Data Protection Policy

We at Liberty Insurance Pte Ltd take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process the personal data of yours and other individuals.

This Data Protection Policy is designed to assist you to understand how we collect, use, and disclose 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 or that of other individuals.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

1INTRODUCTION TO THE PDPA

1.1“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 organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2We will collect the personal data which you or your representatives have provided about yourself or other individuals in accordance with the PDPA (“personal data”). If there is any personal data relating to other individuals, you agree to obtain prior consent from them (or if they are lacking in legal capacity, from their legal representatives, guardians or parents as the case may be) for Liberty and third-parties including its related companies, employees, agents, service providers, organizations and contractors etc (collectively, “appointees”) to collect, use and disclose their personal data for the relevant purposes and on the same terms. 

1.3We will notify you of the purposes for which personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to do so without your consent. 

2PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1You agree that the personal data about yourself or other individuals can be collected, used, and disclosed by us or our appointees for various purposes including:

(a)due diligence and considering whether to provide insurance. This includes Liberty considering your application for a policy with Liberty and another Insurer considering your application (whether now or in the future) for a policy with that Insurer;

(b)underwriting, pricing and insurance. This includes dealing with your application with Liberty and any other application that you may make (whether now or in the future) with another Insurer;

(c)administering and/or managing your relationship, account and/or policy with Liberty including but not limited to renewing or reinstating policies, demanding, collecting any outstanding amounts due from you, processing refunds to you;

(d)processing and/or dealing with any claims including the settlement of claims and any necessary investigations relating to the claims, under your policies, whether the policies are issued by Liberty or another Insurer;

(e)carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by Liberty, whether for this policy with Liberty or a policy with another Insurer;

(f)carrying out your instructions or responding to any enquiries by you;

(g)conducting research, surveys, analysis and development activities (including but not limited to data analytics, surveys (such as insurance survey, customer service survey, branding survey), branding campaign, product and service development and/or profiling;

(h)communications - this includes but is not limited to communicating with you via phone/voice calls, text messages and/or fax messages, email and/or postal mail. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(i)investigating fraud, misconduct, any unlawful action or omission, whether relating to your application, your claims or any other matter relating to your policy or policies, whether such policy is issued by us or another Insurer, and whether or not there is any suspicion of the aforementioned; 

(j)reinsurance;

(k)storing, hosting, backing up (whether for disaster recovery or otherwise);

(l)accounting, auditing, legal, regulatory and compliance;

(m)if you have so consented - to send you marketing, advertising and promotional information about other insurance, investment and/or financial products and/or services that Liberty may be selling or marketing;

(n)any purpose which is incidental, implied, ancillary, exploratory, enhancing or supportive of any of the above purposes;

(0)any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”)

3You agree that we can disclose the personal data to appointees and third parties whether sited in Singapore or outside of Singapore, for one or more of the above-mentioned Purposes. Without limiting the generality of the foregoing, such appointees and third parties include:

(a)Liberty’s related, associated or affiliated corporations;

(b)any of Liberty’s agents, employees, contractors or service providers – for example, mailing houses, telecommunication companies, insurance intermediaries, information technology companies, events managers, debt collection services, data storage or hosting companies, data centres, disaster recovery service providers, banks, finance companies, actuaries, consultants, auditors, etc;

(c)lawyers/law firms, legal process participants and their advisors;

(d)any third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition or all or any portion of Liberty’s business, assets or stock (including in connection with any bankruptcy or similar proceedings); and/or

(e)industry or public/government organizations;

(f)third parties to whom disclosure by Liberty is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

4REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1You may request to access and/or correct the personal data currently in our possession by submitting your request to Data Protection Officer at

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

4.2For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made.

4.3For a request to correct personal data, we will:

(a)correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and

(b)subject to paragraph 4.4, we will send the corrected personal data to every other organization to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.

4.4Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date of correction was made.

4.5We will also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct the personal data.

5REQUEST TO WITHDRAW CONSENT

You may withdraw your consent for the purpose(s) of collection, use and/or disclosure of the personal data in our possession or under our control by submitting your request in writing to:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

5.1We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose the personal data for the purposes as stated in your request.

5.2However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the nature and extent of your withdrawal of consent in relation to the personal data, it may mean that we will not be able to continue with your or the data subject’s existing relationship with us.

6ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1We will take reasonable efforts to ensure that personal data is accurate and complete, if personal data is likely to be used by us to make a decision that affects you, or disclosed to another organization. However, this means that you must also update us of any changes to the personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in the personal data that you had initially provided us with.

6.2We will also put in place reasonable security arrangements to ensure that personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of personal data by third parties which are wholly attributable to factors beyond our control.

>6.3We will also put in place measures such that personal data in our possession or under our control is destroyed and/or anonymized 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.

7COMPLAINT PROCESS

7.1If you have any complaint or grievance regarding about how we are handling personal data or about how we are complying with the PDPA, please contact us with your complaint or grievance.

7.2Please write in to us with your complaint or grievance at:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

7.3We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

8UPDATES ON DATA PROTECTION POLICY

8.1As part of our efforts to ensure that we properly manage, protect and process personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2We 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 our website and can be viewed at www.libertyinsurance.com.sg.

8.3You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

 

 

Data Protection Policy

We at Liberty Insurance Pte Ltd take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process the personal data of yours and other individuals.

This Data Protection Policy is designed to assist you to understand how we collect, use, and disclose 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 or that of other individuals.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

1INTRODUCTION TO THE PDPA

1.1“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 organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2We will collect the personal data which you or your representatives have provided about yourself or other individuals in accordance with the PDPA (“personal data”). If there is any personal data relating to other individuals, you agree to obtain prior consent from them (or if they are lacking in legal capacity, from their legal representatives, guardians or parents as the case may be) for Liberty and third-parties including its related companies, employees, agents, service providers, organizations and contractors etc (collectively, “appointees”) to collect, use and disclose their personal data for the relevant purposes and on the same terms. 

1.3We will notify you of the purposes for which personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to do so without your consent. 

2PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1You agree that the personal data about yourself or other individuals can be collected, used, and disclosed by us or our appointees for various purposes including:

(a)due diligence and considering whether to provide insurance. This includes Liberty considering your application for a policy with Liberty and another Insurer considering your application (whether now or in the future) for a policy with that Insurer;

(b)underwriting, pricing and insurance. This includes dealing with your application with Liberty and any other application that you may make (whether now or in the future) with another Insurer;

(c)administering and/or managing your relationship, account and/or policy with Liberty including but not limited to renewing or reinstating policies, demanding, collecting any outstanding amounts due from you, processing refunds to you;

(d)processing and/or dealing with any claims including the settlement of claims and any necessary investigations relating to the claims, under your policies, whether the policies are issued by Liberty or another Insurer;

(e)carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by Liberty, whether for this policy with Liberty or a policy with another Insurer;

(f)carrying out your instructions or responding to any enquiries by you;

(g)conducting research, surveys, analysis and development activities (including but not limited to data analytics, surveys (such as insurance survey, customer service survey, branding survey), branding campaign, product and service development and/or profiling;

(h)communications - this includes but is not limited to communicating with you via phone/voice calls, text messages and/or fax messages, email and/or postal mail. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(i)investigating fraud, misconduct, any unlawful action or omission, whether relating to your application, your claims or any other matter relating to your policy or policies, whether such policy is issued by us or another Insurer, and whether or not there is any suspicion of the aforementioned; 

(j)reinsurance;

(k)storing, hosting, backing up (whether for disaster recovery or otherwise);

(l)accounting, auditing, legal, regulatory and compliance;

(m)if you have so consented - to send you marketing, advertising and promotional information about other insurance, investment and/or financial products and/or services that Liberty may be selling or marketing;

(n)any purpose which is incidental, implied, ancillary, exploratory, enhancing or supportive of any of the above purposes;

(0)any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”)

3You agree that we can disclose the personal data to appointees and third parties whether sited in Singapore or outside of Singapore, for one or more of the above-mentioned Purposes. Without limiting the generality of the foregoing, such appointees and third parties include:

(a)Liberty’s related, associated or affiliated corporations;

(b)any of Liberty’s agents, employees, contractors or service providers – for example, mailing houses, telecommunication companies, insurance intermediaries, information technology companies, events managers, debt collection services, data storage or hosting companies, data centres, disaster recovery service providers, banks, finance companies, actuaries, consultants, auditors, etc;

(c)lawyers/law firms, legal process participants and their advisors;

(d)any third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition or all or any portion of Liberty’s business, assets or stock (including in connection with any bankruptcy or similar proceedings); and/or

(e)industry or public/government organizations;

(f)third parties to whom disclosure by Liberty is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

4REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1You may request to access and/or correct the personal data currently in our possession by submitting your request to Data Protection Officer at

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

4.2For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made.

4.3For a request to correct personal data, we will:

(a)correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and

(b)subject to paragraph 4.4, we will send the corrected personal data to every other organization to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.

4.4Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date of correction was made.

4.5We will also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct the personal data.

5REQUEST TO WITHDRAW CONSENT

You may withdraw your consent for the purpose(s) of collection, use and/or disclosure of the personal data in our possession or under our control by submitting your request in writing to:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

5.1We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose the personal data for the purposes as stated in your request.

5.2However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the nature and extent of your withdrawal of consent in relation to the personal data, it may mean that we will not be able to continue with your or the data subject’s existing relationship with us.

6ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1We will take reasonable efforts to ensure that personal data is accurate and complete, if personal data is likely to be used by us to make a decision that affects you, or disclosed to another organization. However, this means that you must also update us of any changes to the personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in the personal data that you had initially provided us with.

6.2We will also put in place reasonable security arrangements to ensure that personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of personal data by third parties which are wholly attributable to factors beyond our control.

>6.3We will also put in place measures such that personal data in our possession or under our control is destroyed and/or anonymized 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.

7COMPLAINT PROCESS

7.1If you have any complaint or grievance regarding about how we are handling personal data or about how we are complying with the PDPA, please contact us with your complaint or grievance.

7.2Please write in to us with your complaint or grievance at:

Data Protection Officer
51 Club Street, #03-00
Liberty House
Singapore 069428 

7.3We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

8UPDATES ON DATA PROTECTION POLICY

8.1As part of our efforts to ensure that we properly manage, protect and process personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2We 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 our website and can be viewed at www.libertyinsurance.com.sg.

8.3You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.