We are serious about our responsibility to look after the information you give us. We collect various information about you when you use the Pulse App. This notice tells you:
For data collected and/or processed through the Pulse App in its own name and account, the personal data user or controller is Prudential Services Asia Sdn Bhd (the “App Provider”, “our” “us” or “we”) and Prudential Assurance Company Singapore (Pte) Limited, each acting as a separate data user or data controller.
For data collected and/or processed by the Hosted App Providers, or by the App Provider on behalf of the Hosted App Providers, the personal data user or controller will be the respective Hosted App Providers who will process your personal data in accordance with their privacy notices, as the case may be.
Providing your personal data is voluntary. However, if you do not provide your personal data, we may be unable to register you for the Pulse App or provide the Pulse App Services or your use of or access to the Pulse App may be otherwise limited.
We collect the following data about you:
(a) Personal data you provide:
(b) Personal data we collect from other sources:
(c) Personal data we collect automatically when you use the Pulse App:
(d) Personal data we collect through cookies or other similar technologies.
These items may include the following, for example (as may be applicable):
If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means that these advertisements will not be personalized for you using first-party or third-party cookies, web beacons, or similar technologies.
We will use/share your data to conduct direct marketing campaigns to offer Pulse App and insurance related services, including from the Hosted App Providers and their Business and Marketing Partners and members of Prudential Group and their Business and Marketing Partners and to offer you insurance and finance related products; and other products and services provided by the above-mentioned parties or other partners.
The information used/shared will be your name and any contact details (including those obtained from your use of a third party login) you have provided through your use of the Pulse App. We will only do this if (where applicable laws and regulation apply) you have given your consent in a way that is required by laws or regulation
We use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless we have obtained your consent (when required by applicable law or regulation), or we are required by applicable law to use such technology.
We may deploy data analytics tools to monitor Pulse App and Pulse App Services usage to provide us with information to be used in deciding whether to make changes to the Pulse App and Pulse App Services and to conduct profiling such as marketing profiling. We may also collect and use technical data and related information including but not limited to technical information about your device including its system and application software, and peripherals, to facilitate the provision of updates, product support, and other services to you related to the Pulse App.
We process your personal data based on the following:
Where applicable laws and regulations allow, we may also process your data based on the following:
However, for the processing of your personal data where applicable law or regulation requires prior consent, such as, but not limited to, where the processing involves sensitive personal data (including Health Data), where the processing involves automated-decision making or profiling, or where the processing involves the sending of direct marketing and/or promotional communications, our processing of your personal data will be based on your explicit consent only.
We may disclose your personal data to entities in the Prudential Group and their Business and Marketing Partners to the extent necessary for them to assist us with fulfilling the above purposes or in accordance with any consent you have given.
Where we collect your personal data on behalf of a Hosted App Provider, we disclose your personal data to that Hosted App Provider or as they may direct. Please see the privacy notice of the Hosted App Provider for their practices relating to your personal data.
We may also pass on your personal data to any legal, regulatory or government bodies, law enforcement authorities, government officials, and/or a third party where required by law or regulation
We may process your personal data 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.
For more details on our security and data management processes, please contact us.
Your personal data will be stored by us in accordance with applicable data protection laws to the extent necessary for the processing purposes of this Privacy Notice, and specifically, for the following periods:
Your personal data will be deleted or anonymised after the relevant limitation or retention periods have expired.
Please update your details as directed on the Pulse App if any details you have provided to us in your registration changes (e.g., if you change your e-mail address, telephone number). Please use the details below to contact us with any requests to do with your data.
Title / Designation:
Attention: Privacy Officer, Prudential Services Asia Sdn Bhd, Tingkat 15, Menara Prudential, Persiaran TRX Barat, 55100 Tun Razak Exchange, Kuala Lumpur, Malaysia
Contact details :
We will respond to and action all requests within the time limits required by applicable law and regulation. We may refuse to action a request to correct or provide access to personal data where the law allows or requires us to do so. For security reasons, we may take steps to authenticate the identity of the requesting party before responding to a request.
In those countries where we are required to do so by law, we have appointed data protection officers to oversee the protection of your personal data. If you have any questions about this Privacy Notice or about data protection at the App Provider or have complaints regarding this Privacy Notice or our handling of personal data, you can contact us through the Pulse Helpdesk above.
Language: To the extent there is any inconsistency between the English version and an official local translation of this Privacy Notice, the English version shall prevail.
Hosted App: Other than as expressly stated, this Privacy Notice does not apply to collection, use or disclosure of your personal data by a Hosted App Provider in relation to their Hosted App. Please see the privacy notice applying to the Hosted App.
Definitions: Capitalised terms not defined in this Privacy Notice shall have the meaning given to them in the Pulse App Terms and Conditions.
"Prudential Group" means Prudential Plc and any affiliates of Prudential Plc
"Business and Marketing Partners" means service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers/retakaful operators, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance/takaful product providers, advertising providers and legal advisers.
Amendments: We may amend this Privacy Notice at any time by communicating such change to you. The amendment takes effect on the date stated in the notice or, if no date is stated, on the date the communication is made. If you do not agree to the Privacy Notice as amended, you should not use the Pulse App and you should deregister your account as directed on the Pulse App.
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