We, Capsule Pharma Pte Ltd (“CP”), take the privacy and protection of your personal information seriously.
We have set out below information about our processing of your personal information, what rights you have, and how you can get in touch if you want to know more.
When we say personal information, we mean information about you, such as your name, date of birth and contact details. We collect personal information from you that is necessary for us to either provide you with the product or service you’ve requested or to comply with statutory or contractual requirements. Unfortunately, if you’re unable to provide certain personal information which is necessary for us to provide our products and/or services to you, we will not be able to provide you with those products and/or services.
By submitting your information to us, you agree and consent to CP, and where appropriate our respective representatives, third party service providers, contractors and/or appointed distribution/business partners (collectively referred to as “Capsule Pharma”), collecting, using, disclosing personal data in the manner set forth in the prevailing terms of this Privacy Notice, including any future amendments. You acknowledge and agree that CP may, from time to time, amend and update this Privacy Notice in order to ensure it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements.
Please note that the purposes set forth in this Privacy Notice supplement but do not supersede any other consents you may have previously provided to us or which you may provide to us in the future.
We may change this Privacy Notice from time to time by updating our Privacy Notice page on our website. We encourage you to check our Privacy Notice from time to time on our website, as the version of our Privacy Notice which is displayed on our website takes precedence over all previous versions of our Privacy Notice.
Part A – Personal information we process
Part B – Where we get your personal information
We’ll collect personal information from the following general sources:
We use the following types of cookies:
Part C – How we use your personal information and why
We, CP, Capsule Pharma and our Business Partners, will use the personal information you provide to us, together with other information, for the following purposes:
|Purpose||Legal basis for processing|
|Verifying your identity and any information you provide to us;||Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you.|
|Carrying out your instructions or responding to your queries, complaints, feedback and requests and/or otherwise communicating with you;|
|Communicating with you on updates, terms and conditions and providing administrative information, including for the purposes of servicing in relation to the products and services offered|
|The administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service;|
|Keeping your information on record and carrying out other internal business administration.|
|Processing and dealing with any debt collections and claims (which includes the settlement of claims and any necessary investigations relating to such claims|
|Conducting research, surveys, analysis and development activities in order to improve the products and services we offer to you, as well as to improve the overall customer experience;|
|Telecommunications, information technology, payment, processing and training|
|Storing, hosting, backing up of your personal data (including via clouds storage), and for otherwise managing and ensuring the efficiency and security of our IT environment and business operations;||For managing our relationship with you, including notifying you of our marketing events, initiatives, promotions.|
|Managing the administrative and business operations of the Company and complying with internal policies and procedures;||Our legitimate interests in storing, hosting, backing up of your personal data to maintain and develop our relationship with you.|
|Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;||Compliance with our CP and PCA obligations, and other local regulations.|
|Complying with any legal, regulatory and good governance obligations (which may include responding to requests from public or governmental authorities);||Compliance with our CP and PCA obligations.|
|Conducting audit reviews;||Compliance with our legal obligations.|
|Monitoring and coaching employee and agent for quality assurance||Compliance with our legal obligations.|
|If you have consented – to send you marketing, advertising and promotional information about insurance, investment and/or financial products and/or services that we may be selling or marketing; and||Necessary for the performance of the contract with you and complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority|
|Any other such purpose which may be incidental or ancillary to any of the above purposes||Our legitimate interests in monitoring and coaching employee and agent to upkeep our service quality.|
|Compliance with local regulation.|
If you are an employment applicant / employee / ex-employee:
In addition, CP handles and safeguards your personal data for the purpose of administering and managing your employment with the company. The information collected for the purpose of job application and employment in CP will be utilized by the relevant member(s) of CP to assess and process your application and employment. If you are not successful in your application or have resigned, we may retain your information for business or legal purposes.
If necessary, to administer human capital activities, CP may share information about you with medical practitioners and reinsurers. We will also share information with regulatory and fraud prevention agencies and with third parties who process information on our behalf including those outside Singapore with appropriate controls in place.
Who we share your personal information with and why
We’ll share your personal information within the Capsule Pharma and with our Business Partners, for any of the purposes set out in this Part C. If you have a joint policy or investment, the other person may receive your personal information too.
We may process your personal information in a country other than the one you are resident in. To the extent we transfer your personal data, we will use appropriate safeguards and comply with the laws of the country to which your personal information is transferred. Details of the safeguards we use are available on request.
We work with many external parties in order to provide you with a seamless experience in relation to any products and/or services you have purchased from us. In the ordinary course of business, we may be required to disclose personal data to such external parties and these external parties may be located overseas.
We only disclose your personal data, where appropriate and necessary, for one or more of the above-mentioned Purposes or as permitted by law. The external parties we may disclose your personal data to include, but is not limited to, the following:
Accuracy and protection of personal data
We will take reasonable efforts to ensure that any personal data we have about you is accurate and complete. However, this means that you must also update us of any changes to the personal data that you had initially provided to us in a timely fashion.
We will also take reasonable efforts to protect the personal data in our possession by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or any similar risks.
We keep your personal information for a set amount of time
Your personal information will be stored either for as long as you are our customer, or longer if required by law or as is otherwise necessary. It’ll always be in line with our data retention policy.
Part D – Reference checks
For certain products or services, we may use approved credit reference agencies, tracing companies, financial crime prevention agencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering; this may include checks on your current or previous addresses. Results of these may be recorded for future reference.
These checks may also be carried out for a fund investor, joint policy holder or person(s) that you provide personal information on. Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch.
Any transfer of your personal information will always be done securely.
Part E – We may use your personal information to make automated decisions or profile you
We, CP, Capsule Pharma Corporation Asia, our Business Partners, and our Marketing Partners may use your personal information to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling).
To the extent that we conduct such automated decision-making activity, we’ll provide you with further information at the appropriate time.
Part F – Use of your sensitive personal information
For certain products or services, we’ll need to process your sensitive personal information, such as information relating to health, genetics and biometric identifiers. To the extent that we need your explicit consent to process this kind of personal information in the manner described in Parts C, D, and E, we will provide details of this at the point of collection and seek your consent.
Part G – You’re in control
When it comes to how we use your personal data, you have the right to:
If you currently reside in an EU jurisdiction, additional rights under General Data Protection Regulation (GDPR) may apply. As such, you may:
If you want to exercise your rights, or would like an explanation about these rights, we’ve explained how you can get in touch in the Contact Us section.
If you do need to speak to us, it’ll be useful to have to hand that the data controller2 of your personal data is CP. We may monitor or record calls or any other communication we have with you. This might be for training, for security, or to help us check for quality.
Part H – Acting on someone else’s behalf?
If you give us personal information about another person (or persons), we’ll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:
If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us at the email address below before sending us anything.
Part I – Direct marketing
We CP, Capsule Pharma Group, our Business Partners, and our Marketing Partners will still send you information by post about our and the Capsule Pharma Group’s products and services and carefully selected third parties.
Additionally, from time to time, we CP, Capsule Pharma Group would like to contact you by electronic means with details about products, services and any special offers. We will only do this if you have consented to us contacting you by electronic means.
And if you change your mind, and / or you would like to opt-out of receiving non-electronic direct marketing, it’s easy to let us know through the following channels:
For any further queries, please write to us at the address below or email us at cps<at>capsulepharma<dot>com
If want to exercise your rights in Part G or if you require any other information about any other part of this notice, you can contact us in several different ways.
For customers, contact us at:
Capsule Pharma Pte Ltd, 1 Kaki Bukit Road 1, #02-44 Enterprise One, Singapore 415934. Tel: +65-64812886 or email: cps<at>capsulepharma<dot>com
For employment applicants/ employees/ex-employees, contact us at:
If you wish to contact CP about a Data Protection concern, please write to The Data Privacy Officer at:
The Capsule Pharma Group means Capsule Pharma Pte Ltd and all subsidiaries and affiliated companies
Business Partners means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, and our legal advisers.
Marketing Partners means our service providers, intermediaries (and other stakeholders), scheme advisors, introducers and selected third party service providers.
1We will provide any electronic information (not paper records) that we hold and only that which you provided to us – we will not provide the results of any processing carried out on that data.
2Data Controller – Natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.