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Prudential Assurance Company Singapore (Pte) Ltd (PACS)

Privacy Notice

We, Prudential Assurance Company Singapore (Pte) Ltd (“PACS”), take the privacy and protection of your personal information seriously.

So, we’ve set out below information about our processing of your personal information, what rights you have, and how you can get in touch if you want to know more.

When we say personal information, we mean information about you, such as your name, date of birth and contact details. We collect personal information from you that is necessary for us to either provide you with the product or service you’ve requested or to comply with statutory or contractual requirements. Unfortunately, if you’re unable to provide certain personal information which is necessary for us to provide our products and/or services to you, we will not be able to provide you with those products and/or services.

By submitting your information to us, or signing up for any products and/or services offered and/or distributed by us, you agree and consent to PACS, and where appropriate our respective representatives, agents, third party service providers, contractors and/or appointed distribution/business partners (collectively referred to as “Prudential”), collecting, using, disclosing personal data in the manner set forth in the prevailing terms of this Privacy Notice, including any future amendments. You acknowledge and agree that PACS may, from time to time, amend and update this Privacy Notice in order to ensure it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements.

Please note that the purposes set forth in this Privacy Notice supplement but do not supersede any other consents you may have previously provided to us or which you may provide to us in the future.

We may change this Privacy Notice from time to time by updating our Privacy Notice page on our website.  We encourage you to check our Privacy Notice from time to time on our website, as the version of our Privacy Notice which is displayed on our website takes precedence over all previous versions of our Privacy Notice.

Part A – Personal information we process

  • personal and contact details, such as title, full name, contact details and contact details history;
  • your date of birth, gender and/or age;
  • your nationality (if relevant to the product or service);
  • details of fund investors, beneficiaries, such as joint policy holders and minor beneficiaries of our products or services;
  • family members (if relevant to the product or service);
  • records of your contact with us such as via the phone number of our customer service centre and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address and MAC address;
  • products and services, you hold with us, as well as those you have been interested in and have held and the associated payment methods used;
  • the usage of our products and services, any claims and whether those claims were paid out or not (and details related to this);
  • analysis of data relating to marketing made to you, including history of communications and whether you open them or click on links;
  • information about your use of products or services held with our Marketing Partners, such as insurance policies, mortgage, savings or financial services and products;
  • information we obtained from third parties, including information about insurance risk, pricing, claims history, instances of suspect fraud and usage history;
  • personal information which we obtain from Credit Reference Agencies and Fraud Prevention Agencies, including public (for example, defaults) and shared credit history, financial situation and financial history;
  • fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud;
  • criminal records information, including alleged offences;
  • information about your health or if you are a vulnerable customer if you are applying for medical or life insurance;
  • information about your property, such as location, value, number of rooms, property type and building work you’ve had done (if relevant to the product or service);
  • financial details about you, such as your salary and details of other income, details of your savings, details of your expenditure, and payment method(s);
  • details about all your existing borrowings and loans (if relevant to the product or service);
  • information about your employment status (if relevant to the product or service);
  • information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application;
  • your residency and/or citizenship status;
  • your marital status, family, lifestyle or social circumstances (if relevant to the product or service). For example, the number of dependents you have or if you are a widow or widower;
  • information we buy or rent from third parties, including demographic information, details of outstanding finance, marketing lists, publicly available information, and information to help improve the relevance of our products and services;
  • insights about you and our customers gained from analysis or profiling of customers;
  • third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction; and
  • tax information (if relevant to the product or service). For example, for investment accounts.

Part B – Where we get your personal information

We’ll collect personal information from the following general sources:

  • from you directly, and any information from family members, associates or beneficiaries of products and services;
  • information generated about you when you use our products and services;
  • when you submit an application or registration form, or any other forms relating to any products and services offered and/or distributed by us;
  • when a policyholder takes up an insurance policy for your benefit or appoints you as the life assured / insured members;
  • 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;
  • when you interact with our customer service officers, representatives, agents or appointed service providers (for example, via telephone calls, letters, face-to-face meetings, social media platforms, surveys, workshops and/or e-mails);
  • when you use our electronic services, or interact with us via mobile services, social media accounts, digital platforms, any of our websites or web services;
  • when you request us to contact you (whether pursuant to a request for more information, complaints, or any other purposes);
  • when you respond to our promotions, lucky draws, contests, events, initiatives, surveys organised by Prudential, its partners, representatives or service providers and/or any other request for personal data;
  • from a broker or other intermediary (for example, agents, distributors, business partners) who we work with to provide products or services or quote to you;
  • Prudential Group companies if you already have a product with them, have applied for one or have held a one previously;
  • cookies, location services, IP addresses when you visit our website or mobile app.
  • questionnaire and contact details when you attend surveys, investor conferences, roadshows or when you update contact us form on our website;
  • from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies; and
  • we buy or rent information about you or customers generally from third parties including demographic information, vehicle details, claims history, fraud information, marketing lists, publicly available information and other information to help improve our products and services or our business.
  • 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 our agents when you attend our events;
  • when we receive references from business partners or third parties (for example, where you have been referred by them);
  • when we receive information from third parties about you when you make payment through (including but not limited to physical and digital payment kiosks).
  • when we seek information from third parties about you in connection with the products and services you have applied for; including but not limited to from other insurers, insurance associations, healthcare institutions, clinics, investigators, ex-employer and the relevant authorities; o when you submit your personal data to us for any other reason; and/or
  • other publicly available sources where relevant and appropriate.

Part B.1 – Cookie Policy

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you use the Site and also allows us to improve our Site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is stored on your computer's hard drive. 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.

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into our secure Site;
  • Analytical/performance cookies. These allow us to recognise and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily; and
  • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

By continuing to use the Site, you accept to the use of cookies as outlined above.

Part C - How we use your personal information and why

We, PACS, Prudential Corporation Asia, the Prudential Group and our Business Partners, will use the personal information you provide to us, together with other information, for the following purposes:

Purpose

Legal basis for processing

Verifying your identity and any information you provide to us;

Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you.

Assessing and processing of any claims and payments arising under your policy including by requesting from hospitals and clinics information such as your medical reports and blood test results;

Carrying out your instructions or responding to your queries, complaints, feedback and requests and/or otherwise communicating with you in relation to your policies;

Communicating with you on updates to the policy benefits, terms and conditions and providing administrative information, including for the purposes of servicing in relation to the products and services offered

The administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service;

Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you.

Carrying out checks using agencies such as credit reference agencies, tracing companies, or publicly available information (See Part D for more);

Underwriting (including preliminary underwriting), pricing, insurance and re-insurance of your application with and/or through us;

Carrying out due diligence activities in accordance with any legal, regulatory or internal risk management obligations in relation to your application with and/or through us;

The provision of customer services - like to reply to a question, or tell you that something’s changing;

Necessary for the performance of our contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you.

Automated decision-making or profiling (see Part E for more); and

Keeping your information on record and carrying out other internal business administration. 

Administering and managing your relationship, programme and/or policy with us, which includes activities such as (i) renewing or reinstating policies, (ii) collecting any outstanding payments from you, (iii) providing you with financial health check review services; or (iv) processing any refunds to you;

Processing and dealing with any debt collections and claims (which includes the settlement of claims and any necessary investigations relating to such claims, under your policies (whether such policies have been issued by us or any other insurer)

Conducting research, surveys, analysis and development activities in order to improve the products and services we offer to you, as well as to improve the overall customer experience;

Our legitimate interests in designing and improving our products, provide value added services, developing our business and gaining insight into how our products are used.

Administering contests, lucky draws and events;

For managing our relationship with you, including notifying you of our marketing events, initiatives, promotions.

Telecommunications, information technology, payment, processing and training

Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you.

Storing, hosting, backing up of your personal data (including via clouds storage), and for otherwise managing and ensuring the efficiency and security of our IT environment and business operations;

Our legitimate interests in storing, hosting, backing up of your personal data to maintain and develop our relationship with you.

Monitoring of undesired sales practice and ensuring compliance with our own policies and standards, as well as compliance with any policies or standards throughout the Prudential group of companies;

Compliance with our PACS and PCA obligations, and other local regulations.

Managing the administrative and business operations of the Company and complying with internal policies and procedures;

Compliance with our PACS and PCA obligations.

Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;

Compliance with our legal obligations.

Complying with any legal, regulatory and good governance obligations (which may include responding to requests from public or governmental authorities);

Compliance with our legal obligations.

Conducting audit reviews;

Necessary for the performance of the contract with you and complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority

Monitoring and coaching employee and agent for quality assurance

Our legitimate interests in monitoring and coaching employee and agent to upkeep our service quality.

If you have consented – to send you marketing, advertising and promotional information about insurance, investment and/or financial products and/or services that we may be selling or marketing; and

Compliance with local regulation.

Any other such purpose which may be incidental or ancillary to any of the above purposes

If you are an employment applicant / employee / ex-employee:

In addition, PACS handles and safeguards your personal data for the purpose of administering and managing your employment with the company. The information collected for the purpose of job application and employment in PACS will be utilized by the relevant member(s) of PACS to assess and process your application and employment. If you are not successful in your application or have resigned, we may retain your information for business or legal purposes.

If necessary, to administer human capital activities, PACS may share information about you with medical practitioners and reinsurers. We will also share information with regulatory and fraud prevention agencies and with third parties who process information on our behalf including those outside Singapore with appropriate controls in place.

Who we share your personal information with and why

We’ll share your personal information within the Prudential Group and with our Business Partners, for any of the purposes set out in this Part C. If you have a joint policy or investment, the other person may receive your personal information too.

We may process your personal information in a country other than the one you are resident in. To the extent we transfer your personal data, we will use appropriate safeguards and comply with the laws of the country to which your personal information is transferred. Details of the safeguards we use are available on request.

We work with many external parties in order to provide you with a seamless experience in relation to any products and/or services you have purchased from us. In the ordinary course of business, we may be required to disclose personal data to such external parties and these external parties may be located overseas.

We only disclose your personal data, where appropriate and necessary, for one or more of the above-mentioned Purposes or as permitted by law. The external parties we may disclose your personal data to include, but is not limited to, the following:

  • within the Prudential group of companies and distribution partners / brokers / business partners / applicable group policyowners to facilitate the conduct of our business, carrying out our business activities and servicing you in relation to the products and services offered to you where appropriate and relevant;
  • our third-party service providers, sub-contractors of third-party service providers, contractors and vendors – which could include accountants, auditors, lawyers, IT service providers, business consultants, claim investigators, event managers, debt collection service providers, other such third-party service providers and sub-contractors of such third-party service providers which may assist us in carrying out our business activities;
  • medical institutions, clinics, financial institutions, credit card companies, Credit Bureau (Singapore), industry bodies, other insurance and re-insurance companies – to facilitate the processing of your applications, claims or any other insurance-related information or procedures;
  • public and governmental authorities, including regulatory authorities – to comply with legal process, to respond to requests from such parties, to detect and prevent fraud and to protect our business operations; and
  • your family, relatives, appointed executors and their professional advisers - in connection with your will(s) or the administration of your estate;
  • any business partner, investor, assignee or transferee (actual or prospective) - to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies; and
  • any other party whom you authorize us to disclose your personal data to.

Accuracy and protection of personal data

We will take reasonable efforts to ensure that any personal data we have about you is accurate and complete. However, this means that you must also update us of any changes to the personal data that you had initially provided to us in a timely fashion.

We will also take reasonable efforts to protect the personal data in our possession by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or any similar risks.

Third-Party Sites

Our website may contain links to other websites operated by third parties, which may be co-branded with our logo or trademark, even though they are not operated or maintained by us. We are not responsible for the privacy practices of such third parties that are linked to our website. Once you have left our website, we strongly encourage you to refer to the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

We keep your personal information for a set amount of time

Your personal information will be stored either for as long as you (or your joint policyholder) are our customer, or longer if required by law or as is otherwise necessary. It’ll always be in line with our data retention policy.

Part D - Reference checks

For certain products, we may use approved credit reference agencies, tracing companies, financial crime prevention agencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering; this may include checks on your current or previous addresses. Results of these may be recorded for future reference.

These checks may also be carried out for a fund investor, joint policy holder or person(s) that you provide personal information on. Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch.

Any transfer of your personal information will always be done securely.

Part E – We may use your personal information to make automated decisions or profile you

We, PACS, Prudential Corporation Asia, our Business Partners, and our Marketing Partners may use your personal information to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling).

To the extent that we conduct such automated decision-making activity, we’ll provide you with further information at the appropriate time.

Part F – Use of your sensitive personal information

For certain products or services, we’ll need to process your sensitive personal information, such as information relating to health, genetics, biometric identifiers and sexual orientation. To the extent that we need your explicit consent to process this kind of personal information in the manner described in Parts C, D, and E, we will provide details of this at the point of collection and seek your consent.

Part G – You’re in control

When it comes to how we use your personal data, you have the right to:

  • request a copy of your personal data (we have the right to charge a reasonable fee to complete this request);
  • request that we correct anything that’s wrong, or complete any incomplete personal data;
  • complain to a data protection authority or another independent regulator about how we’re using it.

If you currently reside in an EU jurisdiction, additional rights under General Data Protection Regulation (GDPR) may apply. As such, you may:

  • ask us to delete your personal data if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing;
  • object to us using your personal data for direct marketing (including related profiling) or other processing based on legitimate interests;
  • request that provide a copy of your personal data in a structured and commonly used format in certain circumstances1; and
  • limit how we use your personal data or withdraw your consents (including automated decision making) you have given for the processing of your personal data.

If you want to exercise your rights, or would like an explanation about these rights, we’ve explained how you can get in touch in the Contact Us section.

If you do need to speak to us, it’ll be useful to have to hand that the data controller2 of your personal data is PACS. We may monitor or record calls or any other communication we have with you. This might be for training, for security, or to help us check for quality.

Part H – Acting on someone else’s behalf?

If you give us personal information about another person (or persons), we’ll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

  • our processing of their personal information and sensitive personal information (as we’ve explained in Parts A - G above); and
  • you are getting any information protection notices on their behalf.

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us at the email address below before sending us anything.

Part I – Direct marketing

We PACS, Prudential Corporation Asia, our Business Partners, and our Marketing Partners will still send you information by post about our and the Prudential Group’s products and services and carefully selected third parties.

Additionally, from time to time, we PACS, Prudential Corporation Asia, and the Prudential Group would like to contact you by electronic means with details about products, services and any special offers. We will only do this if you have consented to us contacting you by electronic means.

And if you change your mind, and / or you would like to opt-out of receiving non-electronic direct marketing, it’s easy to let us know through the following channels:

  • If you do not wish to receive marketing materials from your PACS representative, please write to your PACS representative at their usual contact address.
  • If you do not wish to receive marketing materials from PACS, please use the Update of Contact Information Form or Pruaccess.

For any further queries, please write to us at the address below or email us at customer.service@prudential.com.sg.

Contact us
If want to exercise your rights in Part G or if you require any other information about any other part of this notice, you can contact us in several different ways.

For customers, contact us at:
Prudential Customer Centre
5 Straits View #01-18/19, Marina One The Heart, Singapore 018935
customer.service@prudential.com.sg
1800 333 0 333

For employment applicants/ employees/ex-employees, contact us at:
Pacs.hr@prudential.com.sg

If you wish to contact PACS about a Data Protection concern, please write to The Data Privacy Officer at:
Data.Privacy@prudential.com.sg.

If you withdraw your consent to any or all use of your personal data, depending on the nature of the request, we may not be in a position to continue administering any existing contractual relationships with you, which result in certain legal consequences. This may 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.

Prudential Corporation Asia means Prudential Corporation Asia Limited.

The Prudential Group means Prudential Plc, Prudential Holdings Limited and any other affiliates of Prudential plc. Prudential Plc is not affiliated in any manner with Prudential Financial, Inc. a company with principal place of business is in United States of America or with the Prudential Assurance Company, a subsidiary of M&G Plc, a company incorporated in United Kingdom.

Business Partners means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, and our legal advisers.

Marketing Partners means our service providers, intermediaries, pension trustees (and other stakeholders), scheme advisors, introducers and selected third party financial and insurance product providers.


1
We will provide any electronic information (not paper records) that we hold and only that which you provided to us – we will not provide the results of any processing carried out on that data.
2Data Controller - Natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.