The Personal Data Protection Act (“PDPA”) governs the collection, storage, use and disclosure of personal data in Singapore. The provision of your personal data is voluntary, However, if you choose not to provide us with any requested data, such failure may inhibit our ability to provide services to you or affect the quality of the services we provide to you.
Data will be collected from you in the following manner:
When there is usage of our Platform to use our services, access to our online services or to our website or use of our mobile application services;
When User Content is submitted to us;
When you submit your enquiries, or issue instructions or make any requests or updates to your account with us or requests for changes to your account;
When you interact or communicate with our agents, our personnel, or customer service officers whether by telephone, email, face to face meeting, SMS messages, fax, by letter or otherwise;
When we receive referrals and collect or share personal data from within our group of related or affiliated businesses and/or companies and third party providers of services to us or to other members of our group of related or affiliated businesses and/or companies;
When we seek information from third parties who hold personal data concerning your goodself, including your medical, healthcare, legal, banking, accounting professionals ;
When you submit personal data to us during the course of your participation in any marketing promotional or advertising event organised or hosted by us or our related or affiliated businesses and/or companies; and
When you respond to our approaches or promotions.
Type of Information Collected Personal Information
When you create an Account with us through the Platform, we may ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). We collect Personal Information including your name, phone number, address, email address, password, date of birth and identification numbers for us to contact you and also for our recording purposes. We may also require you to provide us with some additional information such as profile picture or other useful identifying information. If you permit us to access the address book on your device through permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate interactions through our Services and for other purposes.
We may enable you to log into your account with us through certain third party social networking sites (“SNS”) (including LinkedIn and Facebook) via the Website and/or the Applications. If you decide to create your account by logging into a SNS, we may extract the Personal Information you have provided to the SNS (such as your “real” name, email address and other information you make publicly available via the SNS) from the account you have with such SNS and use that information to create your account with us; the information we extract may depend on the privacy settings you have with the SNS.
We also collect the other information that you provide as part of registration and the administration and personalisation of your profile on the Platform (which may include your age, gender and individual preferences) (“Non-Identifying Information”).
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the services you have requested through the Platform, complete your transactions, and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).
We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users of the Platform to attempt to provide you with a better experience, to improve the quality and value of the services provided to you and to analyse and understand how the Platform and the services provided through the Platform are used.
When you visit the Platform, we may automatically record information that your browser sends whenever you visit a website or use the applications (“Analytics Data”). This Analytics Data may include information such as your Internet Protocol address, the browser type or the webpage you were visiting before you came to the Platform, pages of the Platform that you visit, the time spent on those pages, information you search for on the Platform, access times and dates, and other statistics. We may use this information to monitor and analyse use of the Platform and the services provided through the Platform, for the purpose of administration of the Platform, to increase the Platform’s functionality and user-friendliness, and to better tailor the Platform to our visitors’ needs.
We do not treat Analytics Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyse and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
In addition to Analytics Data, we may also collect information about the device you are using to access the Platform, including what type of device it is, what operating system you’re using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider
When you use our services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may provide us with information on nearby devices, Wi-Fi access points and cell towers. We collect your precise location data for us to determine the exact location of the accident. If you are using web browsers, we may also collect the precise location of your device.
Like many websites and applications, the Platform uses “cookies” to collect information. A cookie is a small data file that we transfer to your computer or mobile device’s hard disk for record-keeping purposes.
Third party advertisers on the Platform may also place or read cookies on your browser. You can adjust your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Platform.
When you provide us with photos, videos or information about accidents such as the address of accident scene, how did the accident happen, the name of the involving parties and the like information, we will need to collect the information which you have provided to us for storage in our data bank, and processing purposes.
We will need to collect images and other information from your device’s camera and photos. For example, you may not be able to send pictures or videos or upload pictures or videos from your camera roll unless we can access your camera or photos.
How Information Will Be Used and Shared
When you create your account on the Platform and submit your Personal Information and Non-Identifying Information to do so, we use your Personal Information and Non-Identifying Information mainly to provide the services you have requested, to communicate with you and to administer your inquiries. We will create an account for you to use the Platform based upon the Personal Information and Non-Identifying Information you provide.
We may share the information in your account (including your Personal Information) with the SNSs that you have linked to your account. These third parties have access to your Personal Information only for this purpose (unless the SNS has received your Personal Information independently of the Service) and are obligated not to disclose or use it for any other purpose.
We may also use your Personal Information and Non-Identifying Information for data sharing and information within our Company, our affiliates and related business companies and partners who provide administrative, professional advisory or other support services to us.
We only disclose your Personal Information and only such specific parts of it and only to such persons e.g. accident victims as you expressly authorise us in writing to do so.
We may use information we have collected from cookies and other technology to enhance the services and your experience with them.
We may share and disclose Non-Identifying Information and Analytics Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
We may employ third party companies and individuals to facilitate the services available through the Platform, to provide such services, to perform Website and Application-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website and Application’s features) or to assist us in analysing how the Platform is used. These third parties may have access to your Personal Information, Non-Identifying Information and Analytics Data but only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may allow users to automatically post recent activity back to Facebook, and give them the option to disable Facebook Connect at any time by logging into their profile and selecting the option to disable Facebook Connect. Further, you may be able to edit your privacy settings for the content that you post which appears on Facebook by making selections in your “Edit Profile” settings on the Platform.
Device Information, Location Information and User Content are collected, stored in our data bank and processed by us for any information or evidence or for tracking of any witnesses regarding the circumstances in which an accident has occurred and to match them to the accident victim or User who needs the same.
We may share User Content submitted to us by Providers such as photographs, sketch plans, pictures and videos with all the Users of the Platform as well as the general public in order to obtain more information or evidence or for tracking of any witnesses regarding an accident
We may cooperate with government and law enforcement officials and private parties to enforce and comply with any laws to which we and/or you may be subject. We may, in our sole discretion, disclose any information about you to government or law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process, to protect our property (including intellectual property) and rights or a third party, to prevent, detect and investigate any crime, including fraud and any form of financial crime, analysing and managing of any financial risks, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Limited Disclosure to Third Parties
Personal Data is only otherwise disclosed to the following third parties:
Our Company’s affiliated companies;
Operators of payment systems such as Network for Electronic Transfers (Singapore) Pte Ltd, banks, financial institutions, credit card companies and their respective service providers;
Our financial or legal advisers or other professional advisers for the purposes of obtaining financial, or accounting, legal or other professional advice and services in relation to our business operations;
Governmental agencies or regulatory agencies or authorities for legal compliance purposes;
Any liquidator, receiver, official assignee / trustee, judicial manager under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other like process; and
Any third party company or business with whom we have a business relationship and who provide us with administrative or other support services such as telecommunications, call centre, mailing, information technology, payment, payroll, data processing training, marketing research, storage and archival services or who are our sub-contractors, advisers, assistants or agents [whether on paid or voluntary basis] tasked with performing all or part of the services we have contracted to provide to you.
Save for Governmental agencies or regulatory agencies or authorities, your personal data is disclosed only to such of the above mentioned third parties as have entered into an express or implied Confidentiality Agreement with us to preserve the confidentiality of your personal data and on a “need to know” basis and for the purposes we have set out above.
Changing or Deleting Your Information
Any user of the Platform may review, update, correct or delete his or her Personal Information in their account by contacting us or by editing such profile via the Website and/or the Applications. If you completely delete all such information, your account may become deactivated. We will use commercially reasonable efforts to honour any requests you may have to delete or change your information.
However, FindWitness, its affiliates, or its service providers may retain an archived copy of your records including Personal Information or User Content provided by you as a Provider as required by any law to which you and/or we may be subject, or for backup, archival, audit or other legitimate business purposes for a commercially reasonable time.
We may make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in any applicable legislation on security breach notification) to you via email, SNS or conspicuous posting on the Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with
the legitimate needs of any governmental or law enforcement agencies; or
any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Your information collected through the Service may be stored and processed in any country in which FindWitness, its affiliates or service providers maintain facilities.
FindWitness, its affiliates, or service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, FindWitness cannot ensure the security of any information you transmit to FindWitness or guarantee that information submitted through the Platform may not be accessed, disclosed, altered, or destroyed.
Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and FindWitness, at all times. Your privacy settings may also be affected by changes the social media services you connect to FindWitness make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
Links to Other Websites
The Website and/or the Application may contain links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website.
The fact that the Platform provides links to a website or presents a banner ad or other type of advertisement is not an endorsement, authorisation or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites.
These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
No Trading In Personal Information
Save as provided herein, we do not disclose any Personal Information to any other third party unless we are required by law or by an Order of Court. In addition, we only permit authorized employees, who are trained in the proper handling of Personal Information to have access to such information and on a “need to know” basis.
n the event of an assignment or transfer of our ownership of the Platform to an assignee or transferee, your personal information will be part of the assets of the Platform and subject to such assignment or transfer.
Save as provided herein, we do not trade or sell your Personal Information to anyone under any circumstances.