As a dedicated Financial Consultant, I take my responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPa”) seriously. I also recognise the importance of the personal data you have entrusted to me and believe that it is my responsibility to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how I collect, use, disclose and/or process the personal data you have provided to me, as well as to assist you in making an informed decision before providing me with any of your personal data.

If you, at any time, have any queries on this policy or any other queries in relation to how I may manage, protect and/or process your personal data, please do not hesitate to contact me at: stevelimzx@pruadviser.com.sg

1 INTRODUCTION 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 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 I will collect your personal data in accordance with the PDPA. I will share with you of the purposes for which your personal data may be collected (please read on), 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 me to collect and process your personal data without your consent.

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

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

(a) processing your enquiries and application for generating quotations, financial review services and products by my company, Prudential, as well as services and products by other external providers provided through my agency like General Insurances from third party companies and other services which you may require as my client/prospect;
(b) providing you with the services and products of Prudential, as well as services and products by other external providers provided through my agency, PaceSetters Organisation;
(c) administering and/or managing your insurance portfolio with Prudential and any other companies;
(d) carrying out your instructions or responding to any enquiries by you;
(e) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures (including but not limited to those designed to combat financial crime, “know-your customer”, anti-money laundering, counter-terrorist financing or anti-bribery), that may be required by law or that may have been put in place by Prudential;
(f) dealing in any matters relating to the services and/or products which you are entitled to under this Agreement (including the sending of greeting cards and the printing and mailing of correspondence, statements, invoices, confirmations, advices, information, reports 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);
(g) if consented by you via your registration or participation in any contest, lucky draw, campaign, promotion, event, survey or questionnaire, to administer and provide you with such activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your personal data, so we suggest that you read these carefully;
(h) complying with applicable law in administering and managing your relationship with me as your financial consultant;
(i) any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
As the purposes for which I may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, I 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.

2.2 In order to conduct our business operations more smoothly, I may also be disclosing the personal data you have provided to us to 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 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, I will not disclose your personal data to third parties without first obtaining your consent permitting me to do so. However, please note that I 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 authorised based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) 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;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) 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, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.

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

4 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATa

4.1 You may request to correct the personal data currently in my possession by submitting your request using voice call or mobile. For a request to access personal data, I will provide you with the relevant personal data within a reasonable time from such a request being made.

4.2 For a request to correct personal data, I will:

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

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 your request via the contact page, indicating you desire and decision to withdraw. Click HERE to go to the Contact Page.

5.2 I will process your request from such a request for withdrawal of consent being made, 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 me to process your personal data, it may mean that I may not be able to continue with your existing relationship with me.

6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1 I will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by myself and my company 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 me with. I will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating me of any changes in your personal data that you had initially provided me with.

6.2 I 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 unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, I cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond my control.

6.3 I retain personal data in accordance with legal, regulatory, business and operational obligations.

8 Cookies
8.1 Use of “cookies”

Your visit to this Website may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered through the use of “cookies”. Cookies are small bits of information that are automatically stored on a person’s web browser in their computer that can be retrieved by this Website. Should you wish to disable these cookies you may do so by changing the setting on your browser. However, you will be unable to enter certain part(s) of this Website.

9 UPDATES ON DATA PROTECTION POLICY

9.1 As part of my efforts to ensure that I properly manage, protect and process your personal data, I will be reviewing my policies, procedures and processes from time to time.

9.2 I reserve the right to amend the terms of this Data Protection Policy at my absolute discretion. Any amended Data Protection Policy will be posted here..

9.3 You are encouraged to visit this page from time to time to ensure that you are well informed of my latest policies in relation to personal data protection.

10 PERSONAL PROTECTION NOTICE

By submitting your personal data to me, you consent to me collecting, using, disclosing and processing your personal data in accordance with this Notice. I will also take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update me in the event of any change to your personal data.

In some circumstances, you may have provided personal data relating to other individuals (such as your spouse, family members or other third party including minors). You represent and warrant that you are authorised to provide their personal data to me and you have obtained their consent to the collection, use, disclosure and processing of their Personal Data in accordance with this Notice.

I reserve the right to update and amend this Notice and my Personal Data Protection Policy from time to time. I will notify you of any amendments to this Personal Data Protection Notice or our Personal Data Protection Policy via announcements on our website or other appropriate means. If we amend this Personal Data Protection Notice or our Personal Data Protection Policy, the amendment will only apply to personal data collected after we have posted the revised Personal Data Protection Notice or Personal Data Protection Policy.