AIG On the Go - User Privacy Statement
Effective Date: 22nd October 2021
Scope and Application
AIG Asia Pacific Insurance Pte. Ltd. (“AIG Singapore”, “we”, “us”) collects, uses, discloses and holds information about you when you sign up for and use the AIG On the Go mobile application (“AIG On the Go”) and when, through your use of AIG On the Go or otherwise, you purchase insurance from AIG Singapore or have any communications with AIG Singapore for these purposes.
This User Privacy Statement sets out what and how information is collected, why it is collected, to whom it may be transferred and how you may gain access to/request correction of such information or change your choice with regards to receiving promotional and/or marketing material. It is entirely voluntary for you to provide such information, but there is certain information you must provide a) to access AIG On the Go in the first place; and b) to use all functionalities of AIG On the Go.
By signing up to use AIG On the Go you agree and consent to the information you submit or which is collected through AIG On the Go being collected, processed, used and transferred in the manner identified in this User Privacy Statement.
A feature of AIG On the Go is that you are able to convert your driving score into applicable discounts for your next motor insurance purchase with AIG Singapore. The discount feature of AIG On the Go enables you to see the type of premium discount you may be able to obtain based on your driving score.
What information does AIG On the Go collect?
What information do we ask you to provide directly to us and why?
You will note that we collect your e-mail address, first name and vehicle registration number when you first register for AIG On the Go and ask you to complete certain information in the “Personal Information” section of the app. The reason we ask you to provide certain information is as follows:
· Your e-mail address - When you first download AIG On the Go, we ask you to provide your e-mail address, which we use to generate a password for you. Without you providing this information, you will not be able to start using AIG On the Go. We also use your email address to communicate with you on queries you have on, or to provide you with information in relation to AIG On the Go and other services on AIG On the Go. Further (unless you have exercised your right to “opt out” of receiving promotional material), we may use this to contact you to market our insurance products and services and/or inform or enroll you in contests and other similar promotions.
· Your first name – We collect your first name which will be the name displayed on AIG On the Go with your score which will both be visible to other users of AIG On the Go. You need to provide this in order to use AIG On the Go.
What information does AIG On the Go collect and access when it is in use and why?
When you sign up for AIG On the Go, it is clearly indicated that AIG On the Go requires access to certain information. The type of information, the reasons why AIG On the Go requires access to them and the time at which the information is accessed are set out below:
· Location Information – AIG On the Go functions by collecting precise location data about your trip when you drive. This is to enable AIG On the Go to detect your acceleration, cornering, speed, braking and other measurements which make for safe driving. It is therefore necessary for permission to be given through the permission system of your mobile operating system for AIG On the Go to be used for its main purpose of assessing your performance as a driver. The On the Go app continues to collect your location data (GPS location) while it is running in the background. This enables the On the Go app to collect the relevant information necessary for the app to function as intended while you use other apps such as navigation apps or where you are not actively using your mobile phone. On the Go automatically recognizes driving behaviour: location (GPS sensor) is used while you are not driving to indicate movement of your mobile phone. The movement, if greater than a preset distance, is one of the indicators that a drive has started. The drive is recorded automatically. For these features and the On the Go app to function as intended as described above, you should allow the ‘Always’ Location permission, if requested.
· Sensors Motion Detection – To record the safety measurements of your driving (accelerating, cornering, speed, braking), AIG On the Go needs to access the activity recognition functionality of your mobile phone’s operating system. It is therefore necessary for you to allow such access to AIG On the Go through your mobile operating system in order to assess your safety performance as a driver.
· Network/Wifi states – AIG On the Go collects the location information in real time whilst you are connected via your mobile operator’s network or Wifi. However, if that connection is interrupted, the information is stored locally in your mobile phone until a connection is available. It is therefore necessary for permission to be given for AIG On the Go to access your network or Wifi information through your mobile operating system to obtain the information collected by the app and stored in your mobile phone so that AIG On the Go can assess your driving performance.
· Contacts Information – AIG On the Go provides you with the functionality to invite friends in your contacts list to register for AIG On the Go. If you wish to do this, however, it is necessary for you to permit access to the address book on your device through the permission system used by your mobile phone platform. We will only use such information if you use the “invite friends” function.
What information may be collected from other sources?
A feature of AIG On the Go enables you to share your score and other information on your social media sites. Your use of this feature will enable the sharing of information with your friends or the public, depending on the privacy settings you set within your social media service. Please check the privacy policies of your social media service for information on your privacy settings.
Important information about platform permissions
Most mobile platforms have defined certain types of device data that apps cannot access without your permission and platforms provide different permission systems for gaining your consent. The iOS platform alerts you the first time AIG On the Go wants access to a particular function (usually the first time you use that function) and asks you to give permission for that function to be used at that point. Android devices will notify you of all the permissions AIG On the Go may need for all functions when you first register for the app and your use of the app constitutes your consent. The above explanations, we hope, gives you details of the functionalities which AIG On the Go needs access to, why and when it will use them.
How do we use your information?
In addition to the reasons set out above, we may also use your information for the following purposes:
· Identification and registration - We may use your information to register you as a user and to manage your account, and to identify you to us and to others (such as to other users of AIG On the Go).
· Communications - We may use your information to communicate with you as part of our business. This includes communications related to new features, promotions or reminders about activities which are available on AIG On the Go. We may also use your information to communicate with you about AIG On the Go, such as to answer your queries or send notifications about AIG On the Go (for example, if we need to suspend AIG On the Go for maintenance).
· Providing our services - We may use your information to provide the features and functionality available on AIG On the Go, performing background updates, and detecting cyber vulnerabilities.
· Marketing and promotional activities - We may use your information to provide advertising and marketing information to you, including marketing our (or our affiliates’) products and services. We may also use your information to enroll you in contests and other similar promotions.
· Personalizing your experience - We may use your information to personalize AIG On the Go to meet your needs and preferences, such as providing information and recommendations which are tailored to you.
· Monitoring and analysis – We may use your information to monitor and analyze user activity, including for statistical analysis, quality control and improvement purposes.
Which third parties we may share your data with?
We may disclose to or share your information to third parties as follows:
· Affiliates – AIG Singapore is part of the American International Group, Inc. (“AIG Inc.") group of companies. AIG Inc. has group companies throughout the world. We may may the information collected through AIG On the Go with other group companies for the purposes set out in this Privacy Statement.
· Service providers – Information collected through AIG On the Go is stored on servers or cloud servers run by AIG affiliates or third party cloud hosting providers. On-going application support for AIG On the Go is provided by third party software service providers with whom AIG Singapore contracts, who in providing such support requires access to the data collected through AIG On the Go. We may also share your information with other service providers including agents, brokers, auditors, lawyers, banks, financial institutions and other professional advisors, as well as advertising, marketing, research and analysis service providers and any other service providers which help us carry out our business.
· Transactions – We may share your information with purchasers and prospective purchasers or other parties in connection with any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.
· Government authorities and law enforcement – We may share your information with government authorities and/or law enforcement agencies, or with our lawyers and other advisors in connection with requests from such authorities or enforcement agencies, where required or authorized by applicable laws or other guidelines or codes of practice issued by regulatory authorities or in connection with legal proceedings.
Where your information may be processed or transferred?
Due to the global nature of our business activities, for the above AIG affiliates or third parties to have access to your information, data collected through AIG On the Go may be transferred to places outside of Singapore (where the cloud data centres and AIG data centres are based and where the service providers are based) for the purposes set out above. The countries/jurisdictions to which personal data may be transferred by AIG Singapore include, without limitation,
· the United States of America, Australia, Malaysia, the Philippines; India, Canada, United Kingdom, and European Union.
These countries may have data protection regimes and standards which are different or not equivalent to those in Singapore. When making these transfers, we will take steps to reasonably protect your information in accordance with the requirements of data protection law. This is typically done through data transfer agreements.
Request for account deletion
You may request to delete your On the Go account by writing to email@example.com and indicate your email address or vehicle registration number used in your On the Go account. Once the account is deleted, your email address, name, vehicle registration number and its associated trips recorded will be removed.
Can you Opt- out?
Opt- out for Promotional Communications
We will use your e-mail address to contact you from time to time about our insurance products which may be of interest to you. You may opt out of receiving such promotional messages from us at any time by sending SMS to 76161 in the following format “optoutNRIC/FIN number” or call us at +65 6419 3000. Alternatively, you can opt out via our website at this link.
Upon receipt of any opt-out request from you, AIG Singapore will, at no cost to you, act on your request and ensure that your personal data will not be used as indicated in your request.
Changes to this User Privacy Statement
We reserve the right to make changes to this User Privacy Statement at any time. We will publish the updates on AIG On the Go and/or our website. Please refer to the “Last Updated" date at the top of this User Privacy Statement to see when it was last updated. You agree that it is your responsibility to review this User Privacy Statement regularly for any updates, and that your continued use of AIG On the Go constitutes your acceptance to this User Privacy Statement and any of its amendments.
If you have any questions regarding this User Privacy Statement, please contact us at firstname.lastname@example.org.