Your personal data is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This Policy sets out how A N A Management Services Pte. Ltd. , our related entities and affiliates, as well as any of our respective representatives and/or agents (collectively referred to herein as “A N A”, “us”, “we” or “our”) manage Personal Data in compliance with the Singapore Personal Data Protection Act in Singapore (“Act”). We encourage you to read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
Types of personal data do we collect
We may collect and hold personal data of persons/entities including but not limited to:
- job applicants and employees;
- service providers; and
- other people who we may come into contact.
Examples of such personal data include biodata, contact details, account information and your preferences, queries, requests and feedback.
How do we collect your personal data?
The ways in which we may collect your personal data include (but are not limited to) collecting directly or indirectly from you or your authorized representatives in the course of:
- you signing up for alerts or newsletters;
- you visiting our websites, etc;
- you applying for a job with us;
- you participating in our marketing or promotional events;
- you using our products or services;
- you contacting us with your queries, requests or feedback;
- our conducting market research or surveys;
- our conducting interviews.
Purposes of personal data collection
In general, we may use your personal data for the following purposes:
- conducting and completing your service request (e.g. processing orders and payments; providing products or services that have been requested);
- any purpose that is ancillary or related to our services (including due-diligence background checks, payment and debt-recovery matters, to enforce our legal rights and obligations, and to comply with legal and regulatory requirements).
- providing customer service (e.g. responding to queries and requests; informing you about service status and product updates; sending you alerts and newsletters);
- conducting market research and improving customer service (e.g. conducting market research or surveys; performing market analysis; managing and enhancing our products and services;
- developing new products);
- conducting marketing promotions (e.g. sending of alerts, newsletters, marketing materials and invitations from us wholly or through affiliation with third parties; offering promotions and loyalty programs);
- complying with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies; performing internal audits);
- performing evaluations (e.g. assessing suitability of employees)
In most cases, if you do not provide information about yourself which A N A has requested, A N A may not be able to provide you with the relevant product or conduct your service request.
We will only use, disclose and/or transfer your personal data for the purposes you have been notified of and consented to or which are permitted under applicable laws and regulations.
We will not sell, rent or give away personal data to third parties for commercial purposes without your consent.
Who do we share your personal data with?
Depending on the product or service concerned, personal data may be disclosed or transferred to:
- other divisions within A N A;
- our joint venture/ alliance partners;
- our service providers and specialist advisers/institutions who have been contracted to provide administrative, financial, legal, accounting, information technology, research or other services;
- other insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as agreed or authorized by law;
- credit reporting or reference agencies or insurance investigators;
- anyone authorized by an individual, as specified by that individual or the contract
Role as Data Intermediaries
Under the Personal Data Protection Act, A N A is a Data Intermediary providing you with relevant services and therefore will not be subjected to the main obligations except for the Protection and Retention of Personal Data. A N A will take reasonable measures to comply with the above obligations as required by the Act as a Data Intermediary. You are advised to ensure your own compliance with the Act.
Irrespective of our position as data intermediary, we wish to assure all our clients of our openness, as we are committed to explaining our policies and procedures and approach to data protection.
Management, protection and storage of your personal data
We have appointed a Data Protection Officer (“DPO”) to oversee our management of personal data in accordance with the Act.
We regard breaches of your privacy very seriously and we have implemented measures to secure and protect your information, such as training our employees who handle your personal data to respect the confidentiality of such personal data and your privacy, storing personal data in a combination of secure computer storage facilities and paper based files and other records, taking steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure.
However, it is not for us to perfectly secure your personal data from cyber attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.
The Act also requires us not to store personal data longer than necessary. We will cease to retain your personal data when we no longer require such personal data for the purposes we originally notified you of or for any business or legal needs.
Keeping your personal data accurate and up-to-date
We endeavour to ensure that the personal data we hold about you is accurate and up-to-date. We realize that such personal data changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible in order to update any personal data it holds about you.
Please email us at firstname.lastname@example.org with the subject “Change of Personal Information” stated. We may require you to verify your identity.
Access the personal data we hold of you
To make a request to access the personal data we hold about you, please contact the DPO in writing. You may email us at email@example.com with the subject “Access Personal Data” stated. We will require you to verify your identity and to specify what data you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the data sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
We gather information on our website activity, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregate, anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. We do not at our website automatically collect Personal Data unless you provide such information.
By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
Third-Party Links and Products on our Services
Exercise your right to withdraw your consent
To make a request to withdraw your consent previously given, you may email us at firstname.lastname@example.org with the subject “Withdraw consent” stated.
If you consider that any action of A N A breaches the Act or this Policy, you can make a complaint through email at email@example.com with the subject “Complain” stated. We endeavour to act promptly in response to a complaint.
Should you have any query, request or feedback relating to your Personal Data, please contact our DPO at firstname.lastname@example.org with the with the subject “Personal Data” stated.
Updates to this Policy
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. This Policy was last updated on 15 Feb 2016. If you are unsure whether you are reading the most current version, please contact us.