Personal Data Protection Policy
Aviva Financial Advisers take our responsibilities under Singapore's Personal Data Protection Act 2012 (the "PDPA") seriously. We recognize the importance of proper management, protection and processing of the personal data that you have entrusted to us.
This purpose of this Personal Data Protection Policy ("Policy") is to help you understand how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this Policy or any other queries on how we manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at AFA_dpo@aviva-asia.com.
The Personal Data Protection Act
The Personal Data Protection Act or "PDPA" governs the collection, use and disclosure of personal data by organisations. It consists of the Do Not Call (DNC) Obligations which came into effect on 2 January 2014 and the Data Protection (DP) Obligations which came into effect on 2 July 2014.
This Personal Data Protection Policy ("Policy") provides details of how Aviva Financial Advisers will process, collect, use and disclose your personal data. Please take a moment to read this Policy so that you are aware of the purposes for which we collect, use and disclose your personal data before you provide your consent.
Purposes for Collection, Use, Disclosure and Processing of Personal Data
To manage your relationship and to process and/or administer your financial advisory services with Aviva Financial Advisers (“AFA”), we will need to collect, use, disclose and/or process your personal data.
Such personal data includes information provided by you or other parties from time to time, in our forms or collected from other sources; and includes existing data in our possession and/or to be collected in the future.
Such personal data will be collected, used, disclosed and/or processed by AFA (or Aviva group of companies) for the purpose(s) of:
- Providing, administering, servicing or dealing with the financial advisory services provided by AFA (including processing of applications for any investment products);
- Managing the investment products that you have purchased under the financial advisory services provided by AFA, which may include providing information about the investment product you have purchased;
- Processing or carrying out your instructions or responding to any enquiry given by you or on your behalf;
- Managing matters relating to the financial advisory services which you are entitled to receive (including sending you information on and invitations to seminars and events organised by AFA);
- Mailing of correspondence or any other relevant document(s), to you, which may disclose certain personal data about you on the envelopes/mail packages);
- Managing AFA’s records required to perform the financial advisory services, including storage, archival, back up and/or destruction of personal data.
- Complying with applicable laws, regulations, rules, guidelines, schemes or directions imposed by any regulator, government body, statutory body, law enforcement agency or dispute resolution body;
- Complying with AFA local and group company policies and procedures (including reporting and disclosure policies and procedures);
- Carrying out compliance monitoring and audit reviews; due diligence checks, other screening activities and/or similar activities in accordance with AFA' legal or regulatory obligations or risk management procedures;
- Conducting, processing and analyzing satisfaction surveys and/or research on AFA's financial advisory services;
- If consented by you, providing you with marketing/ promotional information on new and/or other investment products and financial services which in the opinion of AFA may be of interest or benefit to you, by way of telephone calls, SMS/MMS and facsimile to you to any telephone number provided by you to AFA from time to time.
(collectively, the "Purposes")
Some of these purposes may apply or continue to apply after your relationship and financial advisory services with AFA has ended.
The personal data provided by you to AFA may be disclosed by AFA to the following parties (whether such parties are located or resident within or outside Singapore) for one or more of the above Purposes:
- Financial institutions to provide, service and/or administer the investment products that you have purchased under the financial advisory services provided by AFA (including without limitation any brokers and lawyers);
- Employees, representatives, officials and directors of AFA;
- Related companies or third party vendors engaged by AFA to store and maintain our data and documents, to provide administrative or computer services, data analytics or other services or facilities to AFA;
- Related company or regional office or head office to comply with company policies and procedures or upon their valid request.
- Legal and Accounting firms providing services to AFA; and
- Regulatory, government and statutory body or dispute resolution body to comply with applicable laws or regulation or upon their valid request.
(collectively the "Recipients").
Neither AFA nor any of its officials shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to AFA and/or any of its officials disclosing.
By signing on the forms provided by AFA, you are providing your consent to AFA to:
- Collect use, disclose and/or process your personal data;
- Collect personal data about you from sources other than yourself and to use, disclose and/or process such personal data;
- Disclose your personal data to the Recipients; and
- Transfer your personal data to where the Recipients are sited (whether in Singapore or outside of Singapore)
for the Purposes as described above.
Request to Withdraw Consent
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us at AFA_PDP@aviva-asia.com.
If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days of your request.
Please be informed that if you request to withdraw your consent for us to use your personal data for servicing purposes, we will not be able to provide financial advisory services to you and/or provide servicing support for the investment products you have purchased through us.
Request for Access and/or Correction of Personal Data
- You may request to access and/or correct the personal data currently in our possession by contact us at AFA_PDP@aviva-asia.com.
- For a request to access personal data, we will provide you with the relevant personal data 30 calendar days from such a request being made.
- For a request to correct personal data, we will :
- correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
- subject to paragraph , we will send the corrected personal data to every other organisation to which the personal data was disclosed by AFA within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
- Notwithstanding paragraph [3(b)], we may, if you consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
- We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data.
- If you have any complaint or feedback about how we are handling your personal data or complying with the PDPA, please contact our Data Protection Officer at AFA_dpo@aviva-asia.com.
- We will attend to any complaint or grievance that you may have promptly and fairly.
Updates on Personal Data Protection Policy
- As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
- We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Policy will be posted on our website and you agree to be bound by such amended Policy.
- You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest Policy in relation to personal data protection.