India International Insurance Pte Ltd (“III”)
Updated as at 2 Nov 2020
1. Overview and Scope
Your personal data privacy is important to us and India International Insurance Pte Ltd (“III”) is highly committed in respecting and managing your Personal Data collected in line with this Policy.
2. When and what kind of Personal Data do we collect?
III may collect, use and disclose the following data about you:
- When you provide Personal Data by filling in online or hardcopy forms when applying for III’s products and services or feedback (i.e. surveys), asking queries, requests and other submissions;
- If and when you contact III (i.e. telephone calls, website, emails, face to face meetings), we may keep a record of that correspondence;
- Details of your visits to III’s website including, but not limited to, cookies, location data and other communication data, that you access;
- When you fill up online and hardcopy job or internship application form to apply for a job or internship at III;
- If you make contact with any of our authorized representatives, brokers, agents, partners, accident reporting centres and workshops and other third party service providers and vendors, we may keep a record of that correspondence;
- If you enter into any contract with III or purchase any products/services from III;
- If you participate in any exhibition or event organised by III or where III is a participant;
- If and when you respond to any of III’s marketing and publicity emails, newsletters and other materials;
III may collect the following kinds of Personal Data through the different channels mentioned above:
- Full name;
- Date of Birth;
- NRIC/IPA/WP/FIN/Passport numbers and copies, if necessary;
- Business and/or residential addresses;
- Business and/or personal email addresses;
- Mobile and business telephone numbers;
- Photos and videos (including CCTV), if applicable;
- Bank account and credit card details;
- Next of Kin, family and emergency contact information;
- Medical and insurance information, if necessary;
- Insurance claims history;
- Legal, bankruptcy and financial history;
Additionally, if you are applying for employment with III, III will collect the following:
- Marital Status;
- Educational history and qualifications;
- Employment history and professional qualifications, including testimonials and information disclosed about references, if necessary;
- Curricula Vitae, if any;
3. What purposes does III Collect, Use and Disclose Personal Data?
III may use the information we collect from you for any of the following purposes:
- To perform or carry out III’s obligations arising from any contracts entered into between you and us;
- To enable III’s subcontractors, third-party agents, service providers and partners, to fulfil obligations/services as stipulated in your contract with III (e.g. accident reporting centres and workshops, investigators, surveyors, emergency medical evacuation service providers, etc.);
- To handle products and services requests and enquiries from customers and claimants, including obtaining survey reports needed for underwriting purposes and medical reports and other reports as supporting evidence for claims;
- For payment and financing administration purposes;
- To administer and update your records in our databases; monitoring and maintaining a copy of your record of previous transactions;
- To facilitate the delivery, maintenance and enhancement of III’s products and services for customers, including for underwriting purposes;
- To plan, monitor, and enhance the provision of new products, services, projects, and planning of events for customers;
- For legal, investigations and litigation matters, if required;
- To improve III’s customer service through your feedback;
- To facilitate data analysis and business planning purposes;
- To process your enquiries and any and all other ancillary administrative purposes;
- For communications, sales and marketing efforts and leads generation and publicity purposes;
- For vendor and service provider management and communications purposes, including provision of medical services;
- For government, compliance, audit and other regulatory purposes, including to MAS, SDIC and GIA, AML/CFT, background and credit checks;
- For recruitment and evaluation purposes if you apply for a job with III, i.e. to determine job suitability;
- To apply for employee work visas at the Ministry of Manpower;
- For security and access controls, safety surveillance, monitoring, reporting and communication purposes, especially in emergency situations;
- For internal approval and reporting and/or accounting purposes; and
- Purposes incidental to each or all of the above.
We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.
By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers (as set out in no.3 of “What purposes does III collect, use and disclose personal data?”) and the processing of your Personal data by these agents or service providers.
We only collect, process, use or disclose such Personal Data, in accordance with this policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy by referring them to our agencies’ website.
4. Consent for the collection and use of your Personal Data
In this regard, please note that it is on your part to ensure that all personal data submitted to us is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Please note that if you do not consent to any of the above business purposes, III may also be unable to meet the purposes for which the information was collected.
5. Does III disclose Personal Data to third parties?
III may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).
On occasion, III may use third party agents and service providers to assist us in the use of your Personal Data as outlined under "What purposes does III Collect, Use and Disclose Personal Data?" You consent to such use of your Personal Data by continuing to browse on III’s website or continuing to engage with III.
III will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.
6. For how long does III retain your Personal Data?
III will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
When you visit any of III’s websites, III may collect or analyse anonymized information from which individual information will not be identified. The information collected may include the number of users and the amount of time they stay on our website, which countries they are from, and what mode of device they are currently using to view our website, as well as domain information that helps us to learn our client’s profile, the frequency of viewing. We use this information to improve our website’s content and navigation.
Note that our cookies do not have an expiration date and do not collect personally identifiable information.
8. How does III protect your Personal Data?
The Personal Data that we hold about you is stored on on-site servers located at III’s office in Singapore and on AWS cloud in Singapore (through our third party IT vendor). III implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, III cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
9. Links to third party websites from III’s website
10. Access and Correction of Personal Data
Please contact us via firstname.lastname@example.org should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
11. Further Information
III reserves the right to change this Policy with or without notice from time to time.