1. Personal Data
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your full name (including your first name and last name), date of birth, nationality, gender, residential address, telephone number, email address, password, formal identification information (such as your NRIC, passport, or other identification number), employment information, financial information (including credit card information), travel activity, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, we collect Personal Data in the following ways:
(a) when you submit any form to us, including but not limited to any registration or application forms;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
(c) when you interact with our staff and Representatives, including our customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, email, and via our electronic services;
(d) when you use our electronic services, or interact with us via our websites and platforms or use services and/or features on our websites and platforms (such as https://www.winkwink.sg/);
(e) when you request that we contact you, that you be included in an email or other mailing list, or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(f) when you are contacted by, and respond to, our marketing Representatives and agents and other service providers;
(g) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our services and/or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities;
(h) when you submit an employment application and/or your details for an independent contractor engagement or when you provide documents or information including your resume, your track records and expertise, and/or curriculum vitae in connection with any appointment, engagement or position, or when you attend interviews with us;
(i) where allowed under applicable law, when we seek information about you regarding your relationship with us (including for our products/services or job applications) and receive your Personal Data (for example, from business partners, public agencies, your ex-employers and the relevant third parties);
(j) when you share comments or feedback with us (such as by through our electronic services or by contacting our Representatives via email); and/or
(k) when you submit your Personal Data to us for any other reason.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.
2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have requested.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
3.1 Generally, Stellar Ace collects, uses and discloses your Personal Data for the following purposes:
(a) responding to, processing and handling your queries, requests, feedback and suggestions, or otherwise providing customer support;
(b) managing the administrative and business operations of the Companies and complying with internal policies and procedures;
(c) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity and facilitating and carrying out due diligence checks;
(f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
(g) preventing, detecting and investigating crime (including fraud and money-laundering or terrorist financing), analysing and managing commercial risks, and managing the safety and security of our premises and services (including carrying out CCTV surveillance and conducting security clearances);
(h) project management, conducting audits, reviews, and analysis of our internal processes and action planning, and managing and preparing reports on incidents and accidents;
(i) providing media announcements and responses;
(j) organising promotional events;
(k) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(l) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including disclosures to regulatory bodies, conducting audit checks, surveillance, investigation, and due diligence); and/or
(m) any other purpose relating to or reasonably necessary for any of the above.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).
3.2 In addition, Stellar Ace may collect, use and/or disclose your Personal Data for the following purposes depending on the nature of our relationship:
(a) verifying and processing your personal particulars and payments in relation to the purchase or provision of goods and/or services;
(b) providing you with goods and/or services which you have purchased or requested to receive, and to push content to you which may be relevant to you (including to personalise and customise your experience based on your interactions with our platform(s), your profile information and preferences, and other content you submit from time to time);
(c) communicating with you and informing you of changes and development to the Companies’ policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you;
(d) resolving complains and handling requests and enquiries;
(e) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you;
(f) analysing and understanding the behaviour and preferences of you or another individual in relation to the services;
(g) identifying any other products or services provided by Stellar Ace that may be suitable for you or another individual, or personalising or customising any such products or services for you or another individual;
(h) if you submit any application to us as a candidate for employment / your engagement as an independent contractor:
(i) conducting interviews;
(ii) processing your application / engagement which includes pre-recruit / pre-engagement checks involving your qualifications and facilitating interviews;
(iii) providing or obtaining employee / customer references and for background screening;
(iv) assessing your suitability for the position or engagement applied for;
(v) processing staff referrals;
(vi) verifying your identity and accuracy of your personal details and other information provide;
(vii) performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;
(i) if you are our employee, independent contractor, temporary staff, intern or trainee
(i) administrative, human resources related and support processes relating to your employment or relationship with us, including managing and terminating your employment or appointment, staff benefits (including travel, manpower, business continuity and logistical management or support), processing expense claims, administering insurance applications, leave administration, training, learning and talent development, resolving grievances, and planning and organising corporate events;
(ii) investigating any acts or defaults (or suspected acts or defaults), or contraventions of our internal or external compliance obligations;
(iii) providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;
(iv) ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
(v) ensuring that Stellar Ace’s operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed by Stellar Ace, located in Stellar Ace’s premises, or under Stellar Ace’s control, your activities on such computer software and hardware, your internet access, your work emails and personal digital and storage devices); and/or
(j) processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, where permitted under applicable law, Stellar Ace may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling or processing of Personal Data):
(a) providing or marketing services, products and benefits to you, including promotions and loyalty and reward programmes, including joint marketing and/or cross promotions with third parties;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by Stellar Ace or other third parties;
(c) administering contests and competitions, and personalising your experience at Stellar Ace’s touchpoints;
(d) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile;
(e) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your Personal Data with such third parties or their service providers for them to collect, use, disclose or process your Personal Data for any of such purposes; and/or
(f) collection, use, disclosure and/or processing of customer data by us or our business partners for data monetisation purposes.
3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use and/or disclose your Personal Data. If so, we will collect, use and/or disclose your Personal Data for these purposes as well.
4. DISCLOSURE OF PERSONAL DATA
4.1 Subject to applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) Stellar Ace’s related corporations;
(b) companies or brokers providing services relating to insurance and/or reinsurance to Stellar Ace;
(c) agents, contractors or third party service providers who provide services to Stellar Ace, such as software services, vehicle servicing and towing, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support investigation services, or other services;
(d) vendors or other third party service providers, including in connection with promotions and services offered by Stellar Ace;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
(f) banks, credit card companies, other financial institutions and their respective service providers;
(g) third party referrers;
(h) our co-brand and other business partners;
(i) our professional advisers such as our board of directors, auditors and lawyers;
(j) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
(k) external business and charity partners in relation to corporate promotional events; and/or
(l) any other party to whom you authorise us to disclose your Personal Data to.
4.2 We may also share information about you in aggregate or anonymised form, for example, generic aggregated demographic information regarding visitors and users, with the abovementioned entities or parties (e.g. our business partners, trusted affiliates and advertisers).
5. DEEMED CONSENT
5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to Stellar Ace collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties:
(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to Stellar Ace for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and
6. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA
(a) for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:
(i) any investigations or proceedings;
(ii) fraud detection and prevention;
(iii) entering into, managing or terminating an employment relationship or appointment;
(iv) to recover a debt owed by you to us or to pay a debt owed by us to you;
(v) to obtain legal services;
(vi) detection and prevention of misuse of services by users; and
(b) we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of any of the Companies).
(a) Cookies are small text files stored in your computing or other electronic devices when you visit our website and platforms for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
(b) Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
7.3 Without limiting the generality of the foregoing, we may employ cookies and other technologies as follows:
(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
(b) making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;
(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(d) collating information on a user’s search and browsing history;
(e) when you interact with us on our websites and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page, your searches for hotels or experiences, bookings you have made, and other actions);
(f) using such information to understand how people use our websites and platforms, and to help us improve their structure and contents;
(g) using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms; and/or
(h) personalising the website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
7.4 We may also collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Stellar Ace may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
7.5 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and other Stellar Ace online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
7.7 The way which cookies can be managed depends on your browser. Please check with your browser provider on how you may configure or disable cookies on your browser.
8. DATA SECURITY
8.1 Stellar Ace cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with websites.
8.2 We cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you use our platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
8.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
9. THIRD-PARTY SITES
10. CONTACTING US – QUESTIONS, FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
10.1 If you:
(c) would like to obtain access and make corrections to your Personal Data records, you can email our Data Protection Officer at [email protected].
10.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Stellar Ace on your behalf.
10.3 You may withdraw your consent as provided under PDPA. However, if you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, Stellar Ace may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with Stellar Ace, and your being in breach of your contractual obligations or undertakings. Stellar Ace’s legal rights and remedies in such event are expressly reserved.
11. GOVERNING LAW
Last updated: 1 November 2023