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Data Protection Policy

1  INTRODUCTION TO THE PDPA

1.1  “Personal Data” is defined under the Personal Data Protection Act 2012 (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, identification numbers, contact information, medical records, photographs and video images.


1.2  We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your 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 collect and process your personal data without your consent.


1.3  In the absence of express consent set out in Clause 1.2 above, if you provide your personal data voluntarily to us or any of our authorized agents, employees, partners, service providers, third parties, and/or contractors to (i) request for information from us pertaining to insurance proposal(s); (ii) process a claim made by you under any insurance policy with us; or (iii) enter into insurance contract(s) with us, you shall be deemed to have consented, to the use, collection and processing of your personal data by us or any of our authorized agents, employees, partners, service providers, third parties, and/or contractors for the purposes as stated in Clause 2 hereof. Similarly, you shall also be deemed to have consented to the disclosure of your personal data by us to the third parties stated in Clause 3 hereof where such disclosure is required for the purposes as stated in Clause 2 hereof.


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

2.1  We may collect, use, disclose and process personal data including but not limited to the following:


2.2  The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:


(a)  considering whether to provide you with the insurance you applied for. This includes Tokio Marine Insurance Group considering your application for a policy with us and another Insurer considering your application (whether now or in the future) for a policy with that Insurer (“Insurer” means any insurer or company operating insurance business in Singapore);


(b)  processing your application for underwriting and insurance. This includes dealing with your application with Tokio Marine Insurance Group 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 Tokio Marine Insurance Group including but not limited to accounting and dealing with or collection of any outstanding amounts from you;


(d)  processing and/or dealing with any claims including the settlement of claims and any necessary investigations relating to the claims, under your policy or policies, whether such policy is issued by Tokio Marine Insurance Group or another Insurer;


(e)  carrying out due diligence or other screening activities (including background, anti-money laundering (AML), “know-your-client” 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 Tokio Marine Insurance Group, whether for any policy with Tokio Marine Insurance Group or a policy with another Insurer;


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


(g)  conducting research, analysis and development activities (including but not limited to data analytics, surveys (such as insurance survey, customer service survey), product and service development and/or profiling) to improve our services or products and/or to enhance the product or service for your benefit;


(h)  dealing in any matters relating to the services and/or products which you are entitled to under any insurance policy with us and/or dealing in any matters relating to any insurance policy with us, which you are applying for or have applied. This includes but is not limited to contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your contractual relationship with us such as but not limited to communicating with you on matters related to your policy with us. 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 insurance 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)  storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;


(k)  complying with applicable law in administering and managing your relationship with Tokio Marine Insurance Group;


(l)  if you have so consented, sending you marketing, advertising and promotional information about other insurance, investment and/or financial products and/or services that Tokio Marine Insurance Group may be selling or marketing, whether now or in the future, and which we believe may be of interest or benefit to you, by way of the modes of communication as consented by you; and


(m)  any other purposes which we notify you of at the time of obtaining your consent.(collectively, the “Purposes”).


As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.


2.3  In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our reinsurers, third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such reinsurers, third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.


3  SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1  We respect the confidentiality of the personal data you have provided to us.


3.2  In that regard, we will generally not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:


(a)  cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;


(b)  cases in which the disclosure is necessary to perform our contractual obligations to you;


(c)  cases in which the disclosure is necessary for services requested by you to be provided by third parties to you;


(d)  cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;


(e)  cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;


(f)  cases in which the disclosure is necessary for any investigation or proceedings;


(g)  cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;


(h)  cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or


(i)  where such disclosure without your consent is permitted by the PDPA or by law.


3.3  The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second Schedule of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012?ProvIds=Sc2-XX-Sc2-#Sc2-XX-Sc2-.


3.4  Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.


3.5  The third parties, to whom personal data provided by you to Tokio Marine Insurance Group may be disclosed to for one or more of the above Purposes, include but are not limited to the following:

  1. financial institutions who may have a need for such personal data in order to provide the financial products that you have purchased pursuant to the services provided by Tokio Marine Insurance Group (including without limitation any brokers and lawyers);
  2. employers, officers, directors and agents of Tokio Marine Insurance Group;
  3. Tokio Marine Insurance Group’s related companies (to comply with Tokio Marine Insurance Group’s related companies’ policies and procedures);
  4. Tokio Marine Insurance Group’s lawyers and auditors;
  5. any third party vendors employed or engaged to provide administrative, computer or other services or facilities to Tokio Marine Insurance Group;
  6. any partnering company / organization which Tokio Marine Insurance Group collaborates with to provide services / products to you; and
  7. any regulatory authority, government, dispute resolution or statutory body in Singapore and/ or other jurisdictions.


4  REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1  You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request by using the online form accessible at the Contact Us section of this website.


4.2  For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest reasonably possible time within which we can provide you with the information requested. Please note that the PDPA exempts certain types of personal data from being subject to your access request.


4.3  For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:


(a)  correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Please note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and


(b)  subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by Tokio Marine Insurance Group 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.


4.4  Notwithstanding paragraph 4.3(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.


4.5  We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee that we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.


5  REQUEST TO WITHDRAW CONSENT

5.1  You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting a written request to us.


5.2  We will process your request to withdraw consent within a reasonable time, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.


5.3  However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us and the insurance policy or policies you have with us will have to be terminated.


6  ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1  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 Tokio Marine Insurance Group to make a decision that affects you, or 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 to us. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided to us.


6.2  We will also put in place reasonable security arrangements to ensure that your 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 your personal data by third parties which are wholly attributable to factors beyond our control.


6.3  We will also put in place measures such that your 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.


6.4  Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or applicable law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.


7  COMPLAINT PROCESS

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


7.2  Please contact us through one of the following methods with your complaint or grievance:


7.3  Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.


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


8  UPDATES ON DATA PROTECTION POLICY

8.1  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.


8.2  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 our website and can be viewed at https://powerup.tokiomarine-life.sg/data-protection-policy


8.3  You 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. Your continued use of any of our Online Services following the posting of a revised version of this Data Protection Policy will constitute your acceptance of the revised Policy. If you do not agree with the revised Data Protection Policy, do not use any of our Online Services.

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