PICS - Singapore

Personal Information Collection Statement (PICS)

IPG Financial Services Pte. Ltd. (referred to hereinafter as the “Company”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the 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 all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental access, erasure or other use.

In order to provide you with our insurance brokerage services and other services set out in the "Purpose" section below, wemay collect personal data directly from youor 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.

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 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 carriers 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 customers;
  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. complying with the laws of any applicable jurisdiction;
  13. carrying out other services in connection with the operation of the Company’s business; and
  14. other purposes directly relating to any of the above.

   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.

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.

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 behaviour, 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 carriers and/or re-insurers 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 carriers 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 wish to withdraw your consent, 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.

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
IPG Financial Services Pte. Ltd.
79 Robinson Road, #13-03, Singapore 068897

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

In certain circumstances, you may have additional rights under the General Data Protection Regulation (2016/679) ("GDPR"). To the extent that GDPR applies to our processing of your personal data, the following shall also apply:

We process your personal data with your consent for the purposes notified to you or set out elsewhere in this PICS.

We may also process your personal data based on one or more of the following legal bases:

(i) where it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;

(ii) where it is necessary to comply with applicable law or a legal obligation;

(iii) where it is necessary for the performance of a task carried out in the public interest; and/or

(iv) where processing is necessary in our legitimate interests or the legitimate interests of another person and these interests are not overridden by your interests or rights in the protection of your personal data.

The legitimate interests pursued may include one or more of the purposes set out in this PICS including:

(i) conducting market research for statistical or other purposes;

(ii) conducting identity checks;

(iii) carrying out other services in connection with the operation of the Company’s business; and

(iv) complying with applicable laws and making required disclosures.

We do not normally ask you to specifically provide us with “Special Categories” of personal data but in some cases, we may collect from youor receive from other third parties (such as background and reference checks service providers), special categories of personal data for purposes of identity verification and underwriting. “Special Categories” of personal data are personal data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.

We retain your personal data for the duration of your engagement with us and for a period following termination of your engagement with us, as required by applicable laws or regulations and/or in accordance with our internal policies and procedures.

In addition to your rights of access, correction and withdrawal of consent set out elsewhere in this PICS, you may also be entitled to the following rights in relation to your personal information:

(i) Erasure - the right to request that we delete personal information that we process about you;

(ii) Restriction of processing - the right to restrict our processing of your personal data in certain specified circumstances such as where our processing is unlawful, the accuracy of the personal data is contested by you or we no longer need to process such data for a particular purpose but are required by you to retain the data for the establishment, exercise or defence of legal claims;

(iii) Portability - the right to receive personal information we hold about you, in a structured, commonly used and machine-readable format, and to transmit such data to another data controller;

(iv) Objection - where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation, or for your personal information not to be processed for direct marketing purposes.

(v) Automated decision making, including profiling – the right not to be subject to a decision based on automated processing , which produces legal effects concerning you or similarly significantly affects you, unless it is: necessary for entering into, or performance of, a contract between us; or authorized by law (e.g. for the purposes of fraud or tax evasion); or you provide your explicit consent; or the right to receive meaningful information about the logic involved, the significance, and the envisaged consequences of such processing for you. 

To make a request to exercise any of these rights in relation to your personal information, please address your requests to the Data Protection Officer at the contact details provided above.

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the first instance.