SingHub complies with the Singapore Personal Data Protection Act 2012 (the “Act”) for the collection, use, and disclosure of your personal data. We will ensure that:
- only fair, proper and legitimate means are used to collect your personal data;
- personal data collected is used in accordance with the purpose for which personal data is collected;
- personal data collected is protected by appropriate safeguards and made available only to authorised persons; and
- you have the right to access and request correction of your personal data.
Please read this Statement of Personal Data Protection (the “Statement”) so that you know and understand how SingHub collects, uses, and discloses your personal data.
By interacting with us, submitting information to us, signing up for any product or service offered by us, you agree and consent to SingHub and its affiliates, as well as our Representatives (the companies and Representatives collectively referred to as “SingHub”, “us”, “we” or “our”) collecting, using, disclosing and sharing your personal data amongst SingHub, and disclosing your personal data to SingHub’s authorised service providers, contractors and business partners in the manner set forth in this Statement, including any future amendments.
In addition, this Statement will provide you with more information on the bases upon which we collect, use and/or disclose your Personal Data without your consent, where permitted by applicable laws.
This Statement supplements but does not supersede or replace any other consent you may have previously provided to SingHub in respect of your personal data. Your consent are additional to any rights which to any of the SingHub may have at law to collect, use or disclose your personal data.
1. Personal Data Protection Principles
Personal data is defined as 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. Examples of personal data will include your date of birth, health, education and employment information.
In handling your personal data, we abide by the following personal data protection principles:
1.1 Notification of purpose and consent
(a) Unless otherwise required or permitted by law, we will notify you of the purposes for which we intend to collect, use or disclose your personal data. This will occur at or before the time of the collection, use or disclosure. We limit the personal data we collect to that which is necessary for, or related to, these purposes.
(b) Unless otherwise required or permitted by law, we will only collect, use or disclose personal data with your consent.
(c) You may withdraw your consent for us to collect, use and disclose your personal data.
1.2 Access and correction
(a) Upon written request, we will provide you with access to your personal data and information about the ways in which your personal data may have been used or disclosed in the past year, as required or permitted by law.
(b) You may also verify the accuracy and completeness of your personal data, and request for it be amended or deleted, where appropriate. We will respond to these requests in accordance with our personal data practices and policies and in accordance with the law.
1.3 Accuracy
(a) We will take reasonable efforts to keep your personal data accurate and up to date as it is necessary to fulfil the purposes for which the data was collected and used. For this reason, you must also update us of any changes to your personal data as promptly as you can.
1.4 Safeguards
(a) We will take reasonable efforts to protect your personal data with security safeguards that are reasonable and appropriate to the sensitivity of the personal data, in order to protect it from unauthorized access, use, modification, disclosure, or disposal.
(b) We are responsible for personal data in our possession, including information transferred to service providers who perform duties on our behalf. When we share personal data with our service providers, they must protect the shared personal data in ways that are consistent with our privacy policies and practices.
1.5 Retention
(a) SingHub Singapore complies with applicable regulatory requirements with respect to the retention of personal data.
1.6 Accountability
(a) We have designated individuals who are responsible for monitoring our ongoing compliance with the Act. (See Section 9 below.)
(b) We will make information about our personal data protection policies, practices and complaint process available to you through this Statement, and upon request.
2. Notice to You
2.1 Personal data we collect
We may collect the following personal data from you:
(a) General identification and contact information (title, full name, address, email address, telephone number, age, date of birth, gender, marital status, citizenship, nationality, residency status, education etc);
(b) Identification numbers issued by government agencies (NRIC number, passport number, foreign identification number, birth certificate number, etc);
(c) Financial information and account details such as salary and other income, assets, liabilities, spending (expenditures), credit card information (credit card number, name on credit name), bank account information (account number, statement, account details) etc);
(d) Employment information (employment status, name of current and past employer, current and past occupation, annual declared salary etc);
(e) Medical and health information (health status, injury or disability information, medical and procedures performed, smoking status, family medical history, etc);
(f) Information about your investment knowledge and risk tolerance;
(g) Tax information;
(h) Information from cookies, IP address, type of operating system, time and duration of your visit to our Site, internet locations you came from, web pages you visit in our website, browser and device you are using, date, and number of times you visit our website, information you input into our website or similar technologies, in order to enable or enhance the functionality of our website, or to analyse visitor traffic for marketing or other purposes;
(i) images, photographs, videos, CCTV footage, voice recordings and electronic communications;
(j) Information relevant to the provision of financial products (insurance coverage with other insurers, claims experience, employment information, driving or criminal record, travel record, etc);
(k) Information about family members and other persons who might be designated as beneficiaries or trustees under an insurance plan or trust; and
(l) Information obtained from third party(ies) in instances of suspected fraud, criminal records information, debt and theft information etc.
2.2 Where we collect personal data
We may collect your personal data in the following ways:
(a) when you submit an insurance application form or any other forms relating to any products and services offered and/or distributed by us;
(b) when a policyowner takes up an insurance policy for your benefit or appoint you as the life insured or other roles such as beneficiaries or trustees;
(c) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
(d) when you interact with our Customer Service Officers, Representatives or appointed service providers (telephone calls, letters, social media platforms, surveys, emails etc);
(e) when you use our electronic services, or interact with us via our website or use services on our website;
(f) when you request us to contact you (on your request for more information about product or service, complaints or any other purposes);
(g) when you update the Contact Us form on our website;
(h) when you respond to our promotions, lucky draws, contest, events, initiatives, surveys organised by SingHub Singapore, our Representatives or service providers and/or any other request for personal data;
(i) from a broker or other intermediary (e.g.: distributors, business partners) who we work with to provide products or services or quote to you;
(j) cookies, location services, IP addresses when you visit our website;
(k) when your images are captured by us via CCTV cameras while you are within any of our premises, or via photographs or videos taken by us, our Representatives or service providers when you attend our events;
(l) when we receive information from third party(ies) about you when you make payment;
(m) from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, publicly available directories and information (e.g.: social media, internet, news articles etc), debt recovery and/or other organisation to assist in prevention and detection of crime, police and law enforcement agencies;
(n) when we seek information from third party(ies) about you in connection with the products and services you have applied for; including but not limited to from other insurers, insurance associations, healthcare associations, clinics, investigators, ex-employer and the relevant authorities; or when you submit your personal data to us for any other reason;
(o) other publicly available sources where relevant and appropriate; and/or
(p) when you submit an application to use as a candidate for an employment or Representative position or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, Representative or any other position.
2.3 How we use personal data
The purposes for which personal data of our clients may be collected or used will vary depending on the nature of your relationship with us. For example, we may use your personal data to:
SingHub contracts with advertising agencies, marketing firms, website & IT providers to promote our products and services, including on third-party websites that are not affiliated with us. These contracted service providers may employ interest-based or online behavioural advertising techniques in order to display advertisements that are more likely to be of interest to you.
We use web analytics services to analyse the use of our website. These tools use cookies to collect and generate information about your visits to our website (including your IP address) that is transmitted to their servers in an anonymous form for processing. We study patterns of website activity so we can improve the experience of visitors to our sites.
(a) confirm your identity and uniquely verify your identity;
(b) confirm the accuracy of the information collected;
(c) evaluate, underwrite (including preliminary underwriting) and price your application, and assess the insurance risks we are assuming during any insurance coverage changes or renewals;
(d) determine and verify your ability to afford the financial and insurance products you apply for;
(e) properly administer the products and services we provide, including the investigation, review, assessment and settlement of claims;
(f) communicate with you, especially with respect to your policy, updates and changes;
(g) provide you with ongoing services (including annual review of your plans) and respond to your queries,
feedback, requests or instructions;
(h) make or obtain payments;
(i) recover any debts owed to us;
(j) detect, investigate and prevent errors, misrepresentations, fraud, or other unlawful or improper activities;
(k) coach employees and monitor for quality assurance;
(l) comply with all legal and regulatory requirements within and outside Singapore including disclosures to judicial, regulatory, government, statutory authorities and industry entities;
(m) resolve complaints, managing and preparing on incidents and handle requests for data access or correction;
(n) conduct compliance monitoring, audit reviews and pre-recruitment checks;
(o) facilitating, conducting interviews with candidates (employment or Representative position) and assessing your suitability for the applied position;
(p) compile statistics to design and improve products and services, or participate in industry exercises and studies;
(q) assist us to understand the current and future needs of our clients, for example, to conduct surveys and other forms of market research and analysis;
(r) use your health and wellness data received from the supporting trackers, including but not limited to Apple HealthKit, Samsung Health, Google Fit, Fitbit framework will be used to help you track your health and wellness activities, provided such data will not be used or shared with third parties for the purposes of serving advertising;
(s) perform any functions and activities related to products or services including but not limited to marketing, audit, reporting, research, analysis, reinsurance, general servicing and maintenance of online and other services;
(t) administering contests, lucky draws and events;
(u) design, promote, improve and further the provision of our financial products, services and promotions;
(v) conduct checks with the National Do Not Call Registry and our internal Do Not Call Registry;
(w) comply with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies (whether within or outside Singapore) that is assumed by or imposed on us or any member of our group of companies by reason of its financial, commercial, business or other activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognised bodies;
(x) for operational purposes, credit assessment, credit scoring models or statistical analysis (including in each case, behaviour analysis and evaluation of the overall relationship with our group of companies which includes using such data to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within our group of companies and/or other use of data and information in accordance with any group¬wide programmes for compliance with extraterritorial enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities), whether on our clients or otherwise;
(y) exercise any rights we may have in connection with the provision of insurance products and financial services to you;
(z) enable an actual or proposed assignee, transferee, participant or sub-participant of our rights or business to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;
(aa) market insurance and other financial products where specifically or deemed consented to or where permissible under applicable laws or regulations;
(bb) for any other purposes specifically provided for in any particular product or service offered by us or permitted or required by law or the relevant authorities;.
(cc) personalize and enhance your experience while you are visiting or using our Websites and Apps and make navigation easier;
(dd) enable you to use our online planning, digital advice, or investment strategy tools;
(ee) allow our web server to determine whether the cookies setting on your web browser has been enabled or disabled so that we will know whether data can be collected from your web browser;
(ff) track your visits to our website and recognize your web browser when you are a repeat visitor so that we can gather statistics on the number of new and repeat visitors and evaluate our website effectiveness;
(gg) deliver targeted advertising of SingHub Singapore products and services on our website; or
(hh) enable contracted third parties to perform services or functions on our behalf. They are required to safeguard the information we share with them and can only use it for our contracted business purposes.
In some circumstances we may anonymize your personal data so that it no longer identifies you, and therefore allowing us to retain and use such anonymized data without restriction, including for data analytics.
2.4 To whom we disclose personal data
Personal data held by us will be kept confidential, but we may disclose or transfer such personal data to the following persons and/or entities (whether within or outside Singapore) for any of the purposes set out in Section 2.3 above:
We will not share your personal information, without your consent, with any organization outside SingHub for the purpose of marketing our products or services to you.
(a) any person in connection with any claims made by or against or otherwise involving our clients in respect of any insurance products and financial services;
(b) medical institutions, clinics, financial institutions, credit card companies, credit reference agencies (including any debt collection agencies), industry bodies, other insurance and reinsurance companies (including proposed reinsurers) for facilitate the processing of your applications, claims or any other insurance-related information or procedures;
(c) any agent, contractor or third-party service provider who provides administrative, consultative, telecommunications, computer, information technology, payment, data processing or storage, claim investigation, or any member of SingHub group of companies in connection with the operation of our business, including any custodian, administrator, investment manager, investment consultant or distributor;
(d) any financial consultant, bank partner, broker, introducer or other intermediary (including their employees);
(e) employers of our client, your past employer(s) for pre-recruitment checks;
(f) any person which has undertaken to us or any member of SingHub group of companies to keep such personal data confidential;
(g) any member of SingHub group of companies, where such a disclosure is required for the provision of financial products or services to you;
(h) any person to whom we or any member of SingHub group of companies is under an obligation or otherwise required to make disclosure under the requirements of any laws, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to us or any member of SingHub group of companies including but not limited to any local or foreign regulators, governmental bodies, or industry recognized bodies; or
(i) any person to whom we or any member of SingHub group of companies is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies that is assumed by or imposed on us or any member of SingHub group of companies by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognized bodies.
3. Withdrawal of Consent
You may withdraw consent for us to collect, use or disclose your personal data for any purpose (e.g. sending you marketing messages) by emailing us at Upon receipt of your notice to withdraw consent, we will inform you of the likely consequences of the consent withdrawal. In some cases, withdrawing your consent may have an impact on our ability to provide financial products and services to you or to process your claims.
This may also be disadvantageous to you, as you may lose valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.
4. Transfer of Personal Data Outside of Singapore
We operate our business in Singapore and for contractual, legal or business reasons, we may transfer personal data to any member of SingHub of companies or service providers located outside Singapore. We will use legally binding instruments and other safeguards to ensure that appropriate levels of protection necessary to maintain the security of your personal data are in place and that any transferred personal data is processed only in accordance with the Act and any other applicable laws and regulations.
5. Personal data of another person
If you give us personal information about another person(s), we will assume that they have appointed and authorised you to act on their behalf.
This includes providing consent to:
- Our processing of their personal information as mentioned above; and
- You are receiving our information protection notices on their behalf.
6. Use of Cookies
Cookies are small text files that may be automatically stored on your browser that can be retrieved by our website. Cookies collect and store information about your browsing patterns and information you provide.
We may use cookies to enable or enhance the functionality of our website, or to analyse visitor traffic for marketing or other purposes. We may also use web analytic consultants to research certain usage and activities on our website. Cookies can make our website more useful by storing information about your preferences, thus enabling us to provide a more personalized service to you.
Most web browsers are initially set to accept cookies. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, by disabling them, you may not be able to use certain functions or enter certain parts of our website.
By continuing to use our website, you accept the use of cookies as outlined above.
Our web pages may also contain electronic images known as web beacons. Web beacons are sometimes referred to as “clear GIF images”, “pixel tags” or “single-pixel GIFs”. Web beacons are usually invisible to a user and are used for many of the same purposes as cookies.
7. Changes to this Statement
We reserve the right to modify or change this Statement from time to time on our website. We encourage you to check this Statement periodically to read and understand our latest policy and practices regarding the handling of your personal data.
The date as stated below indicates the last time this Statement was revised.
8. Contact Information
For any complaints, questions, concerns about our personal data protection policies and practices, withdrawal of consent, or to request access to, update or correct the personal data within our possession and control, please contact:
Email: [email protected]
You may also direct certain correction requests or withdrawals of marketing consent to our Client Services Officers or email to [email protected]
Last revised on 27 September 2023