1. Introduction and Scope
AXIS LINK PTE. LTD. ("AXIS LINK", "we", "our", "us") is a company
incorporated in Singapore and registered with the Monetary Authority
of Singapore (MAS) as an insurance intermediary. We are committed to
safeguarding the privacy and personal data of our clients, website
visitors, business contacts, and all individuals whose data we
process.
This Privacy Policy explains how we collect, use, disclose, retain,
and protect personal data in compliance with the Personal Data
Protection Act 2012 (PDPA) of Singapore and its associated
regulations and advisory guidelines issued by the Personal Data
Protection Commission (PDPC).
This Policy applies to all personal data processed by AXIS LINK in
connection with our insurance brokerage and financial planning
services, our website at axislinkpte.com, and all related digital
and physical communications. By engaging our services or submitting
personal data via our website, you consent to the practices
described in this Policy unless consent is withdrawn in accordance
with Section 9 below.
2. Definitions
For the purposes of this Policy, the following terms have the
meanings set out below:
-
Personal Data — any data about an individual who
can be identified from that data, or from that data combined with
other information we have access to.
-
Processing — any operation performed on personal
data, including collection, recording, organisation, storage,
adaptation, retrieval, use, disclosure, or erasure.
-
Data Subject — the individual to whom the
personal data relates.
-
Insurer — any licensed general insurer or life
insurer with whom AXIS LINK places or arranges insurance on behalf
of clients.
-
Third Party — any entity other than AXIS LINK and
the data subject.
3. Categories of Personal Data We Collect
Depending on the service you require, we may collect and process the
following categories of personal data:
3.1 Identity and Contact Data
- Full legal name, NRIC/FIN number, passport number
- Date of birth, gender, nationality
- Residential and mailing address
- Email address, telephone and mobile numbers
3.2 Financial and Employment Data
- Occupation, employer name, employment status
- Annual income and gross monthly earnings
- Existing financial products and insurance holdings
-
Bank account details (where required for premium payments or claim
settlements)
-
CPF account information (where relevant to financial planning
advice)
3.3 Insurance-Specific Data
-
Vehicle registration numbers, make, model, and year of manufacture
- Property address, type, and valuation
- Claims history and no-claims discount (NCD) records
-
Health declarations and medical history (for health and
life-related products)
-
Travel itinerary and passport details (for travel insurance)
-
Business registration details, revenue, and employee headcount
(for commercial insurance)
3.4 Technical and Usage Data
- IP address, browser type and version, device identifiers
- Pages visited, time spent on the Site, referring URLs
-
Cookie and tracking technology data (see our
Cookie Policy)
4. How We Collect Personal Data
We collect personal data through the following channels:
-
Directly from you — via enquiry forms, telephone
calls, email correspondence, office visits, or during the policy
quotation and application process.
-
From insurers and intermediaries — where a policy
is transferred to us from another broker, or where an insurer
shares relevant data as part of an underwriting or claims process.
-
From publicly available sources — such as the
Accounting and Corporate Regulatory Authority (ACRA) for business
information, or other public registers.
-
Through our website — via contact forms, chat
tools, cookies, and analytics services.
5. Purposes of Collection and Use
We collect and use personal data for the following purposes:
-
Providing insurance quotations and arranging insurance policies on
your behalf
-
Submitting applications to insurers and managing policy
documentation
-
Conducting identity verification and anti-money laundering (AML)
checks as required by MAS
- Processing premium payments and reconciling accounts
-
Assisting with insurance claims — preparation, submission, and
follow-up
-
Managing policy renewals and providing proactive coverage reviews
- Providing financial planning advice and recommendations
- Complying with legal, regulatory, and reporting obligations
- Maintaining internal business records and audit trails
-
Sending service-related communications (policy documents, renewal
reminders)
-
Sending marketing communications about relevant products and
services (with your consent)
-
Improving the functionality, content, and user experience of our
website
- Responding to enquiries, complaints, and feedback
6. Legal Basis for Processing
We process personal data on one or more of the following lawful
bases under the PDPA:
-
Consent — where you have given explicit consent
for a specific purpose, including marketing communications.
-
Contractual necessity — where processing is
necessary to perform a contract with you (e.g., arranging and
administering your insurance).
-
Legal obligation — where we are required by
Singapore law or MAS regulation to process your data.
-
Legitimate interests — where processing is
necessary for our legitimate business interests, such as fraud
prevention, business analytics, and service improvement, provided
these interests are not overridden by your rights.
7. Disclosure of Personal Data
We may disclose your personal data to the following categories of
recipients for the purposes described in Section 5:
-
Insurers — to obtain quotations, underwrite
policies, and process claims.
-
Reinsurers — where an insurer passes risk to a
reinsurer as part of their risk management.
-
Loss adjusters and claims investigators — during
the assessment and settlement of claims.
-
Credit reference agencies and fraud prevention bodies
— to verify identity and prevent financial crime.
-
MAS, the PDPC, and other regulatory authorities —
where required by law or regulatory direction.
-
Law enforcement agencies — where required by
court order or statutory obligation.
-
Professional advisors — lawyers, auditors, and
accountants acting under strict confidentiality obligations.
-
Technology and service providers — IT systems,
cloud storage, and CRM providers operating under data processing
agreements that ensure PDPA compliance.
We do not sell, rent, or trade personal data to third parties for
marketing purposes. Any data sharing is limited to what is necessary
for the stated purpose.
8. International Data Transfers
Some of our insurer partners and technology service providers
operate or store data outside Singapore. Where personal data is
transferred to countries that do not have equivalent data protection
standards to Singapore, we take appropriate measures to ensure
adequate protection, including contractual safeguards and data
processing agreements that impose PDPA-equivalent obligations on
recipients.
9. Data Retention
We retain personal data only for as long as necessary to fulfil the
purposes for which it was collected, including to satisfy any legal,
contractual, or regulatory requirements. The following minimum
retention periods apply:
| Data Category |
Retention Period |
Basis |
| Policy documents and correspondence |
7 years from policy expiry |
MAS regulatory requirement |
| Claims records |
7 years from claim settlement |
Legal and regulatory |
| Financial planning records |
6 years from last advice |
FAA / MAS guidelines |
| Identity verification records |
5 years after business relationship ends |
AML/CFT obligations |
| Website enquiry data |
2 years from last contact |
Legitimate interest |
| Marketing consent records |
Until consent withdrawn + 1 year |
PDPA compliance |
At the end of the applicable retention period, personal data is
securely deleted or anonymised in a manner that prevents recovery.
10. Your Rights Under the PDPA
As a data subject, you have the following rights under the PDPA:
-
Right of access — to request a copy of the
personal data we hold about you and information about how it is
used.
-
Right of correction — to request correction of
inaccurate or incomplete personal data.
-
Right to withdraw consent — to withdraw consent
for any processing based on consent, without affecting the
lawfulness of processing carried out before withdrawal.
-
Right to data portability — to request that we
provide your personal data in a machine-readable format where
technically feasible.
To exercise any of these rights, contact our Data Protection Officer
at
support@axislinkpte.com
or in writing to our registered office. We will respond within 30
days of receiving your request. We may require proof of identity
before processing your request.
11. Data Security
We implement a range of technical and organisational security
measures to protect personal data against unauthorised access, loss,
alteration, disclosure, or destruction. These include:
-
TLS/SSL encryption for all data transmitted via our website and
email systems
-
Role-based access controls limiting data access to authorised
personnel only
-
Regular staff training on data protection obligations and security
practices
- Secure physical document handling and disposal protocols
-
Periodic security reviews and vulnerability assessments of our
digital systems
-
Incident response procedures for detecting and responding to
personal data breaches
In the event of a data breach that poses a significant risk of harm,
we will notify the PDPC and affected individuals in accordance with
the Mandatory Data Breach Notification requirements under the PDPA.
12. Cookies
Our website uses cookies and similar tracking technologies. Please
refer to our Cookie Policy for a
full explanation of the types of cookies we use, their purposes, and
how to manage your cookie preferences.
13. Children's Privacy
Our services are intended for individuals aged 18 and above. We do
not knowingly collect personal data from children under 18 without
the consent of a parent or legal guardian. If we become aware that
personal data has been collected from a child without appropriate
consent, we will take steps to delete that information promptly.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect
changes in our practices, technology, legal requirements, or
regulatory guidance. The version number and effective date at the
top of this page will be updated accordingly. Material changes will
be communicated to you by email or via a prominent notice on our
website prior to the change taking effect. Your continued use of our
services after the effective date of any update constitutes
acceptance of the revised Policy.
15. Data Protection Officer & Contact
For any queries, complaints, or requests relating to your personal
data or this Privacy Policy, please contact our Data Protection
Officer:
AXIS LINK PTE. LTD.
Data Protection Officer
143 Potong Pasir Avenue 2, #11-16
Singapore 350143
Email:
support@axislinkpte.com
Phone: +65 9340 7012
If you are not satisfied with our response, you may also lodge a
complaint with the Personal Data Protection Commission (PDPC) at
www.pdpc.gov.sg.