Personal Data Protection Policy
We, at Aioi Nissay Dowa Services Asia Pte. Ltd. (“AIS Asia”) are committed to ensuring the safety and security of your personal information.
We only collect such personal information that is necessary for us to provide you with the services that you have requested, understand your needs, and serve you better as a whole.
The purpose of this document, AIS ASIA’s Personal Data Protection Policy, is to inform you how AIS ASIA manages, collects, uses and discloses personal data relating to you. In Singapore, such business activities are subject to the Personal Data Protection Act (No. 26 of 2012) (the “PDPA”). We conduct our business in compliance with the applicable laws regarding the protection of the Personal Data (as defined below), including the PDPA (if applicable), and have implemented various measures to ensure that any personal data relating to you remains safe and secure.
2. Personal Data
In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
3. Collection of Personal Data
The Personal Data that AIS ASIA may collect from you may include your name, email address, phone number, date of birth, residential address, Foreign Identification Number (FIN), National Registration Identity Card (NRIC) information, preferences, bank account details, and any other Personal Data necessary for AIS ASIA to:
provide our services to you;
improve our services;
add new functionalities;
develop and research new services and products;
market our services;
carry out data analytics;
carry out internal audits;
manage our security and risks;
implement disaster recovery and backup systems;
comply with legal, regulatory and other compliance requirements (including providing assistance to law enforcement, judicial, regulatory, and/or other governmental and statutory bodies); and
carry out work and business related requirements
Typically, AIS ASIA will collect Personal Data relating to you when you:
register for our services and/or submit any forms relating to our products and services to us;
use our services (e.g. through our software applications or when visiting our websites);
sign up for alerts or newsletters;
contact us with enquiries or requests for assistance; or
are referred to us by business partners or third parties.
Apart from collecting such Personal Data directly from you, AIS ASIA may also collect your Personal Data in other ways (e.g. using automated technology such as click-stream data, cookies, flash cookies, web beacons and tracking links) and from third parties (e.g. your use of social media sites, social media applications or third party websites and applications that interact with AIS ASIA) or from publicly available sources.
4. Use of Personal Data
We may use Personal Data relating to you for the Purposes. We will not use Personal Data relating to you for purposes other than those permitted under applicable laws.
5. Disclosure of your Personal Data
We may share and disclose your Personal Data with or to the following parties, for the Purposes or to protect your interests:
Cambridge Mobile Telematics, Inc., a Delaware corporation, which is the original licensor of our services;
companies affiliated and/or related to AIS ASIA located in Singapore and Japan;
partners, vendors, agents, contractors or third party service providers who provide services to AIS ASIA relating to insurance and consultancy;
partners, licensors, vendors, agents, contractors or third party service providers who provide operational services to AIS ASIA such as courier services, telecommunications, IT, payment, printing, billing, payroll processing, technical services, training, market research, call centre, security or other such services to AIS ASIA; and
partners, licensees, agents, contractors, or third party service providers who provide operational services for and on behalf of AIS ASIA.
In the event of an actual or prospective business asset transaction (such as any merger, acquisition or asset sale), we may share and disclose your Personal Data with or to any business partner, investor, assignee, or transferee for the purposes of facilitating such a transaction. We also may share and disclose your Personal Data with or to any relevant government regulators, statutory boards or authorities, courts and arbitral bodies, law enforcement agencies or other industry recognized bodies as required by any laws, rules, guidelines and regulations or schemes imposed by any governmental bodies and authorities.
We may also be required to disclose Personal Data relating to you, where there are grounds to believe that disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes.
In some cases, we shall encrypt, anonymize, and aggregate the information before sharing it. Anonymizing means stripping the information of personally identifiable features. Aggregating means presenting the information in groups or segments (e.g. age groups).
We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.
6. Log Information
Please note that if you use our services, we may collect, use and disclose (i) information about your actual location (such as GPS signals sent by your mobile device) or information that can be used to approximate a location, and (ii) other information on driving behavior such as harsh acceleration, braking, and cornering, speeding, distance travelled and phone distraction while driving for any purposes unless such information is deemed to be Personal Data.
7. Accuracy and Updating of Personal Data
AIS ASIA will strive to keep your Personal Data accurate. We will give you the ability to review and update the Personal Data you have provided.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
Further, when you provide us with any Personal Data relating to a third party (including your spouse, children, parents and/or employees), you represent to us that you have obtained the consent of such third party to provide us with their Personal Data unless otherwise deemed or provided under any applicable laws including the PDPA (if applicable).
Due to the diversity of applications used to support the various functions and services provided by AIS ASIA, updates, choices and modifications to your Personal Data in one (1) platform may not be reflected across all platforms. You may therefore need to update your Personal Data in each platform separately.
If there is any Personal Data relating to you that you are unable to update and which you wish to make corrections to, you may contact us and we will be glad to help you as best as we can.
8. Access to Personal Data and Respecting your Consent
If you wish to access the Personal Data that we have relating to you or inquire about the way in which Personal Data relating to you has been used or disclosed by AIS ASIA in the past year, or wish to withdraw your consent to our use of such Personal Data, you may contact us and we will seek to attend to your request as best as we reasonably can. Please note that:
in order for us to provide any Personal Data we will need to verify your identity and may request further information about your request;
we may refuse access to your Personal Data if it would affect the privacy rights of other persons or if it breaches any confidentiality that attaches to that information;
we may also refuse your request where we are legally permitted to do so and give you such reasons;
we may take a reasonable time to process your application for access as we may need to retrieve information from storage and review the information in order to determine what information may be provided;
if you withdraw your consent to our use and/or disclosure of Personal Data relating to you, we may not be in a position to continue providing our products or services to you or perform any contract we have with you; and
we may charge you a reasonable administrative fee for retrieving Personal Data relating to you.
9. Security of Personal Data
Safeguarding and respecting the confidentiality of your Personal Data is important to AIS ASIA. We will use our reasonable efforts to protect your Personal Data.
Personal Data provided to us is stored on secure servers. AIS ASIA also has security measures in place to protect against unauthorized access, loss, misuse and alteration of Personal Data under our control. However, please note that we will not be held liable or responsible for any loss, misuse or alteration of Personal Data that may be caused by third parties.
10. Retention of personal information
We will only retain Personal Data relating to you for only as long as there is a business or legal need.
In the event that retention of your Personal Data is no longer necessary for any business or legal purposes or when the purpose for which your Personal Data was collected is no longer being served by the retention of your Personal Data, AIS ASIA will remove, destroy or anonymise your Personal Data.
11. Disclosure of personal information policy and procedure of making a complaint
If you believe that we have breached this Personal Data Protection Policy, or any other privacy or data protection laws or regulations which may apply to AIS ASIA, then you should make a complaint to AIS ASIA in the first instance. You should send your complaint in writing to us, and you should include as much detail as you can about the Personal Data affected, and the circumstances that you believe amount to a breach of this Personal Data Protection Policy or the applicable privacy or data protection law or regulation.
Upon receiving your complaint in writing, we will undertake an internal investigation, and we may contact you if we need to obtain any further information in relation to your complaint. We will generally provide a written response to your complaint within one (1) month. Our response will set out the results of our investigation, including whether we agree that AIS ASIA has breached Personal Data Protection Policy or any applicable privacy or data protection laws or regulations.
If you are dissatisfied with our response to your complaint, you may make a complaint to the relevant regulatory body, or privacy or data commissioner (as applicable) in your jurisdiction.
If you have any questions about our Personal Data Protection Policy or concerns about our commitment to your privacy, you may contact us at the email stated below.
12. How to contact us
13. Changes to the Personal Data Protection Policy
AIS ASIA reserves the right to modify and update this Personal Data Protection Policy at any time to ensure it is consistent with industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Personal Data Protection Policy as updated from time to time.
14. Governing Law
This Personal Data Protection Policy shall be governed in all respects by the laws of Singapore.