Asta Solutions Asia Pte. Ltd. Privacy Notice
This notice describes how we, Asta Solutions Asia Pte. Ltd. (ASA), a division of “Asta Capital Ltd” as a data controller, collects, uses, shares and retains your personal data. ASA is committed to ensuring that any personal data we receive is protected and handled in accordance with applicable data protection laws.
We recognize the importance of protecting the privacy and the rights of individuals in relation to their personal data and are committed to compliance with the Personal Data Protection Act (2012), its subsidiary legislation and the guidelines issued by the Personal Data Protection Commission.
This Privacy Notice also informs you about your rights and choices regarding use, access and correction of your personal information.
Please read the following carefully to understand how we will treat your personal information.
2. Who we are
Asta Solutions Asia Pte. Ltd the data controller, is approved by the Monetary Authority of Singapore under the Insurance (Lloyd’s Asia Scheme) Regulations. Asta Solutions Asia Pte is Registered in Singapore under UEN: 20224202022H. Our registered office is 10 Collyer Quay, #10-01 Ocean Financial Centre, Singapore, 049315.
This Privacy Notice applies to all the activities of ASA.
3. Collecting your data
We collect and use relevant information about you to provide you with your insurance cover or the insurance cover that benefits you and to meet our legal obligations.
Personal data/information this Privacy Notice has the same meaning as in the Personal Data Protection Act (2012). It means information which is connected to a natural person who can be identified from that information, either by itself or when combined with other data likely to come into our possession.
We may collect a range of personal and business information supplied by you or third parties on your behalf.
Specifically we may collect the following information throughout the duration of your relationship with us:
- Basic personal details such as your name, address, date of birth or age, gender, marital status, and additional information about your insurance requirements
- Contact details (such as email addresses and telephone numbers) related to correspondents, brokers and/or other relevant connections to insurance business.
- Personal information and health information related to your insurance requirements and details of any specific claims.
We may also collect special category data, such as race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation when needed to provide insurance or process claims. This information will only be used for the specific purpose for which it was provided and to carry out the agreed service. In certain instances, we will also need to collect and process special category data relating to individuals who may benefit from the policy. Where necessary we will obtain your specific consent to use special category data. We may do this via an intermediary or broker.
We may collect data about other individuals, such as employees, family, or members of your household. If you give us information about another person, it is your responsibility to ensure and confirm that you have told that person why and how their personal data will be used and that you have that person’s permission to provide that data (including any special category data) to us and for us to process it.
4. Using Your Information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Assessing your application for a product, service or quote
- Providing and administrating relevant insurance policies
- Client care, including communicating with you
- Payments to and from individuals
- Verifying your identity and carrying out sanctions/anti-fraud/financial crime checks
- Handling claims
- Managing insurance and reinsurance claims
- Defending or prosecuting legal claims
- Investigation or prosecuting fraud
- Dealing with complaints
- General risk modelling
- Contacting the policyholder to renew your policy
- Evaluating the risk to be covered and matching to appropriate policy/premium
- Payment of premium
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with legal or regulatory obligations.
- Transferring books of business, company sales & reorganisations.
5. Retention of Your Information
We will keep your personal data only for as long as it is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under your policy of insurance, or where we are required to keep your personal data due to legal or regulatory reasons.
Retention of specific personal data may be necessary for one or more of the following reasons:
- To fulfil statutory or other regulatory requirements;
- To evidence events/agreements in case of disputes;
- To meet our operational needs;
- To save data for historical purposes.
We will securely delete or erase your personal information if there is no valid business reason for retaining your data.
Details of specific retention periods for different aspects of your personal data are available in our Detention Retention Policy which you can request from us, via our contact details below.
6. Sharing Your Information
The way insurance works means that your information may be shared with, and used by, a number of third parties in the insurance sector for example, insurers, agents or brokers, reinsurers, loss adjusters, premium collection and claims validation processors and providers, sub-contractors, regulators, law enforcement agencies, fraud and crime prevention and detection agencies and compulsory insurance databases. We will only disclose your personal information in connection with the insurance cover that we provide and to the extent required or permitted by law.
We may share your personal data with third parties under the following circumstances:
- Asta Group Companies. We operate as a global business, so we may share your personal data with group companies who may use this information for the purposes described in this Privacy Statement.
- Insurance companies, Lloyd’s Coverholders, intermediaries, financial institutions, retrocessionaires and business partners. We may share your personal data with insurance companies, intermediaries, financial institutions, retrocessionaires and business partners that use your personal data in connection with the provision of insurance and processing of claims. For example, we may share your personal data with other reinsurance businesses for the purposes of settling claims.
- Service providers. We may share your personal data with service providers that perform services and other business operations for us, for example, IT and analytics providers, actuarial service entities, auditors and advisers.
- Any law enforcement agency, court, regulator, government authority or professional body. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- Asset purchasers. We may share your personal data with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal data uses it in a manner that is consistent with this Privacy Notice.
- Customer companies. We may share our personal data with your company or employer in certain circumstances, for example, if your company has a corporate insurance product with us and you make a claim under that product.
- Because we operate as part of a global business, the recipients referred to above may be located outside of Singapore. See the section on "International Data Transfer" below for more information.
Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal data. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
We require all third parties to respect the security of your personal data. Parties processing data on our behalf are only permitted to process your personal data for specified purposes and in accordance with our instructions.
For a broader understanding of how personal data is managed within the insurance market, please refer to the London Market Core Uses Information Notice as above.
Transfer of Personal information from the EU
Where we transfer personal data from EU countries to Asta companies and service providers outside the European Economic Area (EEA), we provide safeguards to ensure the security and the confidentiality of your personal data, by framing the transfer through either (i) the Standard Contractual Clauses adopted by the European Commission or (ii) through Binding Corporate Rules when your personal data is transferred to other entities of the Asta Group.
International Data Transfer
From time to time we may need to share your personal information with other insurance market participants or their affiliates, including Lloyd’s subsidiaries, who may be based outside of the European Economic Area (EEA). We may also allow our service providers, who may be located outside the EEA, access to your personal information. We may also make other disclosures of your personal information overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.
We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests.
- We aim to transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights:
- Where applicable, transfers of data overseas will be covered by standard contractual clauses, adopted by the European Commission which give specific contractual protections designed to ensure that your personal information receives an adequate and consistent level of protection.
- Any requests for information we receive from law enforcement or regulators will be carefully checked before personal information is disclosed.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data.
7. Storing Your Information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Your Rights
Under certain circumstances, you may have rights under data protection laws in relation to your personal data.
- Request access to your personal data
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
Request access to your personal data (commonly known as a “data subject access request”). You are entitled to a confirmation whether we are processing your data, a copy of your data, and information about purposes of processing, who do we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, where we got your data from and how you can make a complaint. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Please be advised that there may be consequences if you exercise your right to erasure. If you subsequently make a claim, it may be impossible to administer your claim without your personal data.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
We can continue to use your personal data following a request for restriction, where we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you (such as the payment of claims). We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please Contact us as detailed below.
9. Changes to our privacy notice
10. How to contact us:
Data Protection Officer
Asta Solutions Asia Pte
10 Collyer Quay
#10-01 Ocean Financial Centre
If you are dissatisfied with how we process your personal data you can make a complaint to a supervisory authority.
The supervisory authority that supervises Asta Solutions Asia Pte is the Personal Data Protection Commission Singapore (PDPC)
Personal Data Protection Commission Singapore | PDPC
If you live in a European Economic Area (EEA) member state, you may complain to the supervisory authority in that country. You can find the contact details of your national supervisory authority on this website https://edpb.europa.eu/about-edpb/board/members_en.
If you live in the UK you can make a complaint to the Information Commissioner’s Office. Details of how to do this are on its website https://ico.org.uk/make-a-complaint/.