|ABOUT THIS DOCUMENT|
|We at AXIS Specialty Limited (Singapore Branch) ("AXIS") take our responsibilities under Singapore's Personal Data Protection Act 2012 and the Personal Data Protection (Amendment) Act 2020 (the "Applicable Data Protection Law")
seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. |
This Privacy Notice is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries regarding this Privacy Notice or any other queries in relation to how we may manage, protect, and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the " DPO") at [email protected].
|INTRODUCTION TO PERSONAL DATA|
|"Personal Data" is defined under the Applicable Data Protection Law to mean 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 organisation
has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images. |
We will collect your personal data in accordance with the Applicable Data Protection Law. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
|PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA|
|The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may need to process your personal data, including, but not limited to:
(collectively, the "Purposes").
As the purposes for which we may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the Applicable Data Protection Law or by law.
In order to conduct our business operations more smoothly, we may also disclose the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third Party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
|SPECIFIC ISSUES FOR THE DOSCLOSURE OF PERSONAL DATA TO THIRD PARTIES/strong>|
|We respect the confidentiality of the personal data you have provided to us. |
In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
The instances listed are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the First and Second Schedules of the Applicable Data Protection Law which are publicly available at http://sso.agc.gov.sg.
Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
|REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA|
|You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of
your request, so as to be able to deal with your request. Please submit your written request to the DPO. |
For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the Applicable Data Protection Law exempts certain types of personal data from being subject to access requests.
For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
We may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
We may also charge you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of such fee. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
|REQUEST TO WITHDRAW CONSENT|
|You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the DPO. |
We will process your request within a reasonable time from such a request being received, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue your existing relationship with us.
|ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA|
|We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that
you must also update us of any changes in your personal data that you had initially provided to us. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your
personal data that you had initially provided to us. |
We have in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
Where your personal data us to be transferred out of Singapore, we will comply with the Applicable Data Protection Law in doing so. In this regard, this includes us obtaining your consent unless an exception under Applicable Data Protection Law applies, and ensuring the foreign recipient organisation of the personal data agrees to safeguard personal data with appropriate security measures equivalent to the standard of protection under the Singapore law. This may include us entering into an appropriate contract with the foreign recipient organisation.
|If you have any complaint or grievance regarding how we are handling your personal data or about how we comply with the Applicable Data Protection Law, please contact us with your complaint at [email protected].
When submitting a complaint via letter or email, please indicate at the subject header that it is an Applicable Data Protection Law complaint to assist us in attending to your complaint speedily. For example, you could insert the subject header as "Applicable Data Protection Law Complaint".
|UPDATES ON PRIVACY NOTICE|
|As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.|
We reserve the right to ament the terms of this Privacy Notice at any time at our absolute discretion.
You may contact us at any time to ensure that you are well informed of our latest policies in relation to personal data protection.
|HOW TO CONTACT US|
|Please address all inquiries, requests, and other communications regarding your personal data or this Privacy Notice to: |
Contact: Data Protection Officer
Email: [email protected]
Address: 52 Lime Street, London EC3M 7AF
Effective Date: 1 January 2023, v1.0