners or third parties (for example, where you have been referred by them);
    10. When SIIS receives information from third parties about you when you make payment through them;
    11. When SIIS seeks information from third parties about you in connection with the products and services you have applied for, including but not limited to from other insurers, insurance associations, healthcare institutions, clinics, investigators, ex employer and the relevant authorities; and/or
    12. When you submit your personal data to SIIS for any other reason.

    As SIIS relies on your personal data to provide products and services to you, you shall ensure that the information provided by you to SIIS is at all times correct, accurate and complete, and shall update SIIS in a timely manner of all changes to the information provided to SIIS.

    If you provide SIIS with any personal data relating to a third party, you represent and warrant to SIIS that you have obtained the consent of the third party to provide SIIS with their personal data for the relevant purposes.

    When you access SIIS’ website, various types of technical information may also be collected about your activities on the website (e.g. your IP address, the date and time that you accessed the website, information relating to your browser and operating system, the pages visited etc.). This information does not allow you to be identified. SIIS may use this information for purposes such as calculating website usage levels, helping diagnose server problems, and administering the website.

    SIIS may also collect aggregate data from its website. This information helps SIIS to better understand your needs and adapt its products and services accordingly. Similarly, this data does not allow you to be identified, and SIIS may use and disclose it for any purpose (save where it is required to do otherwise under applicable law).

    SIIS’ website may also use "cookies" to gather statistical information concerning web traffic and usage patterns. Cookies will enable the website to remember you and your preferences when you visit the website and will enable SIIS to tailor the website to your needs. Cookies do not identify you personally; they do not track your name, email address or other similar personal information. However, if you do not want to receive cookies you can disable this function by changing your browser settings. In addition, SIIS may use "pixel tags", "web beacons" "clear CIFs" or other similar technologies in respect of the pages on its website. This assists SIIS to, among other things, track the actions of the users on the website to enable it to compile statistical usage and response rates.

  7. Types of Personal Data Collected
  8. Depending on your relationship with SIIS (for example, as a consumer policyholder, non-policyholder insured, commercial broker or appointed representative, or other person relating to its business), personal data collected about you and your dependents may include:

    1. General identification and contact information – such as your name, address, e-mail and telephone details, gender, marital status, date of birth etc.
    2. Identification numbers – such as your Identity Card number, passport number, or driver's or other license number.
    3. Financial information and account details – such as your payment card number, bank account number and account details, credit history and credit score, assets, income, and other financial information.
    4. Medical condition and health status – such as your current or former physical or mental or medical condition and history, personal habits, and injury or disability information.
    5. Other sensitive information – such as your family medical history or genetic information. SIIS may also obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. Sensitive information may also be obtained if you voluntarily provide it to SIIS (for example, if you express preferences regarding medical treatment based on your religious beliefs).
    6. Recordings of telephone calls to the representatives and call centers of SIIS.
    7. Information enabling SIIS to provide products and services – such as your travel plans, age categories of individuals you wish to insure, policy and claim numbers, coverage/peril details, cause of loss, prior accident or loss history, and other insurance you hold.

  9. Transfer of Personal Data
  10. Personal data held by SIIS will be kept confidential but, subject to the provisions of any applicable law, SIIS may disclose or transfer such data to any of the following classes of persons to satisfy the purpose or a directly related purpose for which the personal data was collected:

    1. Any companies carrying on insurance and/or reinsurance related business.
    2. Any insurance intermediaries.
    3. Any insurance claims investigators.
    4. Any associations and federations of insurance companies that exist from time to time.
    5. Any insurance agents and professional advisers.
    6. Any other service providers providing insurance and/or reinsurance related business.
    7. Any marketing companies authorized by SIIS for the purpose of conducting marketing activities in relation to the products of SIIS.
    8. Any person in connection with any claims made by or under or otherwise involving any products or services provided by SIIS.
    9. Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, data processing or storage, or other services to Starr in connection with the operation of the business of Starr.
    10. Any credit reference agencies or, in the event of default, any debt collection agencies.
    11. Any person under a duty of confidentiality to Starr which has undertaken to keep such data confidential.
    12. Any actual or proposed purchaser, assignee, transferee, participant or sub-participant of Starr's rights or business.
    13. Any person to whom Starr are under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice or guidelines binding on Starr including, without limitation, any applicable regulators, governmental bodies, or industry recognised bodies, and where otherwise required by law.
    14. Any registers of claims which are shared with other insurers for the purpose of detecting, preventing or investigating fraudulent claims (and for these purposes, SIIS may search such registers); and
    15. Any party to whom you have consented the disclosure of your personal data.

    Where permitted by law, personal data collected in Singapore by SIIS may be transferred to places outside of Singapore (such as to Starr, Starr's service providers, and governmental and regulatory authorities) and stored in servers outside of Singapore for processing, storage, analysis, disaster recovery or emergency assistance services and such personal data may be required to be disclosed to those authorized under the applicable laws of that foreign country.

    Service providers with whom SIIS has contractual relationships for the transfer of such personal data are required to provide a standard of protection to the transferred personal data that is comparable to the protection under the PDPA and consistent with SIIS’ personal data protection policies and practices.

    By providing SIIS with your personal information or using SIIS’ services or SIIS’ website, you consent to the transfer of such information outside Singapore to Starr’s facilities or to those third parties with whom SIIS shares it as described above.

  11. Data Security
  12. SIIS takes appropriate technical, physical and administrative measures to handle personal data in a secure manner which is consistent with the PDPA. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.

    SIIS shall keep your personal data for as long as necessary to fulfill the original or directly related purpose for which such data was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations. If (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes, SIIS will take reasonable steps to securely delete, destroy and/or anonymize your personal data.

  13. Access, correction and withdrawal of your personal data
  14. Under the PDPA, you have the right to request access to your personal data that SIIS has. However, you may be charged a reasonable fee for every request for such access.

    You also have the right to request correction of your personal data.

    You may withdraw your consent for SIIS to collect, use or disclose your personal data by giving SIIS reasonable notice.

    If you withdraw your consent for SIIS to collect, use or disclose your personal data for non-marketing reasons, SIIS will be unable to process, administer and/or manage your policy, relationship and/or account with SIIS. In such event, you may be required to surrender or terminate all your policies or accounts with SIIS.

    Requests for withdrawal of consent, access and correction should be addressed in writing to SIIS’ Data Privacy Officer at 138 Market Street, #16-04, CapitaGreen, Singapore 048946.

  15. Direct Marketing
  16. Occasionally, personal data may be collected and used for direct marketing in respect of services and products which SIIS offers; for direct marketing of services and products by its parent companies, related companies or group companies and their product distributors, authorised insurance agents and contractors; and for other financial and third party service providers of marketing and technology in Singapore or elsewhere.

    SIIS will not use or provide your personal data to third parties for direct marketing without your consent. You may also at any time contact SIIS to withdraw your consent by writing to SIIS' Data Privacy Officer at 138 Market Street, #16-04, CapitaGreen, Singapore 048946. SIIS will act on your request at no cost to you as soon as practicable.

  17. Links to Third Party Websites
  18. SIIS’ website may contain links to third party websites. SIIS has no control over the content of such third party websites or the way that the operators of such websites deal with your personal data. The inclusion of a link on SIIS’ website does not imply endorsement of the linked site by SIIS.

  19. Use of this Website by Minors
  20. This Website is not directed to individuals under the age of eighteen (18), and SIIS requests that these individuals do not provide personal data through this Website.

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