For the purpose of this Policy, “personal data” means data, whether true or not, about a person who can be identified from that data or from that data and other information to which we have or are likely to have access.
Common examples of personal data that we may collect from you, or that you may provide to us, include the following:
- Date of birth;
- Identification numbers such as can be derived from NRIC, FIN, passports, work permits and birth certificates;
- Photographs and video images;
- Home address, telephone number, email address and other contact information;
- Financial information;
- Unique identifiers, such as those tied to the browser, application or device you are using, such as your Internet Protocol (IP) address and/or device ID, and other unique identifiers such as advertising identifiers;
- Device and browser settings;
- Site-viewing activity, including the pages you have visited, duration of sessions, and search terms;
- Communication preferences;
- Referring domain, destination domain and destination path; and/or
- Geolocation data.
Third Party Personal Data
When you provide personal data on a third party (e.g. spouse, children, parents), including and not limited to beneficiaries or as a life assured, it is deemed you have obtained their consent to provide to us for a specific purpose.
Purposes of Collection, Use and/or Disclosure
Generally, Briix may collect, use, disclose your personal data when it is provided to us by you (or your authorised representative) after you (or your authorised representative) have been notified of the purposes for which the data is collected, and you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes, or where the collection and use of personal data without consent is permitted or required by the PDPA or other laws.
We may collect, use and disclose your personal data for any or all of the following purposes (“Purposes”), depending on the circumstances under which we may need to process your personal data:
- to provide and manage your access to our online services (whether these be presented on a website or in an application, and whether accessed via a computer or a mobile device), including the administration of user accounts and access credentials;
- to manage and follow up on your enquiries regarding our products and services, or any other enquiries;
- to inform you of products, services, offers, promotions, events or activities, whether offered by Briix or our partners, that you may be interested in;
- to process your application for products or services offered or distributed by Briix (including third party products) and provide you with the products and services you have subscribed for or purchased;
- to underwrite and administer our insurance policies, including but not limited to making changes or updates to our policies; providing ad-hoc or regular information about your policy; or assessing, processing, settling, authenticating and investigating claims;
- to collect premiums or make any payments to you in connection with our products and services;
- to verify your identity and any information you provide to us;
- to administer or manage your relationship and/or your accounts with Briix (including the outsourcing of any related services or operational functions to our third party service providers);
- to communicate with you including to send you administrative communications about any account you may have with us;
- to manage and facilitate your relationship with your authorised distributor(s) or representative(s);
- if you are an authorised distributor or representative, to manage your distributor or representative relationship with Briix and our customers, including with respect to commission administration, tagging to customers and the overall supervision oversight framework;
- to administer contests, lucky draws, events and competitions;
- to personalise the appearance or user experience of our customer portal, or to provide targeted advertising on our website or through other channels;
- to conduct investigations, monitoring, security reviews and audit reviews;
- to prevent, detect or investigate crimes, offences or breaches including fraud, money-laundering, counter-terrorist financing and bribery;
- to meet the requirements imposed by any law, rules, regulations, agreements or schemes imposed by any government regulators, law enforcement agencies, government authorities, dispute resolution or industry bodies or in connection with any investigations;
- to analyse your behaviour, for the designing of new or enhancing of existing products and services provided by us; for market, statistical or actuarial research and trend analysis of our products and services for company, regulatory or industry exercises and studies and reviewing the standard of our products and services;
- to generate financial, regulatory, management or other related reports and performance of analytics;
- to maintain the quality of our services (including customer services), including by recording our communications with you for the purposes of training our employees;
- facilitating any proposed or actual business assignment, transfer, participation or sub-participation in any of our rights or obligations in respect of your relationship with us;
- legal purposes such as enforcing obligations owed to us or seeking professional advice (including legal advice); and
- any other purposes which are reasonably related to the aforesaid.
The Purposes may continue to apply for a reasonable period thereafter even in situations where your relationship with us has been terminated or altered in any way.
As the purposes for which Briix may collect, use, or disclose your personal data may depend on the circumstances at hand, a particular purpose may not appear in the list of Purposes above. However, we will notify you of such other purpose at the time of obtaining your consent, unless the processing of your personal data without your consent is permitted by the PDPA or other applicable laws.
Please note that, in the course of our business operations, we may be disclosing the personal data you have provided us to our third party vendors, service providers, agents, affiliates, related corporations and/or other third parties whether located in Singapore or outside of Singapore, for one or more of the abovementioned Purposes. This may also include disclosures of personal data to our professional advisers such as our lawyers and auditors; any law enforcement agency, statutory board, government regulator, government authority, dispute resolution or industry bodies as necessary to comply with any laws, rules, regulations, agreements or schemes; any other party as permitted under applicable law.
Third Party Personal Data
In any circumstances where you provide Briix with personal data of a third party (e.g. your spouse, children, or parents), including and not limited to as beneficiaries or as a life assured (“Third Party Data”), you represent, warrant and undertake that:
- you have obtained the necessary and appropriate consent of that third party for the disclosure of their personal to Briix and the collection, use and disclosure of their personal data by Briix for the abovementioned Purposes; and
- all Third Party Data that you provide to Briix are accurate. You must notify Briix in writing as soon as you become aware that any such Third Party Data has since been updated or is no longer accurate; and
- if you become aware that any individual whose Third Party Data you have provided has partially or fully withdrawn his/her consent, you must notify Briix in writing as soon as practicable. Upon receipt of such notice, Briix reserves the right to discontinue or not provide any products, services, and/or transactions to you that are connected with such Third Party Data.
Withdrawing your consent
The consent that you provide for the collection, use and disclosure of your personal data in connection with the Purposes will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the Purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided above.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you or honour the obligations in relation to any life insurance policy/policies that you may have with us. We will, in such circumstances, notify you before completing the processing of your request. If you decide to cancel your withdrawal of consent following such notification, please inform us in writing or via email to our Data Protection Officer.
Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
You may adjust your browser settings in order to be notified when receiving a cookie. Should you wish to disable the cookies and pixel tags associated with our website and platforms, you may also do so by changing your browser settings. However, please note that by doing so, you may not be able to use certain features or functions of our website and other platforms.
Accuracy, Access and Correction
As Briix relies on your personal data to provide products and services to you, we generally will make a reasonable effort to ensure that personal data collected by or our behalf is accurate and complete. You shall ensure that the information you provide to us is at all times correct, accurate and complete. You shall update us in a timely manner of any changes to the information provided to us.
You may at any time request to access and/or correct your personal data that is in our possession or control by submitting a written request to us at email@example.com.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Protection and Retention
Briix applies reasonable security measures to prevent the unauthorised access, collection, use, disclosure, copying, modification, disposal, erasure, or loss of personal data in our possession or control by limiting physical access to data within our systems and encrypting sensitive data when transferring such data. This will also include physical and technical measures such as up-to-date antivirus protection,. However, Briix cannot completely guarantee the security of any personal data and we cannot be responsible for any unauthorized use of personal data by third parties that is attributable to factors beyond our reasonable control.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
By providing your personal data to us, you accept that Briix may retain your information for as long as it is necessary to fulfil the Purpose(s) for which such personal data had been collected or other legal or business purposes. Commercially reasonable steps will be taken to delete, destroy or anonymise your personal data when it is no longer necessary for any of the Purposes or other legal or business purposes.
Links to other websites
Our website and platforms may contain links to third party websites for your convenience and information, and social media features such as the Facebook “Like” button. However, please note that these websites and features operate independently from us, and may have their own privacy notices or policies. If you choose to access these websites and/or use these features, you should review their privacy notices or policies to understand their privacy practices. We will not be responsible for your access or use of these websites and/or features.
Changes to this Policy