Client Terms of Business

2.1 Generally, we collect your Personal Data in the following ways: 

a) when you submit forms (online or otherwise) relating to any of our products and services, or submit any online queries; 

b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us; 

c) when you register for and/or use any of our services on websites owned or operated by us; 

d) when you interact with our staff, including customer service officers, for example, via telephone calls or video conferencing calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails; 

e) when you request that we contact you or request that you be included in an email or other mailing list; 

f) when you respond to our promotions, initiatives or to any request for additional Personal Data; 

g) when we receive references from business partners and third parties, for example, where you have been referred by them; 

h) when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events; 

i) when you are contacted by, and respond to, our marketing representatives and customer service officers; 

j) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our services or job applications, for example, from business partners, public agencies, your exemployer, referral intermediaries and the relevant authorities; and/or 

k) when you submit your Personal Data to us for any other reason.

2.2 When you browse our website, you generally do so anonymously but please see paragraph 6 below for information on cookies and other technologies which we have implemented on our website. We do not, at our website, automatically collect Personal Data unless you provide such information to us. 

2.3 Without prejudice to the generality of Clause 2.1, we may collect information about the computer, mobile telephone, smart phone or other device you use to access our website. 

2.4 If you provide us with any Personal Data relating to a third party (e.g. information of your dependent, spouse, children and/or parents), by submitting such information to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

3.1 In general, we collect, use and disclose your Personal Data for the following purposes:

a) to provide you with the products or services that you have requested, including sourcing for quotes, arranging for placement of your policies, handling claims on your behalf, servicing your policies and account;

b) to help us review, develop, improve, manage the delivery of and to the extent this requires the use of Personal Data, enhance our products and services, including analysing customer behaviour and future customer needs, conducting market research, list processing and data analytics (including by requesting feedback from you or your participation in surveys);

c) to help us administer, maintain, manage, renew and operate our products and services, including to carry out billing;

d) for authentication and verification purposes;

e) to communicate with you and respond to your queries, requests and complaints;

f) to handle disputes and conduct and facilitate investigations and proceedings;

g) to protect and enforce our contractual and legal rights and obligations;h) to prevent, detect and investigate crime, including fraud and moneylaundering, and to analyse and manage other commercial risks;

i) conduct checks to comply with anti-money laundering and anti-terrorism financing requirements;

j) to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

k) to manage our administrative operations and business operations and to comply with internal policies and procedures;

l) to organise, facilitate, and administer roadshows, tours, promotional events, contests and/or competitions;

m) to comply with any contractual terms and conditions to which eazy is bound by;

n) to commence, respond to, or act 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);

o) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

p) to match any Personal Data held which relates to you for any of the purposes listed herein;

q) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sales);

r) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

s) purposes which are reasonably related to the aforesaid.

3.2 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

a) If you have an account with and/or policy serviced by us:

(i) to process your application for the account and/or arrange for placement of policy and to maintain your account and/or service your policy;

(ii) to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

(iii) to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(iv) providing customer service and support (including but not limited to customer relationship management and processing and settlement of invoices and bills);

(v) administering and processing your requests including creating and maintaining profiles of our customers in our system database for administrative purposes (including but not limited to tracking your use of the website);

(vi) personalising your experience on the website and conducting market research, understanding and analysing customer behaviour, location, preferences and demographics in order to improve our service offerings;

(vii) if you use the website or our application, sending you notifications and facilitating the provision of our services to you;

(viii) administering debt recovery and debt management; and/or

(ix) for purposes which are reasonably related to the aforesaid.

b) If you are an employee, officer or owner of a vendor, contractor or other external service provider, or prospective vendor, prospective contractor, or other prospective external service provider of eazy:

(i) to conduct appropriate due diligence checks;

(ii) to evaluate your organisation’s suitability as a vendor, contractor, and external service provider for eazy and to conduct background checks on you;

(iii) to create and maintain profiles of our vendors, contractors, and external service providers in our system databases;

(iv) to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider; (v) to process and facilitate payment of invoices and bills;

(vi) to respond to emergencies;

(vii) to communicate with you changes and development to our policies, terms and conditions and other administrative information;

(viii) for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance);

(ix) to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and

(x) for purposes which are reasonably related to the aforesaid.

3.3 Furthermore, where permitted under the Data Protection Laws, eazy may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

a) taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;

b) providing or marketing services and benefits to you, including promotions, service upgrades, loyalty and/or reward programmes (including event invitations, newsletters and marketing and promotional information to you pursuant to such programmes);

c) organising roadshows, tours, campaigns and promotional or events and administering contests and competitions;

d) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services;

e) sending you details of services, services updates and rewards, either to our customers generally, or which we have identified may be of interest to you;

f) conducting market research, aggregating and analysing customer profiles and data to determine health-related patterns and trends, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you other products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or

g) purposes which are reasonably related to the aforesaid.

3.4 If you have provided us with your Singapore telephone number(s), email address(es), mailing address(es) or such other contact information and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), email address(es), mailing address(es) or such other contact information, then from time to time, eazy may contact you using such Singapore telephone number(s), email address(es), mailing address(es) or such other contact information (including via voice calls, text, fax or other means) with information about our products and services.

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 or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.6 You may withdraw your consent for receiving marketing or promotional materials/communication by contact us using the contact details below.

3.7 Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.

3.8 Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from eazy.

As an independent insurance intermediary, we act as your agent and strive to be impartial in advising you. However, in certain circumstances, we may act for and owe duties of care to other involved parties or other factors may potentially compromise our ability to act in your best interests. We will advise you when these circumstances occur, so you will be aware of any possible conflict of interest. Should a potential conflict of interest be particularly complex or difficult to manage, we will agree with you the best way forward.

We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may resultin our inability to provide, or delays in providing you with products and services you have requested, or processing any requests and applications you may have made to us.

6.1 When you visit or interact with our sites, services, we or our authorised service providers may use cookies, web beacons, and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience.

6.2 The information collected by us or our authorised service providers may recognise a visitor as a unique user and may collect information such as how a visitor arrives at our sites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

6.3 The use of cookies, web beacons and similar technologies by us on our website has different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off our sites.

Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a particular device or browser. There are several types of cookies:

• Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.

• Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.

• First-party cookies are set by the site you are visiting.

• Third-party cookies are set by a third party site separate from the site you are visiting. Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options.

Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) may be included on our sites and services. Web beacons typically work in conjunction with cookies to profile each unique user and user behaviour.

Similar technologies – Technologies that store information in your browser or device utilising local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers.

We may use the terms “cookies” or “similar technologies” interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.

6.4 The website and certain site features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits.

However, if you decline cookies or other similar technologies, you may not be able to take advantage of the website and certain site features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.

Our website may contain links to other websites operated by third parties, including for example our business partners. We are not responsible for the data protection practices of websites operated by third parties that are linked to our website. We encourage you to learn about the data protection practices of such third party websites. Some of these third party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

8.1 If you:

a) have any questions or feedback relating to your Personal Data or about this Privacy Policy;

b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or

c) would like to obtain access and make correction to your Personal Data records,

please contact us as follows:

8.2 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to eazy on your behalf.

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

If you pay a premium to us it will be treated as having been received by the insurer, which means you cannot be asked to pay it again, even if we do not pay the premium to the insurer. Similarly, once we have received the premium, we would be unable to return it to you, for example in the event of the insurer becoming insolvent. Also, if the insurer pays claims money or a return premium to us for onward transmission to you and we do not pay you, then the insurer will still be liable to you.

It is your responsibility to check the documentation we send you in relation to each insurance contract and satisfy yourself that it is entirely in accordance with your understanding and instructions. You should advise us promptly, in any event within 7 days, of any incorrect points or changes required. Otherwise, we will assume that the documentation and insurance contract satisfy your requirements. It is important that you keep your insurance documents safe.

This Privacy Policy shall be governed in all respects by the laws of Singapore.

If we fail to reach the standards you expect of us, you should contact your eazy servicing manager in the first instance. We will endeavour to ensure that the matter is handled fairly and promptly by a suitably senior and independent member of staff.

If we are unable to settle your complaint with us, and you are a consumer, you may be entitled to refer it to the Financial Industry Disputes Resolution Centre Ltd (FIDReC).

We are required by law to conduct due diligence to protect us and our clients against the risk of financial crime which include money laundering and terrorism financing. At the start and throughout our relationship, you agree to provide any information as is necessary to verify your identity and do all things necessary to enable us to comply with applicable anti-money laundering, terrorism financing and “know-your client” laws, regulations, directives and guidelines. You agree that we shall be not be liable for any Losses arising as a result of any delay or failure to process any application or transaction if such information and documentation as has been requested by us has not been provided by us or to our satisfaction.

In addition, we are obliged to report evidence or suspicion of financial crime to the relevant authorities, and where we do so, we may not be able to inform you that a disclosure has been made or of the reasons for it.

This Privacy Policy shall be governed in all respects by the laws of Singapore.

We are each entitled to terminate this appointment to act as your agent at any time.

Except as you may specifically arrange and agree with us, upon termination:

a) our obligations to you will cease and we will owe you no further obligations to provide any services or products; and

b) we will be entitled to retain and receive any fees, commissions, brokerage or other remuneration earned.

Although we provide post-placement and claims handling services for you for as long as you remain our client, we reserve the right at our discretion to charge a reasonable fee for such services when you cease to be a client but still wish us to act for you (and we are prepared to do so).

Under no circumstances will we be liable to you for:

a) any special, punitive, indirect or consequential loss or damage of any kind whatsoever including but not limited to loss of business, reputation, goodwill, opportunity or profits, in each case however caused or arising and whether or not foreseeable, even if we are actually aware of or have been advised of the likelihood of such loss or damage and regardless of whether the claim for such loss or damage is made in negligence, for breach of contract, breach of trust, breach of fiduciary obligation or otherwise on our part;

b) any failure or delay in the performance of our obligations if we are prevented from so performing our obligations by any existing or future law or regulation, any existing or future act of governmental authority, Act of God, flood, war (whether declared or undeclared), terrorism, riot, rebellion, civil commotion, strike, lockout, other industrial action, general failure of electricity or other supply, aircraft collision, technical failure, accidental or mechanical or electrical breakdown, computer failure or failure of any money transmission system or any reason which is beyond our control; or

c) any action taken or omitted by us except to the extent that a court of competent jurisdiction determines that our gross negligence, wilful default or fraud was the primary cause of any loss to you.

Further, our total liability to you arising in connection with the performance or contemplated performance of our obligations to you shall in the aggregate be limited to S$200,000 in respect of any policy or insurance brokered by us on your behalf.

Nothing in these terms of business will limit, or will be construed as limiting, our liability for death or personal injury resulting from our negligence, nor our liability for fraud or any other liability which cannot be excluded or limited under applicable law.

You shall also indemnify us against all Losses, actions, demands and proceedings (including, but not limited to, all costs, charges and expenses paid or incurred in disputing or defending any of the foregoing) which we may sustain or incur or which may be made against us in connection with (a) our appointment or performance of our role as your agent as contemplated under these Terms of Business; (b) your breach of these Terms of Business; (c) use of electronic communications as contemplated under these Terms of Business; (d) any action taken by us either as part of our investigation of any suspected breach of these Terms of Business or as a result of our finding or decision that a breach of these Terms of Business has occurred; and/or (e) your breach or infringement of any rights of any other person, except such as may result from our own wilful default, gross negligence or fraud. You shall cooperate as fully as reasonably required in the defence of any such claim, action or proceeding. eazy Pte Ltd reserves the right, at its own expense, to assume the exclusive defence and control of any claim or matter subject to indemnification by you.

This Clause 16 shall survive the termination or expiry of these terms of business or our appointment as your agent.

We shall be entitled to amend, add to, vary and/or introduce new terms to these Terms of Business from time to time upon notice to you. Such amendment(s), addition(s) and/or variation(s) shall take effect from the date stated in the notice. However, in certain cases where it is not practicable for notice, we should not obliged to give prior notice.

Such notification may be provided to you by:

a) posting such changes on our website;

b) electronic mail or letter; or

c) such other means of communication as we may determine.

If you do not accept any such amendments, additions and/or variations, you shall forthwith discontinue making use of our services and inform us that you wish to terminate our appointment.

If you continue to make use of our services and do business with us, you shall be deemed to have agreed to all the amendments, additions and/or variations of terms applicable without reservation or modification.

If any provision of these terms of business is held to be illegal, invalid or unenforceable, in whole or in part, that provision shall apply with such modification or deletion as is necessary so that the provision is legal, valid or enforceable, as the case may be, and gives effect to the commercial intention of the parties. To the extent that such modification or deletion of the provision in whole or in part is not possible, then such provision or such part of it shall, to the extent that it is illegal, invalid or unenforceable, be deemed not to form part of this terms of business, so that the legality, validity or enforceability of the remainder of these terms of business shall be unaffected.

These terms of business constitute the entire agreement and understanding of the parties and supersedes any previous agreement between the parties relating to the subject matter of this agreement.

A person who is not a party to these terms of business has no right under the Contracts (Rights of Third Parties) Act (Cap. 53B) of Singapore to enforce any term.

These terms of business shall be governed by and construed in accordance in accordance with the laws of Singapore. The courts of Singapore are to have exclusive jurisdiction to settle any disputes which may arise out of or in connection to these terms of business and accordingly any legal action or proceedings arising out of or in connection with these terms of business may be brought in such courts.