ADDITIONAL PRIVACY POLICY

This addendum supplements, details and provides more information in regards to the Privacy Statement in accordance with the applicable local data privacy law, its implementing rules and regulations and related issuances of the local data privacy regulator (collectively referred to herein as “Law”).

This addendum applies to the processing of personal data by NuLife website, employees and team. For this purpose, the term “processing” shall include, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of personal data.

Personal data

Singapore law defines personal data as data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.

This collection may include but not limited to: 

  • name, title, address;

  • personal identification and/or passport number;

  • telephone number;

  • email address and online passwords;

  • records of communications with NuLife;

  • responses to market surveys and contests conducted by NuLife or on its behalf;

  • credit card or debit card information;

  • camera or video footage that identifies individuals (including CCTV footage) installed at some parts of NuLife’s premises as part of its security infrastructure;

  • username, password and other identifiers when you register at NuLife’s website;

The personal data collected by NuLife may include, but not limited to, the following:

In processing personal data, we will take into account the nature of its sensitivity and will only process sensitive data upon the express consent of the data subject and only for purposes it was provided, or in accordance with law.

In processing sensitive data, NuLife will inform data subjects of the sensitive data that is necessary to carry out the core functionality of the product or service, and the consequences of refusal to the processing, for the purpose of allowing the data subjects to decide whether or not to give consent.

Collection, Purpose of Collection and Processing of Personal Data. 

Personal data will, generally, only be collected and used for the primary purposes of:​

  • communicating with employees, customers, contractors, suppliers, agents or any other individuals;

  • conducting, improving, maintaining and developing a business relationship and/or for employment purposes;

  • general HR administration and information required for the management of the employment relationship;

  • processing, servicing or enforcing transactions and sending related communications;

  • identifying and verifying individuals that have been supplied with any NuLife's services or products;

  • administering customer orders or managing projects;

  • responding to an individual’s queries;

  • administering contests or market surveys conducted by NuLife or on NuLife’s behalf;

  • marketing with consent (such as providing individuals with information about NuLife's products and promotional notices and offers);

  • processing your purchase, application, inquiry or request;

  • ensuring IT security and resource management;

  • ensuring site security;

  • compliance with applicable laws and regulations of regulatory authorities and enforcement agencies;

  • administrative purposes such as billing, payment and debt collection;

  • responding to any claim and/or legal process; and

  • improving NuLife’s website.

 

Disclosure

NuLife does not disclose your personal data for any secondary purposes unless your consent has been previously obtained in accordance with law.

NuLife will not sell or license any personal data that it collects from an individual.

In situations where NuLife processes personal data outside reasonable expectations, NuLife will require your consent prior to processing. Information and reasons personal data may be disclosed include but are not limited to: 

  • for the primary purpose for which it was collected; or

  • for purposes that a reasonable person will consider appropriate in the circumstances; or

  • where the individual has consented; or

  • for direct marketing by NuLife where consent has been given, but individuals will be given the opportunity to opt out of such direct marketing. NuLife includes its contact details in any direct marketing; or

  • where permitted by law;

  • to NuLife’s parent, related, affiliate and/or associate company;

  • in any court of law or any relevant party in connection with any claim or legal proceedings, legal firms and/or advisors, debt collection agencies, credit reporting agencies and/or credit providers;

  • to any payment agencies including, but not limited to, financial institutions for purposes of maintaining financial records, assessing or verifying credit, and facilitating payment;

  • regulatory authorities and enforcement agencies;

  • third party service providers, consultants, insurers, underwriters, auditors and advisors as well as their respective agents and/or contractors on a need to know basis; and

  • any actual or potential assignee, transferee or acquirer of any of NuLife’s business in connection with any corporate exercise.

Cross-border disclosure

Any personal data provided to NuLife may be transferred to, stored by or disclosed to an overseas recipient. For example, NuLife may use a server hosted overseas to store data, which may include your personal data.

Your personal data may also be processed by employees or by other third parties operating outside of Singapore in countries like the United States of America or in the European Union, who work for NuLife, or by the representatives and employees of NuLife's affiliates and partners.

NuLife will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal data.

Data breach 

Where a suspected data breach has occurred, NuLife will act in accordance with its data breach response plan. In the event that NuLife has determined that a data breach has occurred, we will notify the local data privacy regulator and affected data subject (s) in accordance with law.

Anonymity 

NuLife gives individuals the option not to identify themselves when dealing with it, where practicable. However, if you do not provide us with the personal data that we request, our ability to handle your inquiry, request, complaint or application may be diminished.

Consent and limitation in the processing of personal data

You may choose whether or not to provide your personal data, and, if already provided, you may choose to exercise your right to object, block, or remove such personal data as provided by law. If you would like to exercise your right to object, block, or remove your consent, please contact one of our members at NuLife or use the contact form found in the footer below. 

In this case, however, we may not be able to adequately provide you the assistance or services you requested. When you object, block or remove your consent, NuLife shall no longer process your personal data, except in cases allowed or required by law. If you would like to update, correct or access your personal data, please contact one of our members at NuLife or use the contact form found in the footer below. 

Inquiries and Complaints 

If you have any queries or concerns about NuLife’s privacy policy, this addendum or about our use of your personal data, you may write to us please contact one of our members at NuLife or use the contact form found in the footer below. 

Updated: 18 September 2021​