Privacy Policies

PRIVACY POLICY STATEMENT

Spring Harvest PLT ("SHPLT") is committed to protecting the Personal Data of the individuals we encounter in conducting our business. Generally, “Personal Data” is data about an individual who can be identified or identifiable from that data, or who is identifiable together with other data in the possession of the data user. This Privacy Policy explains how and why SHPLT, its representatives, distributors, reinsurers and authorized administrators (“we” “us” “our”) handle the Personal Data of customers, potential customers, claimants, insureds and policyholders (“you” “your”). Our policies and procedures have been designed to ensure that your Personal Data is protected. This Privacy Policy is designed to assist you in understanding why and how SHPLT collects and uses your Personal Data, to whom such data is disclosed and to whom data access requests can be addressed.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS PRIVACY POLICY MAY BE MODIFIED FROM TIME TO TIME.

BHSIC Personal Data Protection Obligations

The very nature of SHPLT’s business is such that the collection, use and disclosure of personal information is fundamental to the products and services we provide. We work hard to respect and maintain personal privacy and accordingly align this policy with the Personal Data Protection Act 2010 (“PDPA”) when collecting, holding, processing or using Personal Data in Malaysia. We are equally committed to ensuring that all our employees and agents uphold these obligations. Under the PDPA, SHPLT is bound to the following obligations with respect to your Personal Data:

  1. Consent
  2. Purpose Limitation
  3. Notification
  4. Access and Correction
  5. Accuracy
  6. Protection
  7. Retention
  8. Transfer Limitation
  9. Openness
  10. Other Rights, Obligations and Uses

Obligation 1 – Consent

The PDPA prohibits SHPLT from collecting, using or disclosing an individual’s Personal Data unless the individual gives or is deemed to give consent for the collection, use or disclosure of his Personal Data. By providing the Personal Data requested by us, you consent to us using and disclosing your Personal Data as set forth in this Privacy Policy Statement and our Personal Information Collection Statement (if one has been provided to you).

This consent remains valid until you alter or revoke it by providing written notice to SHPLT (contact details provided below). Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you, administer any contractual relationship in place or respond to a claim.

Obligation 2 – Purpose Limitation

The PDPA limits the purposes for which and the extent to which an organisation may collect, use or disclose personal data. SHPLT collects your Personal Data (which may include health information) when you apply for, change or renew an insurance policy with us, or when we process a claim. We collect your personal data to assess your application for insurance, to provide you with competitive insurance products and services and administer them, and to handle any claim that may be made under a policy. If you do not provide us with your personal data, then we may not be able to provide you with insurance products or services or respond to a claim.

SHPLT will only collect Personal Data that is reasonably necessary and related to our provision of insurance products and services (including, but not limited to processing your insurance application, arranging a contract of insurance with you, managing your account with us or handling a claim made under a contract of insurance) and the other purposes of our collection of Personal Data as set out in our Privacy Policy Statement and Personal Information Collection Statement.

Obligation 3 – Notification

When we collect Personal Data directly from you, we will inform you of the purpose of the collection, use or disclosure by reference to this Privacy Policy or through a Personal Information Collection Statement. We will only collect Personal Data by lawful and fair means. Personal Data is collected when you complete an insurance proposal form, make a claim under a contract of insurance with us, or when you use or visit our website and submit other information (including Personal Data) to us.

Some information is collected automatically when you visit our website because your IP address needs to be recognized by the server. We may use the IP address information to monitor and analyze how parts of our website are used.

We may use cookies for a number of purposes as set out in our website terms of use. Our cookies will track only your activity relating to your online activity on our website and will not track your other internet activity. Our cookies do not gather personally identifiable information. Please refer to our website terms of use for our policy on the use of cookies.

Obligation 4 – Access and Correction

Under the PDPA, you have the right (subject to certain exemptions) to request:

  1. Access to some or all of your Personal Data in our possession; and
  2. Information about the ways the Personal Data has been or may have been used or disclosed by us within a year before the date of your request.

Subject to certain exemptions under the PDPA, we will grant access to and correct Personal Data as requested by you. If we hold Personal Data about you and you are able to establish that the Personal Data is not accurate, complete and up to date, we will take reasonable steps to correct your Personal Data so that it is accurate, complete and up to date. We will provide reasons for any denial of access or a refusal to correct Personal Data.

Your request to access or correct Your Personal Data will be actioned as soon as reasonably possible from the time the access request is received. If we are unable to respond within 21 days, we will inform you in writing of the time in which we will be able to respond to your request.

Obligation 5 – Accuracy

We will take practical steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up to date, having regard to the purpose (including any directly related purpose) for which the Personal Data is or is to be used. Please refer to Obligation 4 for details on how you can obtain and correct any Personal Data relating to you that we may hold.

Obligation 6 – Protection

We will take all practical steps to ensure that Personal Data we hold is protected against unauthorized or accidental access, processing, erasure or other use. We provide a highly secure online infrastructure for activities conducted via our website, including SSL (secure socket layer) encryption, IDS (intrusion detection system) and the use of firewalls and anti-virus software. We also adopt stringent security procedures with the use of user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy. Our online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms.

Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Data you might have with us has been compromised), please immediately notify us.

Obligation 7 – Retention

We will retain your Personal Data for only as long as necessary to serve the purposes set out in this Privacy Policy and Personal Information Collection Statement in compliance with all statutory and regulatory requirements in Malaysia concerning the retention of Personal Data. We will take reasonable steps to destroy or permanently anonymize Personal Data if it is no longer needed for such purposes.

Obligation 8 – Transfer Limitation

Due to the global nature of our business, for the purposes set out in this Privacy Policy, we may transfer Personal Data to parties located in other countries that may have a different data protection regime than is found in Malaysia. Personal Data collected in Malaysia by SHPLT may be transferred to parties which may be located in Malaysia or overseas, such as to other SHPLT branches; SHPLT secure data centers; SHPLT affiliates, reinsurers, lawyers, auditors, service providers and business partners; governmental or regulatory authorities; providers of risk intelligence for the purpose of customer due diligence or anti-money laundering screening, in order to carry out the purposes, or directly related purposes, for which the Personal Data was collected. Where such a transfer is performed, SHPLT will take appropriate steps to ensure that the overseas recipient of Personal Data is bound by legally enforceable obligations to provide a standard of protection to that Personal Data that is comparable to that of the PDPA.

Obligation 9 – Openness

We have clearly expressed policies and practices on our management of Personal Data. These policies are set out in this Privacy Policy and in our Personal Information Collection Statement, which we make available to anyone who requests it.

If you would like to access a copy of your personal data, correct or update your personal data, or have a complaint or want more information about how SHPLT manages your personal data, please contact info@purenex.com.

Notice to Customers Relating to the Processing of Personal Data for Direct Marketing Purposes

This Statement is intended to notify you why Personal Data is collected and how it may be used to send you marketing and/or promotional messages.

Marketing messages are messages sent to individuals with the intention of advertising; promoting or offering to provide goods or services; interests in land; business or investment opportunities or advertising; or promoting the supplier or provider of the aforesaid. These changes generally do not affect our sending of other types of messages via your Malaysia telephone number(s), such as informational and service related messages, messages that are for business to business marketing, market survey/research or which promote charitable or religious causes, and personal messages sent by individuals.

Use of Data in Direct Marketing

SHPLT aims to comply with the requirements of the PDPA and respects your choices.

If you have previously consented to our sending you of promotional and/or marketing messages via your telephone number, we will continue to do so until you withdraw your consent.

Examples of the Personal Data which SHPLT may collect, use and/or disclose in order to send you marketing and/or promotional messages about our products and services which may be of interest and relevance to you include (non-exhaustive list): your name, contact details, transaction patterns and behaviour, and demographic data.

Depending on the product or service concerned, your Personal Data may be disclosed to: SHPLT group companies; third party financial institutions, insurers, credit card companies, telemarketing companies, securities and investment services providers; service providers who have been contracted by SHPLT to provide SHPLT with administrative, financial, research, professional or other services; anyone authorised by you, as specified by you.

At any time, you may opt out of receiving marketing communications from us by contacting us or by using any opt-out facilities provided in our marketing communications and we will ensure that your name is removed from our mailing list.

July 2020