Personal Information Collection Statement (PICS)

Grandtag Financial Consultancy (Singapore) Pte. Ltd. (referred to hereinafter as the “Company”) recognizes its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Singapore Personal Data Protection Act 2012 (“PDPA”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take appropriate technical and organisational steps aimed at ensuring the security of the personal data and to avoid unauthorized or accidental access, loss or damage, erasure, or other unauthorised or unlawful use.

In order to provide you with our insurance brokerage services and other services set out in the “Purpose” section below, we may collect personal data directly from you or from other third parties. Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.

(A) CATEGORIES OF PERSONAL DATA

We will collect and process the following categories of personal data:

1. personal identification details, including name, date of birth, nationality and etc.
2. copies of identification documents, such as passports, national identification cards and/or visa documents.
3. contact details such as email address, telephone number, residential address and etc.
4. copies of documents required to verify information, such as utility bill required to verify your address.
5. images, photographs, video recordings and electronic communications.
6. financial identifiers and other information such as tax identification number, bank account statements, investment portfolio statements, bank account details or other payment details.
7. details collected from your use of our information technology systems, including our website, such as your IP address and data collected from cookies on our website.
8. identification and contact details of beneficiaries or dependents and etc.

(B) SPECIAL CATEGORIES OF PERSONAL DATA

We do not normally ask you to specially provide us with “Special Categories” of personal data but in some cases, special categories of personal data may be contained on other documentation you provide to us for purposes of identity verification, such as passport or identify card copies. “Special Categories” or personal data are personal data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliation or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including generic data and biometric data where it is used for the purpose of uniquely identifying a natural person.

Basis for processing Special Categories of Personal Data to the extent we do process such data it will be on the following lawful bases:

• where we have your explicit consent for specified purposes;
• if necessary for us to comply with the law applicable to us;
• on grounds of substantial public interest; and
• if necessary and proportionate to protect you from potential bias or inaccuracy in decision making.

We are also permitted to process your special categories of personal data if necessary for the establishment, exercise or defence or legal claims by us.

(C) PURPOSE

From time to time, it is necessary for the Company to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by us for purposes (“Purposes”), including:

1. providing insurance brokerage services to you, including assessing and evaluating your needs on insurance, wealth management, estate planning, business planning or other financial matters;
2. advising or acting for you on matters relating to insurance, wealth management, estate planning, business or financial planning, or arranging insurance contracts on your behalf;
3. offering, providing and marketing to you the insurance products/ services of local or offshore insurance companies or other insurance service providers (see “Use and Provision of Personal Data in Direct Marketing” below);
4. preparing for you any applications for insurance products/ services. This will entail providing your personal data to insurance companies for the purpose of obtaining life cover;
5. providing subsequent services to you, including but not limited to conducting face-to-face meetings or phone discussions for the purposes of reviewing and administering any products/services you have purchased; any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/ services you have purchased, including investigation of claims;
6. any other reasonable purposes in connection with the provision of our brokerage services;
7. designing products/services for clients;
8. conducting market research for statistical or other purposes;
9. matching any data held which relates to you from time to time for any of the purposes listed herein;
10. making disclosures as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government, regulatory or tax authorities in Singapore or elsewhere;
11. conducting identity checks;
12. carrying out other services in connection with the operation of the Company’s business; and
13. other incidental purposes directly relating to any of the above, provided such processing is fair and transparent.

(D) TRANSFER OF PERSONAL DATA

Personal data will be kept confidential and subject to the provisions of any applicable law. Your personal data may be provided to the following recipients for the Purposes listed above:

1. any of our affiliates, any person associated with the Company, insurance or any reinsurance company, claims investigation company, industry association or federation, or financial institution in Singapore or elsewhere and in this regard, you consent to the transfer of your data outside of Singapore;
2. any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to the Company and/ or our affiliates in Singapore or elsewhere and who has a duty of confidentiality to the same;
3. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
4. any government department or other appropriate governmental or regulatory authority in Singapore or elsewhere, in accordance with an official request or legal requirement.

For our policy on using your personal data for marketing purposes, please see the section below “Use and Provision of Personal Data in Direct Marketing”.

Transfer of your personal data will only be made for one or more of the Purposes specified above.

The transfer mentioned above may involve the transfer of your personal data to jurisdictions outside Singapore for processing. Overseas jurisdiction may not have laws which require the same protection of personal data as Singapore. We will ensure that any such transfer only take place under adequate safeguards, as required by the law, or otherwise in accordance with the law.

(E) RETENTION OF PERSONAL DATA

The Company only store and process your personal data for the time necessary to achieve the purposes for which personal data is collected, in accordance with applicable data protection laws.

(F) USE AND PROVISION OF PERSONAL DATA IN DIRECT MARKETING

The Company and/ or its affiliates intends to:

1. use your name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data held by the Company from time to time for the purpose of providing products and services and additional insurance advisory activities;
2. provide your personal data to insurance companies and/ or reinsurers for the purpose of obtaining life cover;
3. provide information regarding your insurance policy and/ or application to a financial institution for the purpose of obtaining financing;
4. provide your personal data to insurance companies and/ or reinsurers for the purpose of obtaining additional life cover as well as health, wellness, annuity and other insurance products;
5. provide information regarding your insurance policy to the policy’s owner which may be you or an affiliated entity as instructed by you;
6. use your data to provide “after-sales” services including face-to-face meetings and phone discussions for the purpose of advising, reviewing and administering your policy(ies).

You may in the future withdraw your consent to the use and provision of your personal data for providing the insurance advisory activities.

If you do not wish to receive direct marketing from us, you can opt out at any time. To opt out, please inform us in writing to the address in the section on “Access and Correction of Personal Data”. The Company shall, without charge to you, ensure that you are not included in future insurance advisory activities.

(G) ACCESS AND CORRECTION OF PERSONAL DATA

Under the PDPA, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request the Company to inform you of the type of personal data held by it, and how such personal data has been used or disclosed within the last year.

Requests for access and correction or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:

Data Privacy Officer
Grandtag Financial Consultancy (Singapore) Pte. Ltd.
3 Anson Road, #17-03 Springleaf Tower, Singapore 079909

A reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests.