AllAssured Privacy Policy

Introduction
AllAssured is owned by Trunk Tech Pte Ltd, UEN 201705723K, a registered company in Singapore, hereinafter referred to as (“We/Us”). This Privacy Policy sets out our policy regarding the collection, use, and disclosure of any information you may provide when you access and use our website via desktop or mobile application AllAssured (the “Application”) or the services provided by Us. This policy also explains the choices that you can make about the way that we use your information. It is intended to be read together with AllAssured’s Terms and Conditions. By accessing and using the Application, you are deemed to have read, accepted, and agreed to be legally bound by the terms of this Privacy Policy and AllAssured’s Terms and Conditions, whether you have registered as a user.

Data Collection
When you access or use the Application or any part thereof, or communicate with Us or any of our officers, employees or agents whether through written, published or electronic means, the telephone or otherwise, We may collect or receive personal or non-personal information or data about, in connection with or from you, including without limitation possibly through cookies, pixel tags, website and data analytics, and other technologies (“Your Information”), in accordance to the Personal Data Protection Act 2012 (“PDPA”).

Personal information or data may include without limitation, your:
• Name
• Age
• Telephone number
• Email address
• Background information

Non-personal information or data may include without limitation, your:
• Browser information
• Internet protocol (IP) address
• How you use the Application or any part thereof
• Aggregated information

We may also collect personal information about someone else from you to provide a better analysis. If you provide personal information to Us about someone else, you must obtain that person’s prior consent for you to provide his/her personal information to Us.

Most web browsers are initially set up to accept cookies. You can choose to block or disable cookies by changing the settings on your web browser. If you choose to block or disable all cookies, including strictly necessary cookies, you may find that certain features on the AllAssured or any part thereof will not work properly.

We will retain Your Information for as long as the purpose(s) for which AllAssured collected it continues. It is then destroyed unless further retention is required to satisfy any legal, regulatory or accounting requirement or to protect our interests.

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email at support@all-assured.co.

Information we may receive from third parties
We may receive information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Facebook Connect, by “following,” “liking,” adding the AllAssured application, linking your account to the AllAssured, etc., that third party may pass certain information about your use of its service to AllAssured. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the AllAssured. You may also unlink your third party account from the Service by adjusting your settings on the third party service. If you unlink your third party account, we will no longer receive information collected about you in connection with that service.

Information we collect from you automatically
In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, information about the way you use the Application and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Cookies information
When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets AllAssured help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time.

You can control or reset your cookies through your web browser, which will allow you to customise your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log file information
Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear gifs/web beacons information
When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service.

Device identifiers
When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by AllAssured. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Location data
When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Data Usage
We may use Your Information in accordance to the PDPA:
• to follow up on and to facilitate the processing of your request(s) or application(s) in relation to products and services, and to connect you with third party product or service providers who will provide you with information, or process your request(s) or application(s) about products and services;
• to respond to, address, facilitate or fulfill your inquiries or requests;
• to update our records about you;
• to understand your needs;
• to personalise your experience on the Application and on our other websites by presenting advertising, promotions, offers, products and services tailored to you;
• to allow you to participate in contests and similar promotions, and to administer these activities. There may be additional rules applicable to these activities, which may contain additional information on how We use and disclose your Information;
• to communicate with you about the Service: We use your contact information to get in touch with you and to send communications about critical elements of the Service. For example, we may send you emails about technical issues, security alerts or administrative matters.
• to promote and drive engagement with AllAssured: We use your contact information to get in touch with you about features and offers relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences. You can opt-out of getting these communications as described below.
• to enable you to send messages, or refer the Application, or any part thereof, or any product or service mentioned on the Application, to another person. By using this functionality, you represent and warrant that you are entitled to use and provide Us with that person’s name, email address and other contact details;
• for our business purposes, which will include, without limitation, data analysis, audits, developing new products, improving our Application and their respective contents, improving the products and services offered or distributed by Us, calculating the Application’s usage levels, identifying user behaviour and usage trends, determining and improving the effectiveness of our promotional campaigns, diagnosing server problems, geographic mapping, and administering the Site or any part thereof;
• to conduct background and credit checks and assist other financial institutions to conduct background and credit checks;
• for crime or fraud detection, prevention and prosecution; and
• to comply with any law, regulation, order or legitimate request, to any relevant governmental or other authority or regulatory body.
• to enforce our Terms of Use or to protect the security or integrity of our Service
• to exercise or protect the rights, property, or personal safety of AllAssured, our Users or others.
• for matters that you have specifically consent to: From time to time AllAssured may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.

You agree that in the event you contact us via email, online chat, letters, facsimile, or other written, published or electronic means, We are entitled to keep a record of the relevant correspondence.

Legal bases for processing information under the GDPR (for users in the EEA)
For AllAssured users in the the European Economic Area (EEA), AllAssured processes your information in accordance with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how AllAssured may process your information, and the rights that EEA users have in relation to it. This means that AllAssured will collect and use your information only where:

• We need it to provide you the Service and fulfil our obligations to you under our Terms of Service.
• It is justified because of a legitimate interest such as for research and development or marketing the Service (but only where our legitimate interest isn’t overridden by your interest in protecting your data).
• You consent to us using your information in a certain way.
• It is necessary for compliance with our legal obligations.

If you have consented to our use of your information you may withdraw that consent at any time. Depending on the situation you can withdraw your consent by emailing support@all-assured.co. Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so it may mean that it is not possible for you to continue using the Services.

Disclosure to Third Parties
We will not sell your Personal Data to any third parties outside AllAssured and its group companies (including any parent, subsidiaries and affiliates) without your consent. There may be instances however that we will need to share your Personal Data to certain suppliers, agents or service providers for the purpose of providing the Service to you and to facilitate AllAssured’s interests, as outline above.

Some of the third parties that AllAssured may share your personal information with include providers who assist AllAssured with functions such as:
• optimising, monitoring or researching the usage, performance and operation of our Application as well as the services we provide through our Application.
• Email services
• Hosting and storage

We only share your Personal Data with such third parties in so far as necessary to perform their services and tasks and we will ensure that these third parties protect your Personal Data in a manner consistent with this Privacy Policy and will not use your Personal Data for any other purposes than those specified by us.

We may provide personal data without express written permission, if allowed under applicable laws, in circumstances that include, but are not limited to:
• Requests from governmental agencies, subpoenas, court orders or other legal requirements. In these circumstances, AllAssured will make every effort to limit the nature of the disclosure.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• With our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
• You have consented to our sharing it with a third party for a particular purpose.

AllAssured may also share your information with a third party in circumstances where we sell divest or transfer AllAssured (including any shares in AllAssured), or any combination of its products, services, assets and/or businesses to a third party. Information such as customer names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations, similar transactions or proceedings involving all or a portion of the AllAssured.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

Consent to Disclose Information
We understand your need for privacy and will take reasonable care with regards to collecting, safeguarding, transference and usage of all your personal data.

Thus, only authorised employees of the company will be allowed to gain access to your data. Any disclosure of your personal information is strictly subjected to your clear consent via the contact form in our Application, i.e. request for more information, etc.

You are not obligated to provide any personal information or consent the disclosure of your information to us. However, if you disagree to provide the required information or consent, certain services to you may not be available.

Ads on AllAssured
We may share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business partners to deliver advertisements (“ads”) that may be of interest to you. AllAssured may allow third-party ad servers or ad networks to serve advertisements on the Service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalise the advertising content. AllAssured does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask AllAssured to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, AllAssured determines the target audience and AllAssured serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The AllAssured Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

How we transfer, store and protect your data
All data will be stored in Singapore. If there is a need for Us to transfer Your Information out of Singapore, We will only do so after we have been assured that Your Information will receive a comparable level of protection as laid down in this Privacy Policy and/or the PDPA. We endeavour to take reasonable steps to protect the confidentiality and security of Your Information in accordance to the PDPA. However, We cannot guarantee the security of any data you transmit by electronic means, as no data transmission over the Internet or by any other electronic means can be guaranteed as totally secure. You accept the inherent security risks of providing information and dealing over the Internet or by electronic means. To the maximum extent permissible under applicable law, We are neither responsible nor liable for any breach of security.

The Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. It is your responsibility to maintain the secrecy of any user ID and login password you hold.

Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence. As a result, We do not accept responsibility or liability for the confidentiality, security or integrity of Your Information in connection with its transmission over the Internet.

Cross-border transfers of information (for users in the EEA)
For Users in the EEA, where we transfer your information to a third party provider that is not located in the EEA, and is not subject to an adequacy decision by the EU Commission, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information. From time to time we may also seek your consent to transfer your information to a third country outside the EEA.

Keeping your information safe
AllAssured cares about the security of your information, and uses appropriate safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from AllAssured, at all times. However, AllAssured cannot ensure or warrant the security of any information you transmit to AllAssured or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the AllAssured, such as social networks. AllAssured is not responsible for the functionality or security measures of any third party.

In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, We reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.

Compromise of information
In the event that any information under our control is compromised as a result of a breach of security, AllAssured will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

You control your account information and settings
You may update your account information by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at support@all-assured.co.

Opting out of collection of your information for Tracking / Advertising
Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents AllAssured or its business partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at support@all-assured.co.

Rights in respect of your Information
The laws of some countries grant particular rights in respect of personal information. Users in those jurisdictions may have the right to:

• Request a copy of your information;
• Request that we correct inaccuracies relating to your information;
• Request that your information be deleted or that we restrict access to it;
• Request a structured electronic version of your information; and
• Object to our use of your information;

Should you wish to make a request in respect of your personal information please contact us at support@all-assured.co. Alternatively, for requests relating to rights under the GDPR, contact us at support@all-assured.co.

In some circumstances AllAssured may not be able to comply with a request that you make in respect of your personal data. For example, we may not be able to provide a copy of your information where it infringes on the rights of another User. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so.

If we are unable to resolve your request, or if you are concerned about a potential violation, you may be entitled to report the issue or make a complaint to the data protection authority in your jurisdiction.

Data Retention Policy, Managing Your Information
We will retain Your Information for as long as you use the Application and for a reasonable time thereafter and for as long as we have a valid purpose to do so. In particular, AllAssured may retain your information for the purpose of comply with its legal and audit obligations, and for backup and archival purposes. If you would like us to delete Your Information, please contact us at support@all-assured.co and we will respond in a reasonable time. Please note that some or all of Your Information may be required in order for the Application to function properly.

Links to Other Sites and services
Our Application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. In addition, you agree that we are not responsible for and we do not exercise control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

Do-Not-Call Registries
In your dealings with Us, you may have provided consents for Us to collect, keep and use your personal data and to contact you for providing health and wellness information and other related purposes. These consents apply even if your mobile or other contact numbers are listed with the Singapore Do-Not-Call registry (or any other similar registries or services), and will override the DNC or similar listings. Your consents apply to all your dealings with Us, including through mobile apps, Internet portals and any other electronic systems or properties.

Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
If you:
• have any questions or feedback relating to your Personal Data or our Privacy Policy;
• would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
• would like to obtain access and make corrections to your Personal Data records;

You may email us at support@all-assured.co. We will try to comply with your request as soon as reasonably practicable. In some cases, we may not be able to remove or change Your Information or any part thereof, including, without limitation, where doing so would be against the law or regulations or any direction by any public or governmental authority. Withdrawal of your consent will automatically limit certain services to you as personal information is required for such services, such as a request for Us or Financial Adviser Representative to contact you.

If your personal data has been provided to us by a third party (e.g. your employer or partner), you should contact that party to make such queries, complaints, and access and correction requests to Us on your behalf.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, We may not be in a position to continue to provide its products or services to you, or administer any contractual relationship in place. It may also result in the termination of any agreements with Us, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.

Staying In Contact
If you create an account with us, or if you do not create an account but you do submit your email address we can send you: newsletter updates, account information updates and other Website announcements. If you want to hear more from us you can opt to receive more information which will include messages and content we think would be interesting for you including targeted advertisements and marketing messages from us. As soon as you are no longer interested in these extra mailings, you can choose to unsubscribe from our mailing list by dropping us an email at support@all-assured.co.

Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Singapore and you agree to be subject to the non-exclusive jurisdiction of the courts of Singapore.

Privacy Policy Periodic Updates
Our goal is continuous improvement and we will make amendments and revisions to our Privacy Policy from time to time as deemed necessary. Any changes and updates that we make shall be made available for viewing here.

We reserve the right to revise our Privacy Policy at any time without any notice. The Privacy Policy will be effective immediately at the time of revision and will supersede any previous Privacy Policy. Thus, please check our Privacy Policy whenever you visit our website. Your usage of our website will constitute as your acceptance of these Terms & Conditions of Use.

Last Update
This Privacy Policy was last updated and revised on 19 Jun 2018.