Privacy and cookies
Singapore Personal Data Protection Act 2012 ('the PDPA')
Collection, purpose and use of personal data
Personal data is collected and held by Friends Provident International Limited.
- Personal data is collected in the policy application forms you have completed, or in any document provided by you to Friends Provident International Limited which forms part of the application form, or has been otherwise authorised by you to be provided to Friends Provident International Limited – please see also Administration and servicing below.
- Information is collected automatically when you visit the Friends Provident International website because your Internet Protocol address needs to be recognised by the server.
- We will only use your personal data for Direct Marketing purposes where we have your consent to do so. If you consent, Friends Provident International Limited may contact you to inform you about products or services, special offers or other information from Friends Provident International Limited or other Aviva companies which may be of interest to you. Please contact us if you decide to change your preference to receive or not receive the above marketing materials.
Administration and servicing
In order to carry out our business, process, administer and/or manage your relationship, policy and/or account with Friends Provident International Limited, we will have to collect, use and disclose your personal data.
Such personal data will be collected, used, disclosed and/or processed by Friends Provident International or other Aviva companies for the purpose(s) of:
- providing financial advice to recommend product(s) based on your financial needs analysis, where applicable;
- administration of your policy, which may include but is not limited to:
- underwriting of the risk proposed;
- requesting and collecting premiums;
- providing regular information about your policy;
- making changes or updates to your policy;
- reviewing or renewing or reinstating your policy;
- carrying out your instructions or responding to any enquiries by you;
- assessing and processing your claim(s) made under the policy;
- administration of your account which may include but is not limited to:
- maintenance of your account;
- performing or updating transactions on your account;
- carrying out your instructions or responding to any enquiries by you;
- dealing in any matters relating to your policies and/or accounts (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages).
- managing your relationship with Aviva;
- compiling statistics or conducting research for company or industry exercises and studies, to design, review or improve our products and services;
- compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by Aviva and/or the industry;
- complying with applicable laws, regulations, rules, guidelines, schemes or directions imposed by any regulator, government body, statutory body, law enforcement agency or dispute resolution body;
- providing general information on product enhancements and services, which are relevant to your needs or policies(including increasing benefits, adding riders / supplements and/or insured lives);
- investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned – please see also Financial crime below;
- archiving, backing-up or destroying personal data.
Some of these purposes may apply or continue to apply after your relationship, policy or account with Friends Provident International Limited has ended or is no longer in force or active.
As the purposes for which we may/will 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 PDPA or by law.
Financial crime (fraud and money laundering)
To verify your identity and prevent financial crime we may use and share your information with any company within the Aviva group, with companies who work for us and with appropriate organisations.
We may also search, send your details to, and use information from third party verification service providers and financial crime and credit reference agencies (third parties). This involves checking your details against databases these third parties use. The Aviva group and these third parties may keep a record of the search, the results of the search, any suspicions of financial crime and the details may be used to assist other companies for verification and identification purposes. The search is not a credit check and your credit rating will be unaffected. These activities help to:
- prevent financial crime (for example, fraud, money laundering)
- verify the identity of policyholders/ex-policyholders
- trace and validate beneficiaries or recover debt
- make decisions about your policy
Appropriate organisations may include (but are not limited to) the Police, Financial Conduct Authority, Association of British Insurers. The third party verification providers, financial crime and credit reference agencies may include (but are not limited to) 192.com, Callcredit, Equifax and Experian.
The Anti Money Laundering Manager, Friends Provident International Limited, Royal Court, Castletown, Isle of Man, British Isles, IM9 1RA.
Security of personal data and consent to use personal data
By proceeding with access to any of our websites you consent to Friends Provident International Limited and the Aviva group of companies:
- collecting, using, disclosing and/or processing your personal data for the purposes described above; and
- transferring the personal data mentioned above to other Aviva group companies, its third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries, regardless of where such third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries are sited (whether in Singapore or outside of Singapore).
We will take all practicable steps to ensure that your personal data is protected against unauthorised access, processing, erasure, loss or use.
Where we use third parties to process personal data on our behalf we put in place contracts with privacy, security and contractual restrictions in addition to the obligations imposed on us by the PDPA.
The Aviva group has global information security policies in place to protect information and customer personal data. Examples of our information security policies and the areas they cover are listed below:
- Data Security
- Data Classification
- End User Computing
- Incident Management PCI-DSS Compliance
- Security Audits
- Third Party Access
- User Access
- User ID and Password
- Customer ID Verification
- Data Handling
- Data Retention
- Staff Monitoring
Our websites may contain both public (URLs start with HTTP) and protected pages (URLs start with HTTPS) and links to other Aviva websites.
Any information transmitted to Aviva group companies through public pages is not encrypted and could be intercepted by third parties or electronically delivered to parties other than the addressee. Any such information is sent at your own risk and you should therefore carefully consider its sensitivity prior to transmitting it.
Some pages of the website offer the facility to email us with an enquiry. Email is not a secure medium of communication. For this reason, we request that you do not send private information to us by email. Where we do receive personal information from you by email, we will only respond by email if it is through a secure route.
The protected pages of our websites are protected by access via a secure server. This ensures all information transmitted between your browser and our server is encrypted.
Our online services have protected pages and require you to have a valid user name and password. Data transmitted via the secure server is stored on databases, which are protected by further security measures (such as firewalls), and may only be accessed by authorized users. We have strict policies on the storing and disclosing of data to prevent unauthorized access.
The Internet is worldwide and if you are visiting our websites your visit will necessarily result in the transfer of information across international borders. By visiting our websites and communicating electronically with us you are consenting to these transfers.
We may also include links to third party websites for your convenience. By giving access to such sites, we are not making any statement, warranty or representation as to the quality or contents of the other sites and do not have responsibility for those sites. Please note that when accessing another website by way of a hypertext link you may leave the Aviva website.
What are cookies?
Cookies are small text files that some websites place on your computer or other device when you visit.
Session cookies are automatically deleted at the end of each browsing session (typically when the browser is closed).
Persistent cookies remain until the expiry date and time set by the website (or when manually deleted by the user).
- understand how people use our websites so we can improve them, and
- present the right information to people who have logged into our websites, for instance to manage their policies.
You can set your browser to reject cookies but if you do so you will be unable to use some areas of our website(s).
For information about how to block and delete cookies please visit AboutCookies.org.
Accessing and correcting your personal data
Friends Provident International Limited, Singapore Branch complies with its obligations under the PDPA. You have the right to access and to request correction of any personal information concerning you held by Friends Provident International Limited. In accordance with the PDPA, Friends Provident International Limited has the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to:
Richard Watterson, Data Protection Officer, Royal Court, Castletown, Isle of Man, British Isles IM9 1RA
Please contact us if you have any questions or concerns relating to this Privacy and cookies policy.