HL Assurance Pte. Ltd. Policy On Personal Data

HL Assurance Pte. Ltd. (“HLAS”) is a member of Hong Leong Group, a leading conglomerate based in Malaysia with diversified businesses in Asia, Europe, North America and Oceania. We are a licensed general direct insurer and also a member of General Insurance Association in Singapore.

HLAS and its related bodies corporate (“we, our, us”) recognise the importance of protecting the privacy and rights of individuals in relation to their personal data. This document is our policy on personal data and it tells you how we collect andmanage your personal data.

The provisions of this policy may form part of the account terms and conditions and/or the agreement or arrangements that you have or may enter into with HLAS. If any inconsistency is found, the provisions of this policy shall prevail.

What is your personal data?

When used in this policy on personal data, the term “personal data” has the meaning given to it in the Personal Data Protection Act (the “Act”). In general terms, it is any data that can be used to identify you and includes your name, address, telephone number, facsimile, email 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, the data will be considered personal data.

What personal data do we collect and hold?

We may collect the following types of personal data:

• Name
• Mailing or street address
• Electronic mail address
• Telephone number
• Facsimile number
• Age or birth date
• Profession, occupation or job title
• The products and services you have purchased or which you have acquired about, together with any additional data necessary to deliver those products and services and to respond to your enquiries
• 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
• Data you provide to us through our service center, customer surveys or visits by our representatives from time to time.

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 collecting personal data from you, we may collect in ways including:

• Through your access and use of our website
• During conversations between you and our representatives
• When you complete an application or quotation request

We may also collect personal data from third parties including:

• From third party companies such as credit reporting agencies, law enforcement agencies and other government entities
• When we seek information from third parties about you in connection with your policy, policy applications or claims such as other insurers, insurance associations, hospitals, clinics, motor workshops and the relevant authorities.

We hold your personal data in an electronic system in Singapore.

What happens if we do not 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 or services that you may want, including information about discounts, sales 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.

For what purposes do we collect, hold, use and disclose your personal data?

We collect, hold, use and disclose your personal data for the following purposes:

• The daily operation of the insurance services provided to you including but not limited to:
• processing and evaluating your applications;
• administering and providing services in relation to the insurance products;
• investigating and processing claims;
• invoicing and collecting premiums; and
• contacting you for any of the above purposes;
• Ensuring your ongoing credit worthiness;
• Researching, designing, launching, banking, financial, insurance services or related products for your use and monitoring the provision, operation and use of such services or products;
• Marketing services, products and other subjects (please see details below);
• Determining amounts owed to or by you;
• The enforcement of your obligations, including without limitation collection of amounts outstanding from you;
• To comply with any laws, rules, regulations, lawful and binding determination, guidelines or guidance, decision or direction of a regulator, or in cooperation with any governmental authority of any country (or political sub-division of a country);
• Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Hong Leong Group and/or for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
• To provide you with access to protected areas of our website;
• To assess the performance of the website and to improve the operation of our website;
• To provide your updated personal data to our related bodies corporate, contractors or service providers;
• To process and respond to any complaint made by you; and
• Provision of reference (status enquiries).

Who may we disclose your personal data to?

We may disclose your personal data to:

• Claims investigators, medical advisors, reinsurers or your insurance brokers;
• Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, legal, payment or clearing or other services to HLAS in connection with the operation of its business;
• Any other person under a duty of confidentiality to HLAS including a member of the Hong Leong Group which has undertaken to keep such information confidential;
• Any person to whom HLAS is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to HLAS, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers with which HLAS are expected to comply, or any disclosure pursuant to any contractual or other commitment of HLAS with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers, all of which may be within or outside Singapore and may be existing currently and in the future;
• Any actual or proposed assignee of HLAS or transferee of HLAS’s rights in respect of you; and
  1. Any member of the Hong Leong Group;
  2. Third party financial institutions, insurers, credit card companies, securities and investment services providers;
  3. External service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies); and
  4. Any nominee, trustee, co-trustee, centralised securities depository or registrar, custodian, estate agent, solicitor or other person who is involved with the provision of services or products by a member of the Hong Leong Group to you.

We may disclose your personal data to entities located outside of Singapore.

Use of personal data in direct marketing

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 email, SMS, fax, telephone calls and mail, in accordance with applicable marketing laws, such as the Spam Control Act and Do Not Call registry rules under the Act. If you indicate a preference in regards to a method of communication, we will endeavor to use that method wherever practical to do so.

If you do not wish to receive any marketing communications from us, you may exercise your opt-out right by notifying HLAS (see details below) or by using the 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.

How can you access and correct your personal data?

You may request access to any personal data we hold about you at any time by contacting us (details below). We may charge you a fee to cover our administrative and other costs in providing the personal data to you.

You may do any of the following:

• Check whether HLAS holds data about you and;
• Require HLAS to correct any data relating to you which is incorrect, incomplete or inaccurate; and
• Ascertain HLAS’s policies and practices in relation to data and to be informed of the kind of personal data held by HLAS.

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 interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

How do you complain about a breach of privacy?

If you believe that your privacy has been breached, please contact us (see details below) and provide details of the incident so that we may investigate it.

Use of cookies

When you visit our website, information about your browsing behavior on our website may be collected with the use of “cookies”. A cookie is a small piece of data sent from a website and automatically stored in a user’s web browser when a user visits the website. The information collected by “cookies” may include items such as language preference, the pages visited and aggregated research data such as number of visitors but contain no personally identifiable information.

HLAS uses cookies to maintain the state of user connection with our website and gather statistics on users’ overall website browsing behavior so that we can evaluate our website’s effectiveness and improve the user experience. If you prefer, you may disable the cookies by changing the setting on your web browser. However, you may not be able to fully utilise the functions of our website if cookies are disabled.

HLAS may work with or engage third parties to conduct research on the usage and activities of users on our website on our behalf. No personally identifiable information about you is collected or shared with third parties as a result of the research.

Security

HLAS takes reasonable steps to ensure your personal data is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your personal data in either electronic or hard copy form. Personal data is destroyed or de-identified when no longer needed.

However, 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 that 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 that you transmit to us is transmitted at your own risk.

Contact us

If you have any questions about this policy on personal data, any concerns or a complain regarding the collection, use or disclosure of your personal data or a possible breach of your privacy, please use the Contact link on our website or contact our Data Protection Officer via the details set out below.

• HL Assurance Pte. Ltd.
• 11 Keppel Road
• #11-01 ABI Plaza
• Singapore 089057
• Phone: +65 6702 0202
• Email: service@hlas.com.sg

Changes to our policy on personal data

We may change this policy from time to time and any changes will be posted on HLAS’s website at www.hlas.com.sg. This policy on personal data was last updated on 5 December 2013.