Collection of Personal Data

We generally collect Personal Data in the following ways:

• When you submit any information or form(s) to us relating to our products, services or for any other reasons;
• When you enter into any agreement or provide any information relating to your transaction with us;
• When you respond to our request for additional personal information or to our promotions;
• When you interact with our appointed representatives or staff e.g. telephone calls, face-to-face meetings (both of which may be recorded), emails and letters;
• When you submit an enquiry through our website or use our online services;
• When you submit a job application to us;
• When you register for our events and any photographs/ videos taken of you by our representatives or us during the events that are hosted by us;
• When you complete feedback forms after our events such as seminars or talks;
• When we seek or receive information from third parties about you for compliance with regulations, e.g., prevention or detection of money laundering, terrorism financing or other unlawful activities, or from your former employer(s) in connection with your Job application;
• When our business partner or third party refers you to us with your consent;
• When your images are captured by our CCTV cameras while you are within our office premises;

If you provide third parties’ personal data (e.g. information of the life assureds, insured persons, beneficiaries, beneficial owners, dependents, spouse, children parents, siblings, prospects, payors and/or employees) to Sony Life, you represent and warrant to Sony Life that prior consents have been obtained from each of the third parties for the collection, usage, disclosure and processing of their personal data in the manner as set out in this Policy.

Purposes for Collection, Use
and Disclosure of Personal Data

We collect, use and disclose your Personal Data for any one or more of the purposes below:

• Verifying your identity and the accuracy of the information collected;
• Providing financial advisory services or recommendation for product(s) or services based on your financial needs analysis, where applicable;
• Completing product provider’s application forms and provide any additional information that the provider may subsequently request;
• Administering, servicing, maintaining, managing and operating the products and services offered to you;
• Facilitating the processing of claims;
• Resolving complaints;
• Providing you with ongoing service and requesting updates of your Personal Data;
• Preventing, detecting and investigating crime, including fraud and money-laundering, and other unlawful activities ;
• Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
• Processing your application for a job with us, including checks such as credit standing and qualifications;
• Obtaining reference checks and for background screening/ vetting prior to your employment with us;
• Inviting you to our events or to participate in contests and competitions;
• Communicating with you the marketing, advertising and promotional information or material about the insurance products, financial or investment products or services that we are selling or marketing which may be of interest or benefit to you;
• Requesting feedback, participation in surveys or conducting market research;
• Conducting audit reviews and compliance monitoring;
• Conducting checks with the Do Not Call Registry;
• Debt collection;
• Responding to, processing and handling your queries, complaints, feedback and requests;
• Storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
• Training employees and monitoring for quality assurance; and/ or
• Any other purposes relating to any of the above;
  (collectively, the “Purposes”).

As the purposes for which we may/ will collect, use, disclose and process your personal data depend on the circumstances at hand, such purpose may not appear above However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or law.

Disclosure of Personal Data

Sony Life will take reasonable steps to protect your Personal Data against unauthorised disclosure. To facilitate our business operations and carry out one or more of the Purposes, we may disclose the personal data you have provided to us and/or collected by us to third parties whether located in Singapore or overseas. The third parties listed below may use and process your personal data for one or more of the Purposes. They are:

• Our associated and related corporations;
• Our providers for insurance and investment products and services;
• Agents, contractors or third party service providers who supply services to Sony Life such as information technology, telecommunication, data entry, data storage, data recovery, mail distribution, payment, payroll, marketing, training, market research, compliance, auditors, lawyers, medical and professional service;
• Credit reference agencies, or in the event of default, any debt collection agencies;
• Governmental/ regulatory authorities, law enforcement agencies, courts, dispute resolution entities (which have jurisdiction over Sony Life such as the Financial Industry Disputes Resolution Centre Ltd) or legal process participants and their advisers;
• Your family, relatives, appointed executors and their professional advisers in connection with your will(s) or the administration of your estate;
• Any third parties involve or facilitate in business asset transactions; and/ or
• Any other parties to whom you have authorised us to disclose your Personal Data;

Management of Personal Data

We take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Sony Life to make a decision that affects you, or discloses to another organisation. To achieve this, you must update us in a timely manner as and when required if there are any changes to your personal data that you have provided to us. If you fail or omit to do so, we will not be responsible to you for relying on inaccurate or incomplete personal data provided by you or otherwise.

We put in place commercially reasonable security arrangements to ensure that your personal data is protected to prevent unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties or data loss which are wholly attributable to factors beyond our control.

If your personal data is to be transferred out of Singapore, we will take appropriate steps to ensure that the foreign recipient organisations of the personal data provide the standard of protection that is at least comparable to the protection under the PDPA.

Request for Access and Correction of
Personal Data Withdrawal of Consent

You may request to access to or correct your personal data or withdrawal your consent for us to collect, use and disclose your personal data by submitting a written request to us as follows:

Data Protection Officer

Email: dpo@sonylifefa.com

For the protection of your personal data, we will need to verify your identity before processing the request. We will verify your identity by, for example, asking to look at relevant identification documents. If we are unable to verify your identity, we will not process your request. You may request to access your personal data in our possession or control You may also request the information about the ways in which your personal data has been used or disclosed by us within a year before the date of request. We may seek to provide you with the relevant information within 30 days from the date of receiving your request. If we could not do so, we will notify you before the expiry of the said 30 days, the reasonably soonest time when we can provide you the requested information.

We may request to access your personal data within 30 days from the date of receiving your correction request. If we could not do so, we will notify you before the expiry of the said 30 days, the reasonable soonest time when it can be done.

Please note that the PDPA exempts certain types of personal data from being subject to your correction request It also specifies the situations which correction need not be made by us despite your request.

The withdrawal of consent for your personal data being used for marketing purposes will not affect our ability to provide you with the products and services that you asked for or have with us.

However, if you have withdrawn consent for Sony Life to collect, use and disclose your personal data for any one or more of the Purposes, it may affect or prevent us to provide you with financial advisory services, post-sale service or processing your claims. There may be other consequences of your withdrawal which we may advise you of. All losses arising out of such withdrawal shall be fully borne by you. Sony Life’s legal rights and remedies are expressly reserved.

Use of Cookies

The “cookies” are small text files placed on your computer or electronic devices that can be retrieved by our website.

Through the “cookies”, we are able to collect and analyse non personal information such as your IP address, browser type, domain names, access times, pages browsed, time spent per webpage, website performance and to remember your preferences. We will not collect your personal information unless you provide it to us. If we collect your personal data through cookies, we may use, disclose and process it in accordance with this Policy.

You may choose to disable the cookies by altering your browser setting. By doing so, you may not be able to use certain services, perform certain transactions or browse certain parts of our website.

Third Party Websites

Our website may contain links to websites operated by third parties. Sony Life is not responsible for the data protection practices of the third parties’ websites even though some of these websites may be co-branded with our logo or trademark.

You should check and understand the third party website’s data protection practices.

Updates on Personal
Data Protection Policy & Governing Law

As part of our efforts to ensure that we properly manage, protect and process your personal data or if there are any changes in industry trend, legal, regulatory or business requirements, we will review and amend this Policy from time to time without any prior notice to you.

The amended Policy will be posted on our website at www.sonylifefa.com/privacy. Please visit this website regularly or from time to time for updated Policy.

This Policy is governed by the Singapore laws.