PRIVACY POLICY

Your privacy is important to us. This Privacy Policy (”Privacy Policy”) sets out the basis which ETHOZ GROUP LTD (“ETHOZ”, “we”, “us”, or “our”) manages the personal data of our customers collected on our website (the “Site”) in accordance with the Personal Data Protection Act 2012 (“the Act”).

This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, to help you to make an informed decision before providing us with your personal data.

1. Consent

1.1 By accessing and using any part of our Site, you shall be deemed to have accepted to be legally bound by the terms of this Privacy Policy without limitation or qualification. If you do not agree to the terms of this Privacy Policy, you should immediately cease the use of our Site.

2. DATA WE COLLECT

2.1 Non-personal Data

2.1.1 We collect certain non-personal data when you visit and use our Site. Such data is entirely anonymous and is aggregated for statistical analysis (“Aggregate Information”). The information we obtain in this manner enables us to customise and personalise the services we offer, as well as measure the overall effectiveness of our online content, advertising campaigns, and the goods and services we offer.

2.1.2 When you access our Site, we store Aggregate Information about your visit in a small text file called a “Cookie” on your hard disk by a web server. Cookies collect information about the pages you view, the links you click and other actions that you take on our websites. Most browsers automatically accept Cookies. You can, however, modify your browser settings to disable Cookies. If you choose to do so, some of the functionality of our Site may be impaired.

2.1.3 We may also use electronic images known as Web Beacons to deliver or communicate with Cookies, in order to better understand how you interact with the content on our Site. We also may include Web Beacons from third parties, in e-mail messages to determine whether messages have been opened and acted upon.

2.1.4 We may also use website analytic tools on our websites to retrieve information from your browser, including the site you came from, the search engine(s) and the keywords you may have used to find our Site, the pages you viewed within our Site, your browser add-ons and your browser’s dimensions.

2.1.5 We may also use independent companies to measure and analyse the Internet usage across our Site. For instance, we may use services from other service providers that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area.

2.2 Personal Data

2.2.1 “Customer” refers to an individual who has contacted us through any means to find out more about any goods or services we provide, or may, or has, entered into a contract with us for the supply of any goods or services by us.

2.2.2 “Personal data” means data, whether true or not, about a customer who can be identified from the data; or from that data and other information to which we have or are likely to have access.

2.2.3 Depending on the nature of your interaction with us, some personal data which we may collect from you include identification information such as:

(a)    Name

(b)   NRIC number

(c)    Passport or other identification number

(d)   Mailing address

(e)   Email address

(f)     Photographs

(g)    Employment history

3. COLLECTION OF PERSONAL DATA

3.1 We generally do not collect your personal data unless it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us, or collection and use of personal data without consent is permitted or required by the Act or the laws.

(a)    when you submit an online queries application or registration form, or other forms relating to any of our products and services;

(b)   when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

(c)    when you interact with our employees, eg. via online enquiry, social media platforms and emails;

(d)   when you use our electronic services, or interact with us via any of our websites or use services on our Site;

(e)   when you request that we contact you or request that you be included in an email or other mailing list;

(f)     when you respond to our promotions, initiatives or to any request for additional Personal Data;

(g)    when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment;

(h)   when you are contacted by, and respond to, our marketing representatives and officers;

(i)      when we receive references from business partners and third parties, for example, where you have been referred by them;

(j)     when you fill up surveys administered by us or our third party surveying service providers;

(k)    when we seek information from third parties about you in connection with the products and services you have applied for; and/or

(l)      purposes which are reasonably related to the aforesaid.

4. PURPOSE OF COLLECTION OF PERSONAL DATA

4.1 We may collect and use your personal data for any or all of the following purposes:

(a)    performing obligations in the course of connection with our provision of the goods and / or services requested by you;

(b)   verification of identity;

(c)    responding to, handling, and processing queries, request, applications, complaints, and feedback from you;

(d)   execution and documentation on motor insurance claims and other services;

(e)   processing payment and credit transactions;

(f)     fraud management, crime prevention and / or investigation; complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and / or regulatory authority;

(g)    sending marketing information about our goods or services including notification of our marketing events, initiatives and promotions, membership and rewards schemes and other promotions;

(h)   notification and / or update on business entities and relevant information;

(i)      any other purposes for which you have provided the information; and

(j)     any other incidental business purposes related to or in connection with the above.

4.2 We may disclose your personal data:

(a)    where such disclosure is required for performing obligations in the course of, or in connection with our provision of goods or services requested by you; or

(b)   to third party service provides, agents and other organisations we have engaged to perform any of the functions listed in clause 4.1 above for us; or required by the Act or the laws.

5. DATA SECURITY

5.1 The security of your personal information is important to us. ETHOZ protects Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection and disclosure. Our site implements an SSL (secure socket layer) that protects your information.

5.2 While we strive to protect your Personal Data, no data transmission over the Internet can be guaranteed to be completely secure. We cannot guarantee the security of any information you transmit to us, and you transmit such information at your own risk. We do not accept liability for the security, authenticity, integrity or confidentiality of any transaction and other communications made through the Site. We are not liable for any damages resulting from any security breaches, unauthorised and/or fraudulent use of your personal data.

6. RETENTION OF PERSONAL DATA

6.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

6.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

7. CONTACTING US

7.1 If you have any questions or feedback regarding this Privacy Policy, you may submit your request via email to our Data Protection Officer at DataProtectionOfficer@ethozgroup.com.

7.2 Please indicate in the subject header the nature of your correspondence. We will strive to revert to you speedily.

8. WITHDRAWAL OF CONSENT

If you withdraw of consent to any or all use of your Personal Data, depending on the nature of your request, ETHOZ may be unable to administer any contractual relationship in place. ETHOZ reserves the legal rights to terminate any agreements with you, under the reason of you being in breach of your contractual obligations or undertakings.

9. UPDATES TO THIS POLICY

9.1 This policy will be reviewed from time to time to take into account future developments, industry trends and / or any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. This policy was last updated on 8 October 2019.

9.2 We reserve the right to amend the terms of Data Protection Policy at our absolute discretion.

10. GOVERNING LAW

This Privacy Policy shall be governed in all respects by the laws of Singapore.