Privacy Notice
November 2023
1. bolttech Privacy Notice
This Privacy Notice ("
Notice") describes how bolttech Insurance Agency Pte Ltd and its
affiliates (collectively referred to as "
bolttech", "
we", "
us" or "
our")
collects, uses and shares personal data in the context of our websites, business contacts,
suppliers, (together referred to as "
you" or "
your") or otherwise for the purposes of
conducting or developing business relationships with you. When processing your personal data bolttech complies
with the Singapore Personal Data Protection Act 2012 (PDPA) and other applicable laws and regulations.
This Notice also explains your ability to
edit, update, correct, or delete your personal data and certain security procedures that we have
implemented to protect personal data in line with relevant data protection legislation.
In this Notice, you can find out more about:
■ How we collect personal data, the types of personal data we
collect and the purposes for which personal data is collected
■ Direct Marketing and how you can manage your marketing
preferences
■ How we share information within bolttech and with our service
providers, regulators and other third parties
■ International transfers of personal data
■ Cookies and third-party links
■ How we store and protect personal data
■ Accessing or correcting your personal data
■ Modifications to this Notice
■ How you can contact us for more support.
2. When we collect personal data, the types of personal data we collect and the purposes for
which personal data is collected
In this section, you can find out more about:
■ When we collect personal data
■ The types of personal data we collect and how we use personal
data
This website is not intended for children, and we do not knowingly collect data relating to
children.
3. When we collect personal data
We may collect personal data about you if you:
■ use one of our websites or online services, you are a
registered user, or you choose to register on our websites (Website Users);
■ obtain one of our services (Customers); or
■ work with us as a business partner (Business Partners).
4. The types of personal data we collect and how we use personal data
Website Users
When you use our website, bolttech collects metadata that result from your usage of our websites
including referral page, date and time of access, type of web browser, IP-address, geographic
location as determined by your IP address, operating system and interface, language and version of
browser software, session information (such as download errors and page response times).
Your IP address will be used to enable your access to our websites. The metadata will be used to
improve the quality and services of our websites by analyzing the usage behavior of our users.
If you commence direct communications via our websites enquiry form, by telephone or writing to us,
the nature of the enquiry (e.g., as tick box selection from service type/careers/other) and your
message will also be collected and processed to respond to your communications and to improve our
services.
If you are a registered user or choose to register on a bolttech website, you may be asked to
provide the following personal data about you: first and last name, work phone number, company name,
email address, personal telephone number, address, and primary usage.
Bolttech will process this personal data to provide you with the services for registered users,
verify the legitimacy of your account, to avoid fraudulent accounts being opened, provide you with
the products and services requested by you, customer support, contact forms, marketing materials as
selected by you, inform you about system issues, comply with legal obligations, and defend,
establish and exercise legal claims.
The personal data collected from Website Users is also used to personalize your experience of our
websites. We may use such information in the aggregate to understand how you use our services and
the resources provided on our websites. We may also use the feedback you provide to improve our
services.
Customers
If you obtain products or services from bolttech, you may be asked to provide, among other things,
the following personal data about you, your representative and/or your contact person:
■ Information about you (such as name, gender, nationality,
race, occupation), contact information (such as residential address, email address, mobile phone
number), family background (such as spouse and children’s information)
■ Information about your device (such as make, model, device ID, and purchase date)
■ Your health and medical information (such as pre-existing
medical condition, medical history, health records)
■ Your financial information (such as credit card details, bank
account number)
■ Your account user information (such as user name, password)
■ Your personal government-issued identification document
numbers such as NRIC/FIN/work permit/birth certificate, and passport numbers; as required by
financial / insurance sectoral law or necessary to accurately establish or verify your identity to a
high degree of fidelity
■ Your other information relevant to your insurance application
or claim (such as motor vehicle licence number, photos, videos, travel history, device information, previous claim
history)
■ Your CCTV images when you visit our offices
■ Your academic and employment history, professional and work
experience, and other relevant information usually provided in the Curriculum Vitae
bolttech will use such personal data to process your order, deliver the products or services
ordered, provide customer care services, provide you with marketing materials as selected by you,
provide you with bolttech updates and/or newsletters, to maintain our client relationship management
systems, to investigate any complaint you may make, provide evidence in any dispute or anticipated
dispute between you and us, to detect, investigate, report and seek to prevent fraud and anti-money
laundering, for example through know-your-customer (KYC) checks, anti-money laundering (AML) and
counter terrorism financing (CTF), economic and financial sanctions screening and other identity
checks, comply with other legal obligations, defend, establish and exercise legal claims, and
aggregate it on an anonymous basis with other data for data analytic and reporting purposes. We may
also need to conduct credit and fraud checks on business customers and certain officers of your
business, such as your directors.
Business Partners
If you work with us as a Business Partner or a service provider, we will collect personal data from
you, your representative and/or your contact person such as your full name, job title, email
address, phone number.
Most of the personal data is obtained directly from you. In addition, we will collect personal data
from other public sources such as credit reference agencies.
We use this information to review/assess your suitability as a Business Partner or service provider,
to comply with our legal obligations, to detect investigate, report, and seek to prevent fraud and
anti-money laundering, for example through know- your-customer (KYC) checks, economic and financial
sanctions screening and other identity checks and to meet our obligations under any contracts we
have with you, we may also need to conduct credit and fraud checks on your business and certain
officers of your business, such as directors.
5. Emails
If you send to, or receive emails from us, we may monitor their content to ensure compliance with
our internal policies and to protect our business.
6. How we manage the collection and processing of your personal data
We will only collect, use, and share your personal data where we are satisfied that we have an
appropriate legal basis to do this. In general, we do this by obtaining your consent at the point of
data collection and notify you of what we are collecting and why we are collecting it, such as by
providing a link to this Notice. In some cases, we may rely on deemed consent such as where you have
voluntarily provided us with your personal data along with a specific request or for a specific
purpose.
If you engage with us on behalf of another individual, you must first obtain consent or otherwise
demonstrate that you are authorized to act on behalf of that individual in order for us to collect,
use or disclose their personal data. Where consent can be obtained, that individual must be notified
of the purposes for the collection, use or disclosure of their personal data.
You may contact us to withdraw your consent upon reasonable notice by contacting us through the
bolttech Data Subject Request Web Portal or
[email protected]. Please be aware that by withdrawing
your consent you may no longer be receive important information from us about our products or
services, and in certain circumstances we may no longer be able to offer you our services at all.
7. Direct marketing and how you can manage your marketing preferences
How we use personal data to keep you up to date with our products and services
We may use personal data to let you know about our products or services that we believe will be of
interest to you and/or provide you with our newsletters. We may contact you by email, post, or
telephone or through other communication channels that we think you may find helpful. In all cases,
we will respect your preferences for how you would like us to manage marketing activity with you.
As a rule, we will obtain your consent prior to sending you marketing materials. We will only
contact you with marketing materials without your prior consent if this is permitted by law.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
■ we will take steps to limit direct marketing to a reasonable
and proportionate level and bolttech will only send you communications which we believe may be of
interest or relevance to you;
■ you can ask us to stop direct marketing at any time you can
ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the
email marketing messages we send you. Alternatively, you can submit a request through the
bolttech
Data Subject Request Web Portal or by email to
[email protected]. Please specify whether you would
like us to stop all forms of marketing or just a particular type (e.g. email); and
■ you can change the way your browser manages cookies, which may
be used to deliver online advertising, by following the settings on your browser as explained in the
section on Cookies.
8. How we share information within bolttech group and with our service providers, regulators and
other third parties
We share your personal data in the manner and for the purposes described below:
■ With other bolttech entities within our group: Your personal
data will be received by different recipients such as other bolttech entities. We make such
transfers where it is necessary to provide you with our services or to manage our business.
■ With third parties who help manage our business and deliver
services: bolttech engages external service providers such as legal services, website service
providers, marketing service providers, IT support service providers, email administrators, payment
processors, insurance companies, banks, underwriters, repair service providers, and customer service providers. When providing
such services, the external service providers may have access to and process your personal data. We
request those external service providers to implement and apply security safeguards to ensure the
privacy and security of your personal data. These third parties have agreed to confidentiality
restrictions and to use of any personal data we share with them or which they collect on our behalf
solely for the purpose of providing the contracted service to us.
■ With clinics and hospitals.
■ Where bolttech is acting as a broker or a data processor for a third party,
your personal data may be shared with the insurer and/or business
partner for the purposes of enrolling you in the service and processing your claim and otherwise facilitating
the business relationship (such as invoicing or reporting on product or financial performance).
■ With regulatory authorities and government agencies e.g.
Monetary Authority of Singapore, Ministry of Manpower.
■ In the event of a corporate merger and acquisition, your
personal data will be transferred to the third parties being involved in the merger and acquisition
in accordance with applicable law.
9. International transfers of personal data
The personal data that we collect or receive about you may be transferred to and processed by
recipients who are located within and outside of Singapore (such as our offices in Malaysia, Hong
Kong, or the EU), where the level of data protection may not be equivalent to the level of
protection applicable in Singapore. When we transfer personal data outside of Singapore to a
location that does not have equivalent levels of data protection, we enter into a contract with the
recipient requiring them to provide the data with an equivalent level of protection.
10. Cookies
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your
browser to store on your device in order to remember information about you, such as your language
preference or login information. Those cookies are set by us and called first-party cookies. We also
use third-party cookies – which are cookies from a domain different than the domain of the website
you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and
other tracking technologies for the following purposes:
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems.
They are usually only set in response to actions made by you which amount to a request for services,
such as setting your privacy preferences, logging in or filling in forms. You can set your browser
to block or alert you about these cookies, but some parts of the site will not then work. These
cookies do not store any personally identifiable information.
| Cookie Subgroup |
Cookies |
Cookies Used |
| agency.bolttech.sg |
None |
None |
| broker.bolttech.sg |
None |
None |
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the
performance of our site. They help us to know which pages are the most and least popular and see how
visitors move around the site. All information these cookies collect is aggregated and therefore
anonymous. If you do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.
| Cookie Subgroup |
Cookies |
Cookies Used |
| agency.bolttech.sg |
None |
None |
| broker.bolttech.sg |
_gid, _ga |
First Party |
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those
companies to build a profile of your interests and show you relevant adverts on other sites. They do
not store directly personal information, but are based on uniquely identifying your browser and
internet device. If you do not allow these cookies, you will experience less targeted advertising.
| Cookie Subgroup |
Cookies |
Cookies Used |
| agency.bolttech.sg |
None |
None |
| broker.bolttech.sg |
Cookies set by YouTube including YSC, VISITOR_INFO1_LIVE, CONSENT,
yt.innertube::nextId, yt.innertube::requests |
Third Party
|
11. Third-party links
Our websites contain links to websites operated and maintained by third parties over which bolttech
has no control. Any information you provide to third-party websites will be governed under the terms
of each website’s privacy policy, and we encourage you to investigate and ask questions before
disclosing any information to the operators of third-party websites. We have no responsibility or
liability whatsoever for the content, actions, or policies of third-party websites. The inclusion of
third-party websites on our site in no way constitutes an endorsement of such websites’ content,
actions, or policies.
12. How we store and protect personal data
How long does bolttech keep your personal data?
In line data retention policies, we will only retain your personal data for as long as
reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of
your personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax, accounting or other
requirements.
Details of retention periods for different aspects of your personal data are available in our
retention policy. For queries about bolttech data retention processes please submit an Information
Request through the
bolttech Data Subject Request Web Portal or by contacting
[email protected].
In some circumstances we will anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may retain this information
indefinitely without further notice to you.
We have adopted appropriate data collection, storage and processing practices, technical,
organisational and security measures designed to protect against unauthorized access, alteration,
disclosure or destruction of the personal data that you share with us. For example, such measures
include:
■ placing confidentiality requirements on our staff members and
service providers;
■ permanently removing personal data if it is no longer needed
for the purposes for which it was collected;
■ following security procedures in the storage and disclosure of
your personal data to prevent unauthorised access to it; and
■ using secure communication channels such as SSL ("secure
sockets layer") for transmitting data that is sent to us. SSL is an industry standard encryption
protocol used to protect online transaction channels.
As the security of information depends in part on the security of the computer you use to
communicate with us and the security you use to protect user IDs and passwords, please take
appropriate measures to protect this information.
13. Accessing or correcting your personal data
We will take steps in accordance with applicable legislation to keep your personal data accurate,
complete and up-to-date. Depending on the purposes of the processing, you have the right to have
incomplete personal data completed, including by means of providing a supplementary statement. You
also have the right to request access to your personal data as well as additional information about
the processing and to request us to erase the personal data we hold about you.
To make a request to access or correct your personal data, please visit the
bolttech Data Subject
Request Web Portal or contact
[email protected]. We endeavor to fulfil data subject request within
30 days of their receipt and verification of the individual.
We may ask you for additional information to confirm your identity and for security purposes, before
disclosing the personal data requested to you. We reserve the right to charge a fee where permitted
by law, and may do so, for example, in cases where your request is manifestly unfounded or
excessive.
We may not always be able to fully address your request, for example if it would impact the duty of
confidentiality we owe to others, or if we are legally entitled to deal with the request in a
different way.
14. Modifications to this notice
bolttech reserves the right to change this Notice at any time. Any changes to this Notice will be
effective immediately upon notice, by posting the latest version on our websites.
15. Contact us
If you have any questions, concerns or complaints regarding our compliance with this Notice, the
information we hold about you or if you wish to exercise your rights, we encourage you to first
submit an Information Request or File a Complaint through the
bolttech Data Subject Request Web
Portal or contact
[email protected].
We will investigate and attempt to resolve complaints and disputes and make every reasonable effort
to honor your wish to exercise your rights as quickly as possible and in any event, within the
timescales provided by data protection laws.
Last updated: 09 November 2023
