The use of the Platform entails various types of personal data being provided for various purposes. Under the Personal Data Protection Act (No. 26 of 2012) (the “PDPA”), “personal data” means data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. The PDPA governs and protects the collection, use, disclose and care of personal data. Organisations will have to comply with the PDPA as well as the common law and other relevant laws that are applied in the specific industry that they belong to, when handling personal data in their possession.
Unless expressly provided otherwise, capitalised terms used in this privacy and data protection policy (the “Privacy Policy”) shall bear the respective meanings ascribed to them in the Terms of Use.
By accessing the Platform and creating a user account with InsureGuru, Users agree and consent to InsureGuru collecting, using, disclosing and sharing amongst themselves personal data, and disclosing such personal data to the Broker, licensed insurers and relevant third party service providers in accordance with the Privacy Policy. InsureGuru may engage or use any service providers (including, but not limited to, KYC solution providers and marketing solution providers) (“Sub-Processor”) for the processing of personal data or permit any such third party to process personal data.
If InsureGuru appoint a Sub-Processor, they will ensure that, prior to the processing taking place, there is a written contract in place between InsureGuru and the Sub-Processor that specifies the Sub-Processor’s processing activities and imposes on the Sub-Processor the same terms as those imposed on InsureGuru in this Privacy Policy.
- COLLECTION OF PERSONAL DATA
1.1 Users may browse the Platform anonymously. However, Users will have to create a user account in order to procure Insurance Solutions or receive more information regarding the Insurance Solutions listed on the Platform.
1.2 When creating a user account with InsureGuru, Users consent to provide their personal data including, but not limited to, name, identification/passport number, email address, mailing address and phone number.
1.3 Users may create a user account using social media credentials as provided for on the Platform from time to time. In doing so, Users consent to InsureGuru collecting personal data that may be available through such social media networks, including but not limited to Facebook.
1.4 Users authorise InsureGuru to process and store such personal data for the purposes provided for in paragraph 2.1 and if applicable, verify such credentials with the relevant social media network
1.5 If Users provide InsureGuru with any personal data relating to a third party, by submitting such information to InsureGuru, Users represent to InsureGuru that they have obtained the consent of the third party to provide InsureGuru with such personal data for the purposes stated in paragraph 2.1.
1.6 Users shall ensure that all personal data submitted to InsureGuru is complete and accurate. Any omission or failure to do so may prevent InsureGuru from fulfilling the purposes stated in paragraph 2.1.
1.7 Users acknowledge that all personal data submitted to InsureGuru is in compliance with all applicable laws relating to data protection including without limitation, the PDPA, the General Data Protection Regulation (EU) 2016/679 as well as the common law and other relevant laws (“Applicable Laws”). If Users are in doubt as to their rights in relation to their personal data, they should consult their solicitors or other professional advisors. - USE OF PERSONAL INFORMATION
2.1 InsureGuru uses personal data for the following purposes:
(i) to process purchase or procurement of the Insurance Solutions;
(ii) to personalise User experience and respond to individual needs;
(iii) to improve and receive feedback on the Platform;
(iv) to improve customer service and provide support services; and
(v) to send periodic emails, including but not limited to the Insurance Solutions, news, updates and related information.
2.2 The purposes listed in paragraph 2.1 above may continue to apply even in situations where the relationship between InsureGuru and the Users (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable InsureGuru to enforce its rights under any contract with the Users). - DISCLOSURE
3.1 InsureGuru may disclose personal data to the Broker and third party service providers in connection with the services provided by InsureGuru on the Platform, on condition that the disclosed personal data is kept confidential and not further disclosed.
3.2 InsureGuru may disclose personal data for legal purposes (including but not limited to compliance, enforcement of legal rights and obligations and to obtain legal advice).
3.3 InsureGuru employs security measures to protect personal data.
3.3.1 All personal data collected on the Platform is transmitted via Secure Socket Layer (SSL) technology and then encrypted into the gateway provider’s database only to be accessible by those authorized with special access rights who are required to keep the personal data confidential.
3.3.2 No personal data is stored on the server. - COOKIES
4.1 Cookies are small files that a website or service provider transfers to computer hard drives through a web browser that enables the website or service provider’s systems to recognize the browser and record certain information.
4.2 InsureGuru uses cookies on the Platform to record Users’ usage patterns and trends and customize User experience. InsureGuru may engage third party service providers to assist in such purposes. However, such third party service providers may not disclose personal data obtained in the course of their engagement to any other parties.
4.3 Users may disable the processing of cookies on their web browsers but this may prevent Users from maximising the services provided by InsureGuru. - THIRD PARTY WEBSITES
InsureGuru shall not be responsible for the collection, use, disclosure and care of personal data by any third party websites linked to the Platform. - WITHDRAWAL OF CONSENT
6.1 Users may contact InsureGuru at ask@insureguru.com to withdraw their consent to the use of personal data by InsureGuru, following which InsureGuru shall cease to further collect, use and disclose personal data of that User.
6.2 Users should be aware that the withdrawal of consent may prevent them from utilising the services provided by InsureGuru. - ACCESS TO AND CORRECTION OF PERSONAL DATA
7.1 If Users wish to make (a) an access request for access to a copy of the personal data which InsureGuru holds about the respective User or information about the ways in which InsureGuru uses or discloses such personal data, or (b) a correction request to correct or update any of such personal data which InsureGuru holds, the Users may submit their request via email at ask@insureguru.com.
7.2 Please note that a reasonable fee may be charged for an access request. InsureGuru shall inform the Users of the fees before processing the request. - ACCURACY OF PERSONAL DATA
InsureGuru generally relies on personal data provided by the Users (or their authorised representative). In order to ensure that the personal data is current, complete and accurate, User should update InsureGuru if there are changes to personal data via email at ask@insureguru.com. - TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
Users consent to the transfer of their personal data to countries outside of Singapore. InsureGuru shall take steps to ensure that Users’ personal data continues to receive a standard of protection that is at least comparable to that provided under this Privacy Policy. - RETENTION OF PERSONAL DATA
10.1 InsureGuru may retain Users’ personal data for as long as it is necessary to fulfil the purposes stated in paragraph 2.1, or as required or permitted by Applicable Laws.
10.2 InsureGuru shall cease to retain Users’ personal data, or remove the means by which the data can be associated with the Users, as soon as it is reasonable to assume that such retention no longer serves the purposes stated in paragraph 2.1, and are no longer necessary for legal or business purposes. - CHANGES TO PRIVACY POLICY
Upon any amendments to the Privacy Policy, InsureGuru shall update the Platform and notify Users accordingly. - FEEDBACK
Users may contact InsureGuru at ask@insureguru.com if there are any questions or feedback regarding the Privacy Policy. - EFFECT OF POLICY
This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of the User’s personal data by InsureGuru. - GOVERNING LAW AND JURISDICTION
The Privacy Policy shall be governed by and in accordance with the laws of Singapore.
