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Data Protection Policy
Aviva Asia Pte. Ltd. (Aviva, or "we" or "us") take our responsibilities in respect of your personal data very seriously. We recognise the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
This Data Protection Policy supplements but does not negate any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data.
Aviva is a company incorporated in Singapore, which is also where the Website is managed and operated. As such, the Personal Data Protection Act 2012 of Singapore (“PDPA”) is applicable. The Internet is worldwide and if you are visiting this Website from outside Singapore, your visit will necessarily result in the transfer of information across international borders. By visiting this Website and communicating electronically with us, you are consenting to these transfers.
- “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, nationality, identification numbers, contact information, medical records, photographs and video images.
- The purposes for which your personal data may be collected, used, disclosed and/or processed, are set out below. Please note that we may collect, use or disclose your personal data without your consent in accordance with applicable laws.
Collection, Use, Disclosure and Processing of Personal Data
- Your personal data may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances. Please review the full details of the purposes of collection, use, disclosure and processing of your personal data (collectively, the “Purposes”) in this section. These Purposes are not exhaustive. However, we will notify you of such other purpose(s) at the time of collection, use, disclosure or processing, unless otherwise permitted by the PDPA or any other applicable statutes, regulations, codes, rules, directives, orders, guidelines, schemes or directions ("Laws");
- In order to conduct our business operations smoothly, we (or any other Aviva Group company) may also disclose the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether situated in Singapore or outside of Singapore, for one or more of the Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties may collect, use, disclose or process your personal data either on our behalf or otherwise, for one or more Purposes.
Please note that we may transfer your personal data to a country outside of Singapore for any Purpose as may be required. In such an event, we will take appropriate steps to ensure that the receiving entities are bound by laws or contractual obligations for the protection of your personal data to a standard comparable to the PDPA.
Generally, we collect your personal data in the following ways:
- when you provide information through the Website in relation to an expression of interest or an application for an Aviva Scholarship;
- when you submit an application form or other form relating to the Aviva Scholarship or to any Aviva Group schemes, products or services; and
- when you are contacted by, and interact with, our customer service officers, employees, representatives and agents, either face-to-face or via electronic communications.
If you provide us with any personal data relating to a third party (for example but without limitation information relating to your child, parent or legal guardian), you agree and confirm that you have notified him or her on behalf of Aviva of the collection, use, disclosure and processing of the personal information by Aviva for the Purposes and obtained his or her consent accordingly, and also obtained his or her consent to provide his/her personal information to Aviva and all entities of Aviva Group for any of the Purposes. To the extent applicable, the provisions of the Data Protection Policy shall apply to personal data of such third parties collected, used, disclosed or processed by Aviva (or an Aviva Group company) in the same manner as it applies to your personal data (with such adaptations as may be necessary). The website may also contain a requirement for confirmation by the third party that he or she consents to the collection, use, disclosure or processing of personal data for any of the Purposes.
- If you consent to receiving marketing materials, Aviva or any Aviva group company may contact you through any medium and in any manner, unless you indicate otherwise, to inform you about products or services offer, special offers or other information which may be of interest to you.
- You have a right to opt-out from receiving marketing materials. If you subsequently decide that you do not wish to receive marketing materials from us, all you need to do is to contact us at email@example.com
Alternatively, if you decide that you would like to receive marketing materials, you can also contact us via the details above to do so.
If you are residing in Hong Kong, the following will apply to you:
“Use of Personal Data in Direct Marketing
Aviva may use a data subject’s data in direct marketing and Aviva requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
- the name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data of you held by Aviva from time to time may be used by Aviva in direct marketing;
- the following classes of services, products and subjects may be marketed:
- financial, insurance and related services and products;
- reward, loyalty, co-branding or privileges programmes and related services and products;
- services and products offered by Aviva’s co-branding partners (the names of such co-branding partners will be provided during the application for the relevant services and products, as the case may be); and
- the above services, products and subjects may be provided by or (in the case of donations and contributions) solicited by Aviva and/or:
- any member of the Aviva Group company;
- third party financial institutions, insurers, securities and investment services providers;
- third party reward, loyalty, co-branding or privileges programme providers; and
- co-branding partners of Aviva or any member of the Aviva Group company (the names of such co-branding partners will be provided during the application of the relevant services and products, as the case may be);
- in addition to marketing the above services, products and subjects itself, Aviva may provide the personal data described in (a) above to all or any of the persons described in (c) above for use by them in marketing those services, products and subjects, and Aviva requires your consent (which includes an indication of no objection) for that purpose;
- Aviva may receive money or other property in return for providing the data to the other persons in (d) above and, when requesting your consent or no objection as described in (d) above, Aviva will inform you if it will receive any money or other property in return for providing the data to the other persons.
If you do not wish Aviva to use or provide to other persons your personal data for use in direct marketing as described above, you may exercise your opt-out right by notifying Aviva.”
Personal data provided to Aviva may, subject to the requirements of applicable Laws, be collected, used, disclosed and/or processed by Aviva (or another Aviva Group company) for the purpose(s) of:
- implementing and administering the Aviva scholarship plan and general marketing;
- processing and sending /receiving information and documents in respect of any application for any policy, product or service, where applicable;
- providing financial advice to recommend any policy, product or service based on your financial needs analysis, where applicable;
- administration of your policy, where applicable, which may include but is not limited to:
- underwriting of the risk proposed;
- requesting and collecting premiums;
- providing regular information about your policy and sending updates and administrative notices to you in relation to the products and services used by you, including notification of maturity of payments and maturity of policies;
- making changes or updates to your policy;
- reviewing or renewing or reinstating your policy;
- carrying out your instructions or responding to any enquiries by you; and
- assessing and processing your claim(s) made under the policy;
- administration of any investment account, which may include but is not limited to:
- maintenance of your account;
- performing or updating transactions on your account; and
- carrying out your instructions or responding to any enquiries by you;
- dealing in any matters relating to your policies and/or accounts (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages);
- managing your relationship with Aviva or any Aviva Group company;
- compiling statistics or conducting research for company or industry exercises and studies, to design, review or improve our products and services;
- compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by the Aviva Group and/or the industry;
- where necessary for the management of the Aviva Group's business;
- complying with applicable Laws imposed by, or a bona fide request made by, any regulator, government, tax or statutory authority or body, law enforcement agency or court or other dispute resolution body;
- providing general information on product enhancements and services, which are relevant to your needs or policies (including increasing benefits, adding riders/supplements and/or insured lives);
- investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned;
- archiving, backing-up or destroying personal data. Some of these purposes may apply or continue to apply after your relationship, policy and/or account with the Aviva Group has ended or is no longer in force or active; and
- any other purpose incidental to or connected with any of the above.
- Your personal data or personal data of persons connected with you may be disclosed:
- by any Aviva Group company to any other Aviva Group company (whether in Singapore or elsewhere in the world) for any of the Purposes; and/or
- by any Aviva Group company to third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries, as and when relevant or necessary for any of the Purposes;
- in any circumstances where disclosure may be permitted by the PDPA or applicable law - for more information on the exceptions in Singapore, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA on the collection, use and disclosure of personal data without consent, which is publicly available at http://statutes.agc.gov.sg;.
- by any Aviva Group company to the following parties for the following purposes:
- to medical organisations, insurance offices or organisations, reinsurers, credit agencies, dispute resolution bodies or investigators for underwriting, claims, reinsurance and compliance/audit purposes;
- to your broker, financial adviser or representatives (including any new intermediary appointed by you or the company) to service and administer your plan or policy;
- to related companies for the processing and administration of your plan or policy;
- to banks, Central Provident Fund (“CPF”) agent banks, credit card companies, other financial institutions, CPF Board or third party contractors for payment, collection or refund of any monies due or payable or upon their valid request;
- to third party vendors engaged by an Aviva Group company to perform processes required for the administration of your policy or account (e.g. data entry, printing and dispatch of documents, claims administration etc.), for data analytics or to perform processes required to send marketing material or messages to you, where applicable;
- to related companies or third party vendors engaged by an Aviva Group company to store and maintain our data and documents (including storage for business recovery purposes);
- to any regulatory, tax, government or statutory authority or body to comply with applicable laws, regulations, rules, directive, order, guidelines, schemes or directions or upon their bona fide request;
- any other person as may be reasonably in connection with the purposes set forth above.
- Neither Aviva nor any of its officers, directors, employees, or agents shall be liable for any loss or damage suffered by you or any other person as a result of any disclosure of any personal data which you have consented to.
- By using the Website, requesting for information concerning or applying to the Aviva Scholarship program or applying for an insurance policy or an investment account with any Aviva Group company, you consent to Aviva and/or the relevant Aviva Group companies collecting, using, disclosing and/or processing the personal data mentioned above for any of the Purposes.
Purposes of Collecting, Using or Disclosing Personal Data
If you are residing in the People’s Republic of China, Clauses 2.7 (b) to (f), (h) and (l) will not apply.
Requests for Access and/or Correction of Personal Data
- Subject to certain exceptions provided for under the PDPA or other applicable Laws, you may request to access and/or correct an error or omission in your personal data currently in our possession or under our control by contacting us at firstname.lastname@example.org
- We will provide you with the relevant personal data within 30 calendar days (or as soon as reasonably possible thereafter) from such a request being made.
For a request to correct personal data, we will:
- correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
- subject to paragraph 3.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by Aviva within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
- Notwithstanding paragraph 3.3(b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
- Please note that under the PDPA, not all information that we have collected may be available for access or correction. For example, we will not provide you with your personal data if the provision of that personal data could reasonably be expected to reveal personal data about another individual.
- We will also be charging you a reasonable fee for the handling and processing of your requests to access or correct your personal data.
Requests to Withdraw Consent
- You may withdraw your consent given to us in respect of the collection, use and/or disclosure of your personal data by contacting us at email@example.com
- If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days upon receipt of your request.
- However, if you request to withdraw your consent for us to use your personal data for your insurance or account matters (for example matters relating to the servicing and administration of your insurance policy or your investment account), this will affect our ability to provide you with the products and services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim(s). In this regard, it may mean that we will not be able to continue with your existing relationship with us and/or the contract you have with us will have to be terminated .This may be disadvantageous to you, as you may sustain a loss, losing valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.
- Please note that if you withdraw your consent for a limited Purpose, such as for marketing or a specific category of marketing, we may still contact you or use your information for other Purposes for which you have not withdrawn your consent and such personal data may still be disclosed, as permitted by this Agreement or under the PDPA or other applicable Laws.
Administration and Management of Personal Data
- We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Aviva (or another Aviva Group company) to make a decision that affects you, or likely to be disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data if you did not update us of the changes in your personal data.
- We will also put in place reasonable security arrangements to ensure that your personal data in our possession or under our control is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties due to factors beyond our control.
- We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (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.
Complaints & Feedback
If you have any complaint or feedback about how we are handling your personal data, please contact our Data Protection Officer at:
4 Shenton Way, #01-01 SGX Centre 2 Singapore 068807
8.45am to 5.30pm, Mondays to Fridays, excluding Public Holidays.
Ms Irene Yeo (Personal Data Protection Officer)
Tel: +65 9182 8439
- Where it is an email or a letter through which you are submitting a complaint or feedback, please insert the subject header “Data Protection” and address it to our Data Protection Officer.
- We will certainly strive to attend to any complaint or grievance that you may have efficiently.
Updates on Data Protection Policy
- As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
- We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on the Website.
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Last updated 23 June 2017