Privacy Policy

Privacy Policy

This Privacy Policy explains our practices, including the collection, use and disclosure of the information collected from you. In this Personal Data Protection Policy, personal data refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have, including data in our records as may be updated from time to time (“Personal Data”).

Personal Data that you may provide to us include (depending on the nature of your interaction with us), amongst others, your name, NRIC, passport or other identification number or information, telephone number(s), mailing address, email address, medical history, geographical location, medical information, personal identifiers, medical test results, tests or data and any other information relating to any individual which you have provided us in any form submitted to us, or via other forms of interaction with you.

Collection of Data

Information you provide to us:

We collect your name and email address. We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys.

Generally, we collect Personal Data in the following ways:-

(a) when you submit an application form or other forms relating to any of the Services;

(b) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, emails or social media;

(c) when you use some of our Services, for example, websites and apps including establishing any online accounts with us;

(d) when you purchase or obtain third party services through us;

(e) when you request that we contact 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 are contacted by, and respond to, our marketing representatives and customer service officers;

(h) when we receive references from business partners, medical staff and third parties (e.g. where you have been referred by them);

(i) when we seek information from staff or third parties about you in connection with the Services; and

(j) when you submit your Personal Data to us for any other reasons, including when you sign up for the Services or when you express your interest in the Services. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Data Protection Policy.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Services you have requested.

Information from Partners:

We collect information from other companies with whom you have a relationship (“Partners”). These Partners might include (depending on what services you use): your institutions or service providers who make our service available through their product offerings. The information Partners provide us varies depending on the nature of the Partner services, and may include:

• Contact number, Personal ID, Mailing address and postal code.

 

Use of Information:

We use information to provide, analyse, administer, enhance and personalize our services and marketing efforts, to process your digital certificates/documents, queries, and to communicate with you on these and other topics. For example, we use such information to:

• determine your general geographic location, provide localized content and help us quickly and efficiently respond to inquiries and requests;
• coordinate with Partners on making our service available to you, based on the specific relationship you have with the Partner;
• secure our systems, prevent fraud and help us protect the security of our clients’ accounts where reasonably necessary
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, money laundering and to enforce our terms;
• analyse and understand our audience, improve our service (including our user interface experiences and service performance) and optimise service delivery;
• communicate with you concerning our service so that we can send you news about new features or services where available. These communications may be by various methods, such as email, push notifications, text message and online messaging channels.
• Generally, we collect, use and disclose your Personal Data for the following purposes:-
• respond to your queries and requests;
• manage our administrative and business operations and complying with laws, internal policies and/or procedures;
• to assist you in the setting up and/or management of any company;
• to assist you in the opening and/or management of a bank account;
• to assist you in the clearance, completion and/or management of the ‘know-your-client’ (‘KYC’) process
• facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
• to match any Personal Data held which relates to you for any of the purposes listed in this Data Protection Policy;
• to resolve complaints and handle requests and enquiries;
• to prevent, detect and investigate crime and analyse and manage any commercial risks;
• to provide media announcements and responses;
• to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
• legal purposes (including but not limited to obtaining legal advice and dispute resolution);
• to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
• to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
• purposes which are reasonably related to any of the above purposes in this Clause or for any other purpose which we may notify you at the time of obtaining your consent

 

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

• Within Audacia Pte Ltd (‘Audacia’): We share your information within Audacia as needed for: providing you with access to our services; providing customer support; making decisions about service improvements; and for other purposes described in the Use of Information section of this Privacy Statement.
• Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide account opening, marketing, advertising, communications, security, security checks, security investigations, infrastructure and IT services, to customize, personalize and optimise our service, to analyse and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
• Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing the service to users and providing information about the availability of our service
• Protection of Audacia and others: Audacia and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law (including but not limited to), any regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of users or the public, as required or permitted by law.
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.
• We may also collect, use and disclose your Personal Data for the following additional purposes (the “Additional Purposes”):-
• analytics and tracking, including facilitating the sale of analytical data;
• conducting research and surveys to enable us to understand and determine customer location, preferences and demographics to develop programmes in relation to the Services, and to improve our service delivery and your customer experience at our touchpoints;
• providing additional Services and benefits to you, including promotions and programmes from us and our Strategic Partners;
• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of the Services;
• generating leads and managing activities for Audacia and our Strategic Partners’ Products and Services;
• administering research, surveys and personalising your experience at our touchpoints and our Strategic Partners’
• communicating to you through advertisements involving details of the Products and Services, special offers and rewards, either to our customers generally, or which we have identified to be of interest to you (including but not limited to privately upselling, cross selling and marketing);
• organising events and corporate social responsibility projects; and
• purposes which are reasonably related to any of the above purposes in this Clause or for any other purpose which we may notify you at the time of obtaining your consent. In addition, where permitted under the law and subject to the provisions of any applicable law, your Personal Data may be disclosed for the Audacia Additional Purposes to vendors or other third party service providers in connection with promotions and services offered by us and our Strategic Partners.

 

Whenever in the course of sharing information we transfer personal information to other countries, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection. We will not transfer data overseas without your consent, or if it is against the law.

 

 

This Clause describes how your Personal Data may be disclosed by us.

4.1 Subject to Clause 4.2 below, we may share aggregated, non-personally identifiable information with the public and with our partners, such as our vendors, advertisers and other service providers.

4.2 We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed for the purposes listed in Clause 3 above or for any purpose allowed under any applicable law or regulations, to the following parties:-

4.2.1 our related corporations and employees to provide Services to you, address your questions and requests in relation to your customer accounts, with us as well as Services and to activate, deactivate, install, maintain and operate our systems and/or services;

4.2.2 companies providing services relating to insurance and consultancy to us;

4.2.3 agents, contractors or third party service providers who provide operational services to us, such as, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or any other services;

4.2.4 vendors or third party service providers in connection with marketing promotions and services offered by us, our Strategic Partners or our Preferred Partners;

4.2.5 bank officers or services and advisors in relation to providing services and benefits;

4.2.6 other service providers to facilitate their provision of corporate or administrative services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;

4.2.7 any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;

4.2.8 collection and repossession agencies in relation to the enforcement of repayment obligations for debts;

4.2.9 our professional advisers such as auditors and lawyers;

4.2.10 relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and

4.2.11 any other party to whom you authorise us to disclose your Personal Data to.

 

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, and to fulfill the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

 

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA This Clause describes how you can withdraw your consent or obtain access and make corrections to the Personal Data that you have provided us.

6.1 If you would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy, the following methods of withdrawal will apply:-

6.1.1 for our customers, please email us at enquiry@audacia.com; and

6.2 Please be aware that once we receive confirmation that you wish to withdraw your consent for promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. In the meantime, you may still receive promotional materials/communication from us. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Services that you hold or have subscribed to with us.

6.3 If you would like to obtain access and make corrections to your Personal Data records, please contact us in writing as follows:- Data Protection Officer, Audacia Pte Ltd, Frasers Tower, Level 17, 182 Cecil Street, Singapore 069547 or through email at gerald.chew@audacia.com and enquiry@audacia.com.  

6.4 Please note that if your Personal Data has been provided to us by a third party (for example a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.

6.5 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide the Products and Services to you or administer any contractual relationship that is already in place, which in turn may result in the termination of any agreements that you have with us, resulting in you being in breach of your contractual obligations or undertakings. Audacia’s legal rights and remedies in such event are expressly reserved.

GOVERNING LAW This Data Protection Policy and your use of this website is governed by Singapore law.

 

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with Singapore law.