Data Protection Policy

8 July 2015


Avallis is an independent financial advisory firm advising on financial products and services to individuals and businesses in the areas of investment, insurance, estate distribution, retirement, taxation, mortgage loans, corporate pensions, employee benefits, and business continuation and general insurance brokering.


We value your right to control your personal data and privacy. Your trust in how we handle your personal data is important to us. For that reason, we have implemented the data protection policy laid down in this statement.


The purpose of this Data Protection Policy is to let you know how we collect, use, disclose and protect your personal data. Our Policy meets the standards of the Personal Data Protection Act 2012 and will be reviewed regularly, along with our practices and procedures to take into account any change in the law or best practices. This Policy is current on the date above; you can find our latest policy on our webpage (www.avallis.com).  You can hold us to this Policy when you deal with us.


Under the PDPA, personal data—which is data that can be specifically linked to you as an individual (by itself, or in conjunction with other databases – both internal and public)—must be handled so as to meet certain standards in nine areas. These nine areas and our promises about them are set out below.

 

1. Consent

For the most part, your consent will be sought to collect, use and disclose personal data, subject to certain exceptions. Your consent may be expressed in writing (including electronic writing), orally, or through your authorised representatives. In certain circumstances, it may also be deemed or implied. We will not ask you to provide personal data as a pre-condition for providing a product or service if the purpose is beyond what is reasonable to provide that product or service.


The Personal Data Protection Act allows us to collect, use, disclose and transfer your personal data without your consent in the following situations:

  • Where collection is in your interest,  consent cannot be obtained in a timely manner, and you would not be reasonably expected to withhold consent;
  • Collection is necessary in an emergency that threatens your life, health or safety, or that of another person; or
  • The personal data is publicly available.

A fuller list of such situations may be found in the Second, Third and Fourth schedules of the PDPA.

You may withdraw your consent by giving us written notice and allowing us a reasonable period of time (seven business days). But do note that withdrawing consent may mean that we may not be able to provide those services that require the personal data withdrawn.


What personal data do we collect?


Offline
The personal data we collect vary according to the service we provide you. In all cases, we collect personal data from you only with your consent or as required or permitted by law. In general, we will collect personal data such as your name, gender, address, date of birth, telephone number(s), NRIC/ FIN/ passport number for identification and authentication purposes. When needed we may collect personal data such as your credit card numbers and expiry dates to facilitate payments.


Online
In general, we collect tracking data to enhance your surfing experience. When you visit our website, like virtually all other websites, a computer log of your visit is automatically created. The data in such a logfile that are analysed include your IP address, cookie information, webpages viewed, frequency of visits and time spent on the site. The analysis is to provide statistics regarding the use of the website and will be done in such a way that you will not be personally identified.


The terms and conditions for the use of the website are available at: www.avallis.com
If you send us email, we may retain such personal data so as to contact you and to send you more information.


Avallis sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on Avallis or the site; (b) protect and defend the rights or property of Avallis; or, (c) act under exigent circumstances to protect the personal safety of users of Avallis, or the public.

 

2. Purpose

Whenever we collect, use or disclose your personal data, we will tell you why we are doing so. Your personal data will be collected, used and disclosed for the purposes you consented to, or as permitted or required by law.


We collect, use and disclose personal data for these reasons:

  • Claims & disbursements
  • Comply with legal obligations and regulatory requirements
  • Conduct credit checks, screenings or due diligence checks as may be required under applicable laws/regulations
  • Conduct risk assessment
  • Offer you other insurance and financial services products that may suit your needs
  • Process and administer financial records
  • Process and administer insurance claims
  • Process applications and registration
  • Provide customer service and support
  • Provide financial and advisory services
  • Provide information to affiliates/associates about your transaction
  • Provide information to subsidiaries or partners that perform services for the company
  • Provide updates on changes / notifications
  • Respond to inquiries and provide customer services
  • Sales commissions
  • Servicing of policies and accounts
  • Update records in our database

 

3. Notification

We will inform you of the purposes for which we collect your personal data before or at the time that we collect the personal data from you. For personal data that we intend to use or disclose, we will inform you of the purposes before using or disclosing them.


Should you need clarification, do contact your representative who, if he or she is not able to answer your question immediately, will be able to find the person in the company who will be able to do so.

 

4. Access and Correction

You can ask us about the personal data we have about you or that is in our control. You may also ask us about personal data we have used or disclosed to others a year earlier. Your request should be written and you should give us a reasonable period to respond to you. Because responding to your request does require some time and effort on the part of our staff, we will charge a reasonable fee, which we will inform you before responding your request.


Subject to certain exceptions under the PDPA, you will given access to your personal data.  Such access is usually to verify the accuracy and completeness of information. You may request that your personal data be corrected, amended, or withdrawn as appropriate.

 

5. Accuracy

We will make all reasonable effort to ensure that your personal data will be as accurate, complete and as up-to-date as is practicable. To this end, we encourage you to access, review and correct regularly the personal data that you have given to us and to update these as promptly as you can so that we will always possess complete and accurate data on you.


We will correct and update the personal data you supply as soon as is practicable.

 

6. Protection

We will protect your personal data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification and disposal.

 

7. Retention

We will keep your personal data only for as long as is necessary to serve the purposes for which they were collected, or for as long as they are needed for our business and operational reasons.

 

8. Transfer

We may store or process your personal data with trusted organisations outside Singapore. Unless otherwise permitted by the Personal Data Protection Commission, when we do so, we will ensure that the organisation will be able to protect our personal data to a standard comparable to that under Singapore law. All such organisations will be prohibited from using your personal data except as instructed by us and they are required to maintain the confidentiality of your personal data.

 

9. Openness

Information about our data protection policies and practices will be made available to you upon request. This request is to be directed to our Data protection Officer whose contact information is at the end of this Policy.


To give feedback about our data protection policies or practices, please contact our Data Protection Officer at:


Name: Peggy Huang
Data Protection Officer
Avallis Financial Pte Ltd
#14-02 Clifford Centre
24 Raffles Place
Singapore 048621
Tel: 6220-5333
Fax: 6220-5377
Email: dpo@avallis.com

 

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