Data Protection Policy
We at Altitude AllianCE respect the privacy and confidentiality of our clients’ personal data. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Privacy / Data Protection Policy to assist you in understanding how we collect, use, disclose, process and retain your personal data.
HOW WE COLLECT YOUR PERSONAL DATA
The PDPA defines personal data as “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 the organisation has or is likely to have access.”
We collect the personal data of our prospects and clients through the following methods / channels:
- When you call in to request for information or enquiry
- When you wish to preview a product or service
- When you register as a participant
- When you request for technical support
- When you submit an application form
- When you make payment
- When you indicate you wish to have follow-up from salesperson
- When you send in your job application form
- When you sign in as a visitor
- When you respond to a marketing call
- When your application (e.g. for financial products) is submitted for approval
TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
The types of personal data we collect about you may include:
- Non-medical Treatment/Services
- Education & Professional Qualifications
- Employment Details & History
- Personal Details
- Criminal Background/Past Offences
- Academic History
- Personal Contact Information
- Family Background & Details
- Medical Details/Health Information
- Photos & Video Footage
- Financial Information
- Fitness Records
- Purchase Information/History
HOW WE USE YOUR PERSONAL DATA
We use the personal data we have collected about you for one or more of the following purposes:
- For All Future Purposes
- Process payment for purchases and transactions
- Provide customer service and support
- Pass information about you to our agents and associates to carry out services
- Help improve products and services
- Update records in our database
- Develop, enhance, market and provide products and services
- Comply with legal obligations and regulatory requirements
- Process payment for products and services
- Create, develop, operate, deliver and improve our products and services
- Fulfil orders and services
- Billing and other credit-related activities
- Conduct risk assessment
- Respond to inquiries and provide customer services
- Internal purposes for auditing, data analysis and research
- Analyse risk and business results
- Process applications and registration
- Delivery of products and services
- Process contract renewals and upgrades
- Enhance customer experience
- Customer care and account management
- Internal purposes for accounting, auditing and booking
- Carry out our obligations arising from any contracts entered into between you and us
- Provide information to subsidiaries or partners that perform services for the company
- Send information and updates
- Billing and payment processing
- Process and administer employment records
- Investigate complaints, claims and disputes
- Training & career development
- Benefits & compensation management
- Personnel management
- Recruitment & selection
- Payroll processing
- Processing & administration of employment records
- Staff Appraisals
- Employee communication
- Claims & disbursements
- Account payables/receivables
WHO WE DISCLOSE YOUR PERSONAL DATA TO
We disclose some of the personal data we have collected about you to the following parties or organisations outside Altitude Alliance Pte Ltd:
- Insurance Companies (Group Insurance for Employees)
- Advisory Services (Financial Investment & Insurance Products)
- Regulatory Authorities (e.g. MAS for banks and financial institutions)
- Financial Advisors
- Delivery Services
- Other Contracted Service Providers
- Next-of-Kin / Guardians
- Associates / Agents
- Employees / Staff
- Head Office
- Marketing Firms
HOW WE MANAGE THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
We take our responsibilities under the PDPA seriously. We are committed to implementing policies, practices and processes for data protection that comply closely with the PDPA obligations. These are elaborated in the rest of this Policy document.
- OBTAINING CONSENT
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purpose.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you enter into a sales agreement.
- THIRD-PARTY CONSENT
If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.
- WITHDRAWAL OF CONSENT
If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted.
Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature in an online service.
ACCESSING AND MAKING CORRECTION TO YOUR PERSONAL DATA
You may write in to us, based on reasonable grounds, to find out how we have been using or disclosing your personal data. We are obligated under the PDPA to allow you access to your personal data of the past one year, and to make any correction if there is any error or omission. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will try to respond to your request within 30 days. By which time we will give you an estimate of how long it is going to take to retrieve all the relevant data, and how much we will charge you for processing the request.
ACCURACY OF YOUR PERSONAL DATA
We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we will do a verification exercise for you to update us on any changes to your personal data. If you are a client or customer, it is important that you update us if there are any changes in your personal information such as your home address.
PROTECTION OF PERSONAL DATA
We have implemented an Information Security Policy that governs how personal data and confidential information are protected within our organisation. We will take the necessary security arrangements to protect your personal data that is under our charge or control to prevent unauthorised access, collection, use, disclosure, or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
External data intermediaries who process and maintain your personal data on our behalf will be bound by contractual data security arrangements we have with them.
RETENTION OF PERSONAL DATA
We will not retain any of your personal data under our charge or control when it is no longer necessary for any business or legal purposes. We have a Document Retention Policy that spells out how long we ought to retain each type of confidential document or personal data. Certain retention periods are based on statutory or regulatory requirements.
We will ensure that your personal data that no longer has any business or legal use will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in databases.
TRANSFER OF PERSONAL DATA
If there is a need for us to transfer your personal data to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.
Please note that your personal data may be transferred to — and maintained on — computers located outside Singapore where the data protection laws may differ from those in your state, province, country or other governmental jurisdiction.
If you are located outside Singapore and choose to provide your personal data to us, please note that we transfer the information to Singapore for processing here.
TRACKING OF USER ACTIVITY
We use tracking tools such as Google Analytics
We use “cookies” to collect information about your activity on our Web site. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
The following is used for remarketing services for purposes of advertising
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page http://www.google.com/settings/ads
COMPLIANCE WITH LAWS
Where required to do so by law, we will disclose your personal data to the relevant authorities or to law enforcement agencies upon their requests.
LINKS TO OTHER SITES
We have no control over, or unable to assume any responsibility for the content, privacy policies or practices of any third party sites or services.
CHANGES TO THIS DATA PROTECTION POLICY
We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page.
Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.
If you have any questions about our collection, use, and/or disclosure of your personal data; feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer(s) at:
Contact Number: 6206 0222
Email Address: firstname.lastname@example.org
Any query or complaint should include, at least, the following details:
- Full name and contact information of the data subject
- Brief description of the query or complaint
We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.