Income Insurance Limited (Reg. No. 202135698W) and its subsidiaries (“Income”) recognizes its responsibilities in relation to the protection of the personal data collected, used, disclosed, processed, transferred or retained under the Personal Data Protection Act (“PDPA”).

Personal data will be collected only for lawful and relevant purposes and protected from any unauthorized access, use and disclosure. Income takes reasonable steps to ensure that personal data held by it is accurate.

Income may from time to time update this Privacy Policy to ensure it is consistent with our business requirements, industry trends and/or changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on Income’s website.

Any updates to the Privacy Policy will be effective 30 days following the date on which this Privacy Policy is updated and posted on our website.

Our Commitment in Data Privacy

Income places the privacy interests of its customers and individuals whose data has been collected by it high in its priorities. Income is committed to protecting the privacy, confidentiality, accuracy and security of the personal data provided to it. As part of Income’s Honest Insurance, this Privacy Policy tells you how Income and where appropriate, its employees, representatives, agents and third parties (as listed under Section 8 of our Privacy Policy) (collectively “we”, “us” or “our”) may collect, use, disclose, process, transfer and/or retain your personal data. We are required to comply with Income Privacy Policy when we carry out our daily activities for or on behalf of Income.

1. Personal Data

 

Personal data is defined as information about an individual who can be identified from that data; or from that data and other information to which the organization has or is likely to have access.

If you are a child or minor below the age of 16 years, please inform and seek the consent of your parent or guardian, before you provide your personal data to us. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us to remove, destroy or delete their personal data.

Personal data we collect may include: 

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Name, address, email address, telephone number, age, date of birth, gender, marital status, employment status information, nationality, residency and/or citizenship status

Family member, beneficiary, joint policy holder, insured person, beneficial owner, payor

Health status, medical examination results, medical report, injury or disability information, medical procedures performed, personal habits (e.g. smoking or alcohol consumption) and medical history

Income (e.g. salary, other income), assets (e.g. savings, properties), liabilities, spending (e.g. expenditures), credit card information (e.g. card number, credit payment information), tax information, bank account information (e.g. account number, statement and account details)

NRIC, Passport, FIN No., birth certificate, driving license, work permit, employment pass, vehicle registration number

  • Records of voice and contact information when you use our customer enquiry services or speak to us via phone call
  • Records of your mobile phone location data , IP address and MAC address when you use our online or mobile app services
  • Analysis of data relating to marketing of our products and services to you
  • Usage of our products and services
  • Previous insurance and claims experience
  • Employment information
  • Driving record
  • Travel arrangements
  • Lifestyle or social circumstances
  • Biometric identifiers/data
  • Information we obtained relating to insurance risk, pricing, claims history, medical information, instances of suspect fraud and usage history
  • Information we obtained or purchased which may be demographic information, credit information, marketing lists, publicly available information that could help us to help improve the relevance of our products and services
  • Information about you and our customers gained from analyzing or profiling of other information collected
  • Third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction

2. When and how we collect personal data

 

We collect personal data relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, including when:

  • you use our services or enter into transactions with us (or express interest in doing so).
  • you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us.
  • you apply for any insurance policy offered by Income and/or distributed by us, to be a member of any of our loyalty programs, respond to our promotions, or subscribe to our mailing lists.
  • you use the services of any broker or other intermediary (for example, agents, distributors, business partners) who Income work with to provide products, services or quotes to you.
  • you take up an insurance policy for your or any other party’s benefit or named yourself or any other party as the insured.
  • you download or use Income’s mobile applications.
  • you register an account with Income through Income’s websites or applications.
  • you interact with our employees, representatives, agents or appointed service providers (for example, via telephone calls, letters, face-to-face meetings, digital platforms (including social media platforms), surveys, workshops and/or e-mails).
  • your images / biometric identifiers are captured via CCTV or biometric capture devices when you are within our premises or use our services.
  • your images are captured in photographs or videos taken by us when you attend events organized by us.
  • you participate in events and programs, competitions, roadshows, contests, lucky draws, survey or games organized by Income and/or its partners, representatives and/or agents.
  • you download any cookies, location services, IP addresses when you visit Income website or mobile application.
  • we seek information about you and receive your personal data in connection with your relationship  with Income, for example, if you are seeking an employment with Income or you are Income shareholder.
  • the personal data is publicly available where relevant and appropriate.
  • we receive referrals from your authorized representative.
  • we seek any personal data that is required by any legal or regulatory authorities to comply with the laws and regulations, facilitate enforcement of laws, assist in any investigations or audits.
  • we seek information on you from your authorized representative for purposes of your policy applications, underwriting the risks of your policy, processing of claims and offering Income products or services to you.

3. How we use personal data

 

We may collect, use, retain and/or disclose/transfer your personal data to:

  • verify your identity and information  
  • carry out membership or information checks
  • communicate effectively with you on the products or services that we offer
  • provide you with financial need analysis, financial advice and communicate to you on products or services recommendation that maybe suitable for you
  • provide you with periodic review on your insurance/investment portfolio
  • reach out to you on customer relationship management
  • inform you on important corporate updates, announcements, or changes to our Privacy Policy
  • send you and manage your subscription to our newsletters
  • underwrite and price your application and any policy changes or renewals
  • reinsure risks and for reinsurance administration
  • manage administrative and business operations and comply with internal policies and procedures
  • determine and verify your creditworthiness for the financial and insurance products you apply for
  • provide you with ongoing services and respond to your inquiries or instructions
  • process payments to you
  • process your payments to us
  • investigate, assess and process your claims under the policy including by requesting from hospitals and clinics information such as your medical reports and test results
  • recover any debt owed to us
  • monitor, detect and prevent fraud, unlawful, undesirable sales practices or improper activities
  • perform automated decision-making or profiling
  • conduct surveys, study, research, statistical/data analysis, data matching to improve the products and services we offer to you
  • conduct checks, surveillance and investigation or due diligence required for audit purposes
  • carry out due diligence activities to comply with all applicable laws and regulations,  including reporting to regulatory authorities and industry association
  • evaluate, process, facilitate or administer your request for referral services
  • inform you of our philanthropic and charity initiatives (i.e. OrangeAid), including soliciting donations, acknowledging donations and facilitating tax exemption
  • storing, hosting, backing up of the personal data (including via cloud services)
  • monitor and coach employees and agents for quality assurance
  • resolve complaints, and handle requests and queries  
  • manage and prepare reports on incidents and accidents
  • administer contests, lucky draws and events
  • provide insurance or financial related marketing products or services, promote complementary products or services to you from Income business partners with whom Income have formed an association or Income’s affiliates, if you have consented
  • fulfill any purposes relating to the applications and/or registrations you have submitted for any Income products and/or services
  • carry out any other such purpose which may be incidental or ancillary to any of the above purposes

We will only collect and use personal data in an open, fair and lawful way that is necessary for the purposes identified by us above. We will use the NRIC / National identification for verification of your identity for policy application, customer/policy servicing, claims processing, and/or regulatory reporting.

In some circumstances we may anonymize your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymized data without restriction, including for data analytics.

These purposes may also apply even if you do not maintain any policy or relationship with us, or have terminated the policy or relationship with us.

4. Obtaining your consent

 

We will only collect, use, disclose, process, transfer and retain personal data for the above purposes with your consent or as allowed or required by law. We will notify you on the purposes for which we will collect, use and disclose your personal data before or at the time we collect it.

You can give your consent expressly or impliedly. Your expressed consent can be given to us in writing, verbally (e.g. through our call centre) or electronically (e.g. through our website). Your implied consent can be given to us from your action or nature of dealings. For example, when your healthcare provider provide your personal data to us to enable us to process the payment for your healthcare claim.


Any party authorized by you (including a person having a power of attorney to act on your behalf) may:

  • allow us to collect, use, disclose, transfer and retain personal data for the above purposes; and
  • access your personal data or policy information.

5. Acting on someone else’s behalf

 

If you provide us with personal data of another person, you represent and warrant to us that you have been appointed and authorized by the other person to act on his behalf. This includes providing consent to our collection, use, disclosure, transfer and retention of his personal information and sensitive personal information.

6. Using information for marketing and additional purposes

 

Income, its representatives, agents, relevant third parties and Income’s appointed insurance intermediaries may also collect, use, retain and disclose your personal data (including any future updates and existing personal data) except medical information, that you have/had given to Income and its representatives/ agents to:

  • send you marketing, advertising and promotional information on products and/or services marketed and/or distributed by us via Postal Mail, Email, Voice Call and/or SMS/Text.
  • send you information by post and/or email on your rewards program and special offers (where relevant) in relation to products and/or services offered by Income and Income’s business partners.
  • provide marketing services, products and benefits to you, including promotions, loyalty and reward programmes via various platforms or outreach initiatives.
  • match personal data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by Income or other third parties.
  • send you details of products, services, special offers and rewards, that are either provided to our customers generally, or which we have identified may be of interest to you.
  • conduct market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
  • contact you via Voice Call, SMS/Text, Email or Postal Mail of purposes in relation to particular products or services that you have indicated your interest or in your interactions with us.

 

If you have provided your Singapore telephone number(s) to us and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Income and its representatives, agents, appointed insurance intermediaries and service providers may contact you using such Singapore telephone number(s) (voice calls and text) to market and promote the products and services (including discounts and special offers) of Income and its business partners.

Please refer to Sections 9. Withdrawing your consent and Section 15. Contacting Us below for details on how you can contact us should you decide to withdraw your consent.

7. Other relationships

 

Job Candidate

If you are applying to Income to fill any job vacancy as an Income staff or a representative of Income, we will collect, use and disclose your personal data for the purposes of administering, processing and managing your application, which include the following:

  • Conducting pre-recruitment due diligence checks such as verifying your credit standing, qualifications and obtaining reference check from your ex-employers;
  • Conduct background screening/ verifications;
  • Facilitating and conducting interviews;
  • Assessing your job suitability;
  • Any other purposes relating to the aforesaid.

You should ensure completeness and factual accuracy of your personal data provided to us.

8. Whom we may collect from and/or disclose personal data to

 

We will only collect, use, retain and/or disclose/transfer your personal data as it is reasonably required for the purposes stated above and the data is limited to information necessary for us and these third parties (as listed below), whether they are located in Singapore or overseas, to do the work.

We may transfer personal data to service providers outside of Singapore for processing, storage, analysis, disaster recovery or emergency assistance services and this data may be required to be disclosed to those authorized under the applicable laws of that foreign country. These service providers with whom we have contractual relationships are required to provide a standard of protection to the transferred personal data that is comparable to the protection under the PDPA and consistent with our personal data protection policies and practices.

The third parties/service providers, whether they are located in Singapore or overseas, whom personal data may be disclosed to are listed below:

  • your financial advisers, agent, insurance broker 
  • your employer or group policyholder
  • the party that referred you to us or introducer
  • your family, relatives, appointed executors and their professional advisers in connection with your will(s) or the administration of your estate
  • medical professionals and institutions
  • insurers and reinsurers
  • industry associations, including the Life Insurance Association Singapore and the General Insurance Association Singapore
  • local and/or overseas service providers to provide us with services such as courier service, survey, printing, mail distribution, data storage, cloud services, data entry, marketing and research, disaster recovery or emergency assistance services
  • debt collection agencies
  • dispute resolution parties
  • parties that assist us to investigate, administer and adjudicate your claim
  • financial institutions
  • credit reference agencies
  • regulators, law enforcement, the relevant government regulators (such as the Monetary Authority of Singapore, the Ministry of Manpower, the Ministry of Health and the Central Provident Fund Board)
  • the Government and participating statutory boards, organisations approved by the Government (including government agencies and their respective third party service providers, suppliers, agents, reinsurers, fund managers and intermediaries) and insurers to administer schemes offered under any governmental authority such as the Monetary Authority of Singapore, the Ministry of Manpower, the Ministry of Health and the Central Provident Fund Board and to comply any regulations, laws or rules
  • our business partners and affiliates
  • any other relevant third party or representative authorized by you

9. Withdrawing your consent

 

You may refuse or withdraw your consent for us to collect, use or disclose your personal data by giving us reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so.

If you withdraw your consent for us to use your personal data (except for marketing purposes as set out under Section 6 of our Privacy Policy), we will not be able to provide you with the products and/or services that you asked for or have with us, including preventing us from keeping your insurance cover in force or properly assessing and processing your claim. Withdrawing such consent will require you to surrender or terminate all your policies or be removed from the event with us. These shall include the following:

  • If you are a policyholder, withdrawal of your consent will prevent us from keeping your insurance cover in force or properly assessing and processing your claim. Withdrawing such consent will require you to surrender or terminate all your policies or be removed from any of our events.
  • If you are using our referral services, withdrawal of your consent will affect our ability to provide you with the referral service that you asked for and may result in the cancellation of the referral service.
  • If you have subscribed to our newsletters, your subscription will be terminated and you will not receive any newsletter from us after the withdrawal of such consent.

 

If you have notified Income that you are withdrawing your marketing consent, your request will be affected within 10 days and you will stop receiving marketing messages after 21 days for the selected mode(s) of communication. You will continue to receive marketing messages via other modes of communication or on specific product(s) or services where your consent has been given to Income unless such consent has been withdrawn and notified to Income.

Please refer to Section 16. “Contacting Us” below for details on how you can contact us should you decide to withdraw your consent.

10. Accuracy

 

We will take all reasonable efforts to ensure that your personal data collected by us or on our behalf is accurate and complete.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. If there is a change to your contact information such as your home address, email address or telephone number, please promptly update us. This ensures that you will continue to receive communications from us without disruption or delay. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

11. Your rights of Access & Correction

 

Under the PDPA, you have the right to request access to any personal data of yours that we have, and know how it is being used and disclosed for the last 12 months to the extent your right is allowed by law. However, you may be charged a reasonable fee for every request for such access. You also have the right to request correction of your personal data.

12. Protecting your personal data

 

Income will protect your personal data from unauthorized access, collection, use, disclosure, copying, modification or disposal by having physical, technological and organizational safeguards in place that are appropriate to the sensitivity of the data.

All Income employees, representatives, agents and third parties (as listed under Section 8 of our Privacy Policy)who act on Income’s behalf must comply with Income privacy policies and practices and can only access your data  where it is necessary to perform their duties.

13. Retention

 

We will keep your personal data only for as long as it is needed for the purposes as stated above and for which it was collected and as required for business or legal purposes. Once your personal data is no longer required for these purposes, we will destroy, delete or make anonymous the data.

14. Use of cookies

 

Income may also receive and retain certain types of information whenever you interact with Income on its corporate website. Through the use of cookies, which are small text files placed on your computer by websites, Income is able to collect or track information such as your IP address, browser type, domain names, access times, referring website addresses and other information based on your online behavioral patterns, preferences and interests in the course of using and accessing the website and/or services. Depending on the type of cookie it is, cookies may store user preferences and other information but does not contain any information that can identify you personally.

Income use the information collected through the use of cookies for the following purposes:

  • Keeping count of return visits to its website or its advertisers’ or strategic partners’ websites, the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
  • Understanding how people use its websites and platforms, and improve its structure and contents;
  • Accumulating and reporting anonymous, aggregate, statistical information on websites and advertisement usage;
  • Evaluating the effectiveness of the advertisements and promotions;
  • Determining which features on its website that users like best and tailor its content and advertisements to match your interests;
  • Collating information on a user’s search and browsing history;
  • Saving your password so you do not have to re-enter each time you visit Income website.

The cookies used on Income website will not collect your personal information unless you specifically provide us with the information. You may opt to disable cookies or prevent your browser from accepting new cookies through your browser settings.

If you choose not to allow Income to place a cookie on your computer, this may restrict your ability to perform certain transactions, use certain services or access certain content on Income’s website.

 Third-parties may place advertisements on Income’s websites, and in some cases, in HTML-formatted newsletters. Often, these third parties employ cookies, web tag/pixel or other similar technologies to collect/store information to measure advertisement effectiveness and to provide you with a better, faster, and safer web experience. Income does not disclose any personal, identifiable information to these third parties through Income’s website. Use of any information by such third parties are subject to their own privacy and/or cookie policies. Please note that we do not endorse any cookie, web tag/ pixel placed or created by such third parties and we are not responsible for the access or use of your information by such third parties.

15. Online security

 

For more information on how to secure your transactions and personal information online, please refer to Income Security Policy, which is available at http://www.income.com.sg/security-policy 

16. Contacting us

 

(a)          For data protection concern or queries, please email Income Data Protection Office at:

 

(b)          For request for withdraw consent and access to your personal data and update or correct your personal data, you may

 

Please note that if your personal data has been provided to Income by another party (e.g. you are the life assured of an insurance policy not owned by you), you should contact the same party that provided your personal data to Income to make your access and correction requests to Income on your behalf.

(c) For quality control, training and compliance monitoring purposes, all our inbound and outbound calls are recorded.

 

Last Updated: Mar 2021

 

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