Privacy Policy

1. INTRODUCTION

1.1 This Privacy Policy sets out PolicyPal's policy regarding the collection, use, and disclosure of any information you may provide when you access and use its website www.policypal.com via desktop or mobile App (the "Website"), or the services provided by PolicyPal. It is intended to be read together with PolicyPal's Terms of Service. By accessing and using the Website, you are deemed to have read, accepted, and agreed to be legally bound by the terms of this Privacy Policy and PolicyPal’s Terms of Service, regardless of whether you have registered as a user.

1.2 PolicyPal reserves the right to amend this Privacy Policy without prior notice. Any use of the Site after such amendment shall be deemed acceptance of the amended Privacy Policy in its entirety. If you do not agree to this Privacy Policy, please immediately discontinue your access to, and use of, the Website.

1.3 This Privacy Policy does not apply to third party websites you may access through, or in the course of your use of, the Website. Your rights in relation to those third parties will be governed entirely by the privacy statements and/or terms and conditions of those third party websites.

1.4 This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.

2. COLLECTION OF INFORMATION

When you access or use the Website or any part thereof, or communicate with PolicyPal or any of its officers, employees or agents, whether through written, published or electronic means, the telephone or otherwise, PolicyPal may collect or receive personal or non-personal information or data about, in connection with or from you, including, without limitation, through cookies, pixel tags, website and data analytics, and other technologies, in accordance with the Personal Data Protection Act 2012 ("PDPA"). Personal information or data may include, without limitation, your name, contact information, user profile, and information about your financial status. Non-personal information or data may include, without limitation, your browser information, internet protocol (IP) address, how you use the Website or any part thereof, and aggregated information. PolicyPal will, as far as possible, inform you at each collection point as to what information is required and what information is optional.

3. USE OF INFORMATION

PolicyPal uses the collected information:

  1. for the specific purpose for which the information was provided;
  2. to confirm your identity and ensure that you are eligible to access and use the services provided on the Website;
  3. to process and, where necessary, respond to your application(s), enquiry(s), or request(s);
  4. for the purposes of accessing any services provided by Policy Pal, including transmission to third party agents in order to process a review of your insurance coverage;
  5. to conduct due diligence checks on you in accordance with all applicable laws and PolicyPal's internal 'know your client' and Anti-Money Laundering/Countering the Financing of Terrorism policies;
  6. to enable PolicyPal to comply with all of its legal and regulatory obligations;
  7. to inform or update you about products, or services that you request from PolicyPal or that may interest you, where you have consented to be contacted for such purposes;
  8. to update you on changes to the Website or PolicyPal's operations;
  9. to monitor, improve, and administer the Website and the services provided through it;
  10. to conduct statistical or other forms of analysis for purposes of maintaining or improving the Website and PolicyPal's services in general; or
  11. to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.

4. DISCLOSURE OF INFORMATION

PolicyPal will not sell or rent your personal information to any third party. Information you provide to PolicyPal will be disclosed to third parties where:

  1. you have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure;
  2. necessary to provide you with the products and/or services you have requested for, or to respond to your queries;
  3. necessary for the operation of the Website or PolicyPal's internal processes;
  4. required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
  5. PolicyPal believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, PolicyPal's interests, or any PolicyPal employee;
  6. PolicyPal is the subject of a takeover and your personal information forms part of PolicyPal's assets to be transferred to the acquiring entity; or
  7. you disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Website.

5. SECURITY

PolicyPal has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information. Nevertheless, you acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to PolicyPal is done so at your own risk. PolicyPal does not warrant or guarantee that the information you provide will not be accessed, copied, used, or disposed of in breach of PolicyPal's security measures, and you agree not to hold PolicyPal liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, PolicyPal will, as far as reasonably possible, promptly notify all affected persons. You accept that you are responsible for keeping confidential your username and password to your account with PolicyPal.

6. WEB-RELATED INFORMATION

6.1 PolicyPal may collect certain information from you without you actively providing the information when you navigate the Website via cookies. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Website. These cookies will not give PolicyPal any personal information about you. PolicyPal reserves the right to use the cookies to recognize your browser and thereby customise and optimize the Website to your preferences.

6.2 You can accept or delete cookies. For security reasons, you may wish to deactivate the storing of cookies or adjust your browser to inform you before the cookies are stored on your computer. However, please note that if you do erase or block the cookies, you may not be able to utilize some features on the Website. In such situations, PolicyPal shall not be held liable for any loss or damage resulting from your inability to use those features.

6.3 PolicyPal may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). PolicyPal collects your IP address in order to facilitate its administration and improvement of the Site. The information derived from your IP address can help PolicyPal diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Website.

6.4 We use the following cookies:

  1. Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.
  2. Analytical/performance cookies. They allow PolicyPal to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps PolicyPal to improve the way the Website works, for example, by ensuring that users are able to use custom features.
  3. Functionality cookies. These are used to recognise you when you return to the Website. This enables PolicyPal to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  4. Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. PolicyPal will use this information to make the Website and the advertisements targeted more relevant to your interests. PolicyPal may also share this information with third parties for this purpose.

7. NOTIFICATIONS & COMMUNICATIONS

7.1 PolicyPal may send you email notifications from time to time. You may not opt out of receiving certain service-related notifications that are:

  1. necessary elements of your transactions on the Website and any product or service of PolicyPal's, such as confirmations of particular actions you have taken;
  2. are required for legal or security purposes; or
  3. meant to inform you of changes to Website policies or PolicyPal's operations, products, or services.

7.2 You may, through written notice to PolicyPal, opt out of other service-related notifications at any time, including:

  1. information updates issued by PolicyPal;
  2. user surveys or other requests for user feedback; or
  3. marketing offers from PolicyPal or that PolicyPal sends on behalf of the companies featured on the Website.

8. TRANSFER, STORAGE, & RETENTION OF INFORMATION

8.1 Information collected in accordance with this Privacy Policy may be transferred, stored, or processed outside of Singapore. PolicyPal will comply with its obligations under the PDPA and Personal Data Protection Regulations 2014 in relation to personal data transferred, stored, or processed outside Singapore for as long as the data remains in PolicyPal's possession or control during the transfer. PolicyPal will take appropriate steps to ascertain whether, and to ensure that, the recipient of the personal data who is located outside Singapore is legally obliged to provide to the personal data a comparable a standard of protection. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore in order to provide you with the services you request, you are deemed to consent to such transfer, storage, or processing in providing your personal data to PolicyPal during your use of the Website. You may at any time inform PolicyPal that you wish to withdraw your consent to such transfer, storage, or processing of your personal data.

8.2 PolicyPal will retain all information collected for as long as you continue to use the Website or PolicyPal's services. If you are a member and terminate your PolicyPal account, PolicyPal will retain the information, including personal data, collected during your membership for as long as reasonably necessary for any business or legal purpose.

9. COMMUNICATIONS

PolicyPal may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and PolicyPal. PolicyPal may do so in order to resolve queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.

10. YOUR RIGHTS

10.1 You have the right to ask PolicyPal not to process your personal data for marketing purposes. PolicyPal will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing through written notice to PolicyPal at hello@policypal.com. The Website may, from time to time, contain links to and from the websites of its partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that PolicyPal does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10.2 You may choose to stop receiving or change the frequency of email, direct mail, phone and mobile marketing communications. You can update and correct your personal information anytime using by sending PolicyPal a message via Contact Us within the Website, or by contacting PolicyPal at hello@policypal.com.

Last updated: 29 August 2017