Privacy Policy

COLLECTION OF INFORMATION

1.1 For the purposes outlined in Clause 2., we may collect and process the following information about you:

• Information you give us - information that you provide us (which may include your name, address, email address, telephone number, credit card information and other personal description) by filling in forms on our Site or our App, or by corresponding with us (by phone, email or otherwise), for example:
  • when you register for an account with us on our Site and in our App;
  • when you report any problem to us;
  • when you use certain features on our Site or our App;
  • when you request any support from us; or
  • when you complete any survey or questionnaire we send you.
• Information we collect about you - information automatically collected when you visit our Site or use our App:
  • details of any transactions, purchases and payments you made on our Site and in our App; and
  • information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
• Information we receive from third parties - We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

1.2 We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.

USES MADE OF THE INFORMATION

2.1 We use information held about you for the following purposes:

• providing, improving and developing our services;
• researching, designing and launching new features or products;
• presenting content and information in our Site and our App in the most effective manner for you and for the device you use;
• providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
• complying with laws and regulations applicable to us in any part of the world;
• responding or taking part in legal proceedings, including seeking professional advice;
• for direct marketing purposes (please see further details in Clause 2.2 below);
• communicating with you and responding to your questions or requests; and
• purposes directly related or incidental to the above.

2.2 We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out at any time. For the purpose of this clause:

• the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.1 above;
• the type of services or products that may be offered or advertised will be our insurance carrier's complementary products, and those of our affiliates or business partners;
• the relevant information may be sent to you by email, in-app message or phone call;
• you may opt out at any time by emailing us at support@efgh.xyz. We will cease to send you marketing information without charge.

DISCLOSURE OF YOUR INFORMATION

We will keep your personal data we hold confidential but you agree we may provide information to:

• any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act 1967;
• personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);
• our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
• persons under a duty of confidentiality to us;
• persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
• actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.

COOKIES

4.1 Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.

4.3 We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

4.4 We use the following categories of cookies:

• Necessary cookies - Essential cookies required for the website to function properly. These include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services. These cookies cannot be disabled.
• Analytics cookies - Cookies that help us understand how visitors interact with our website, allowing us to improve user experience. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it.

4.5 If you are located in the European Economic Area (EEA) or the United Kingdom, we will present you with a cookie consent banner when you first visit our Site. Non-essential cookies (such as analytics cookies) will not be placed on your device until you have given your explicit consent, in accordance with the General Data Protection Regulation (GDPR). You may accept all cookies, reject non-essential cookies, or customise your preferences at any time through our cookie preferences dialog.

4.6 You can withdraw or change your cookie consent at any time by accessing the cookie preferences option in the footer of our Site. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.

4.7 We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytics cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These third-party analytics cookies are only activated after you have given your consent, where required by applicable law.

THIRD-PARTY SITES

Our Site, our App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites.

SECURITY

6.1 All information you provide to us is stored on our secure servers.

6.2 Any payment transactions will be encrypted using TLS/SSL technology.

6.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6.4 We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

6.5 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

6.6 Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

DATA TRANSFER

7.1 The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by persons referred to in Clause 3. above who operate outside Singapore.

7.2 We will ensure that all transfers of personal data outside Singapore comply with the requirements of the Singapore Personal Data Protection Act 2012 (PDPA). Specifically, we will take appropriate steps to ensure that the recipient organization is bound by legally enforceable obligations to provide a standard of protection to the transferred personal data that is comparable to the protection afforded under the PDPA.

7.3 Where your personal data is transferred out of the European Economic Area (EEA) or the United Kingdom, we will rely on recognized legal mechanisms for such transfers, such as:

• Transferring the data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK government; or
• Implementing appropriate safeguards, such as the use of Standard Contractual Clauses (SCCs) approved by the relevant authorities.

7.4 By submitting your personal data and continuing to use our Site and App, you consent to this transfer, storage, and processing of your data outside Singapore, subject to the safeguards outlined in Clauses 7.2 and 7.3.

YOUR RIGHTS

8.1 You have the right to:

• check whether we hold personal data about you;
• access any personal data we hold about you;
• require us to correct any inaccuracy or error in any personal data we hold about you; and
• withdraw your consent to the processing of your personal data at any time, where we rely on consent as the legal basis for processing.

8.2 If you are located in the EEA or the United Kingdom, you may also have the right under the GDPR to:

• request the erasure of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data for certain purposes; and
• request the portability of your personal data to another service provider.

8.3 We will process all requests to exercise your rights under Clauses 8.1 and 8.2 free of charge, except where:

• The request is for Access to personal data (under Clause 8.1). For such requests, we may charge a reasonable fee under the Singapore Personal Data Protection Act 2012, and we will provide you with a written estimate of the fee before proceeding.
• A request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request (in accordance with the GDPR and applicable laws).

CHANGES TO OUR PRIVACY POLICY

We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our App after the changes come into effect means that you agree to be bound by the revised policy.

CONTACT US

If you have any questions, comments or requests regarding personal data, please address them to: