PRIVACY POLICY

Protecting your personal information is extremely important to us at Invai (‘Invai Ai Trading Algorithms’). It’s especially important for a large financial company like ours, as our customers trust us to look after a huge amount of sensitive information on everything from their business affairs to their medical history.

The way we collect, use, store and share your information is equally important. Our customers expect us to manage their information privately and securely. If we don’t, they'll lose their trust in us.

This policy tells you how we collect and process your personal information. Please take a few minutes to read it and show it to anyone else connected to your product or whose data you have shared with us. This policy may be subject to future change.

Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.

What does this policy cover?

This privacy policy relates to retail customers and/or any individual consumers of our goods and/or services, including users of our application based technology and those individuals who request financial advice, obtain quotes, utilise our services, purchase our products, enter into agreements with us, individuals that we cover under employer sponsored schemes and/or individuals that we may otherwise interact with us in the course of our business. We have a ol privacy policy for professional business clients, which can be found on our website.

What is personal information?

When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. It can relate to customers (including prospective customers), their appointed representatives (e.g. powers of attorney), employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.

Where do we get our information from?

Directly from you - information you provide when you fill in forms or contact us by phone, email etc. We may record phone calls for our mutual protection and to improve our customer service standarts.

Information we collect about you or receive from other sources. This could be information you provide to us electronically (through our website or an online portal, for example), information we get from your online browsing activity, information from a third party (or from publicly available sources such as social media platforms or the electoral register (e.g. to detect fraudulent claims). We may also receive information if you have been dealing with a financial adviser or broker, or have been introduced to us by another company (e.g. a bank, insurer, building society, your employer or their financial adviser).

We use cookies and similar technologies to support the functioning of our websites and applications. This includes allowing you to browse between pages effectively, recording and storing your preferences and generally improving your online experience. They can also help to ensure that adverts you see online are more relevant to you. You can find more information about setting your cookie preferences by using the ‘Cookie Policy’ link of our websites.

How do we use your information?

  • We use personal information that we hold about you: 
  • To carry out our responsibilities resulting from any agreements you've entered into with us (e.g. to provide financial advice, underwrite and administer your products, including processing claims, checking for false or inaccurate information against previous Invai Ai Trading Algorithms product applications) and to provide you with the information, products and services that you've asked from us (e.g. about the company's investment products).
  • To provide you with marketing information about services and products we offer across the Invai Ai Trading Algorithms group which may be of interest to you. If you have opted in to receive marketing from us, based on your marketing preferences we may deliver this information by post, telephone, e-mail, SMS or personalised online marketing via our own systems such as My Account, social media platforms and/or other third party websites e.g. YouTube. Please note that if you choose not to receive online marketing, you will not see personalised messages using your personal data, however you may still see generic online advertising about our products and services. We will not sell your data to third parties for them to market to you. We may also send marketing to you using our “legitimate interests”, please see below for further information.
  • To tell you about changes to our services and products.
  • To comply with any applicable legal or regulatory requirements (including «know your customer» checks, or to comply with any applicable regulatory reporting or disclosure requirements).
  • For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify financial attitudes, find new audiences with similar attributes and develop more engaging communications). This may also include sharing your personal information with our third-party platform and media suppliers to prevent you seeing adverts for products you already have with us.
  • To define our actuarial, pricing and underwriting strategies.
  • To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
  • For any other purpose that we've agreed with you from time to time.
  • When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the uses described in this document.
  • In some cases, we may use software or systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:
  •  The prevention and detection of fraud and financial crime
  • To perform transaction monitoring, identity verification, money laundering and sanctions checks, and to identify politically exposed individuals. We are required by law to perform these activities which may be achieved using solely automated means to make decisions about you or any individual related to your products or application. We may use these activities to decline the services you have requested or to stop providing existing services to you.
  •  Providing quotes, calculating premiums and underwriting decisions
  • We may evaluate a number of factors, including information about you and your health, lifestyle information such as your zip code, occupation, and hazardous activities you perform. These factors will be assessed against our pricing criteria and underwriting company, which may include life expectancy, disease, injury, and demographic risk statistics. For general insurance, factors may include your claims history, where you live, and the value of your investment products that you wish to insure. We may use these actions to insure your Invai Ai Trading Algorithms investment products.
  • The provision of financial advice and recommendations
  • We may perform computer- based assessments with your personal and financial information in order to produce your financial advice recommendations. These activities are not solely based on automated processing and our qualified financial advisers will always validate the outcome to ensure that the decisions are suitable based on the information that you have provided.
  •  Speech Analytics
  • We may use speech analytics on recorded phone calls to help us meet our regulatory obligations e.g. identify vulnerable customers, complaints, staff training needs, process and product development, quality control and audit. These profiling activities are not solely based on automated processing. The results are manually reviewed to decide if we need to take further action.
  •  Servicing activities such as (i) Personalising the content and design of communications and online services (e.g. My Account) and (ii) Determining when to provide tailored communications about your Invai Ai Trading Algorithms products (e.g. as a result of changes in your personal circumstances or lifestyle) and the appropriate channels to use
    These may be achieved using profiling in order to predict certain characteristics about you (e.g. your economic situation, interests, personal preferences or transactional behaviour). The activities will not have a detrimental effect on you.

    Using your information in accordance with data protection laws
  • Data protection laws require us to meet certain conditions before we're allowed to use your personal information in the way we describe in this privacy policy. We take these responsibilities extremely seriously. To use your personal information, we'll rely on the following conditions, depending on the activities we're carrying out:
  •  Providing our contracts & services to you: We'll process your personal information to carry out our responsibilities resulting from any agreements you’ ve entered into with us and to provide you with the information, products and services you've asked from us, which may include online services.
  •  Complying with applicable laws: We may process your personal information to comply with any legal obligation we're subject to.
  •  Legitimate interests: To use your personal data for any other purpose described in this privacy policy, we'll rely on a condition known as “legitimate interests”. It's in our legitimate interests to collect your personal data as it provides us with the information that we need to provide our services to you more effectively.

We may use your information to:

  • Carry out market research and product development, which can include creating customer demographics and/or profiling.
  • Send marketing information, via post only, to customers who have a relevant and appropriate relationship with Invai Ai Trading Algorithms.
  • Develop and test the effectiveness of marketing activities.
  • Develop, test and manage our brands, products and services.
  • Study and also manage how our customers use products and services from us and our business partners, including customer surveys.
  • Manage risk for us and our customers.

This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.

The outcome of this assessment will determine whether we can use your personal data in the ways described in this privacy policy (except in relation to marketing, where we'll always rely on your consent). We'll always act reasonably and give full and proper consideration to your interests in carrying out this assessment.

  •  Consent: We may provide you with marketing information about our services or products where you've provided your consent for us to do so. You may opt out of marketing at any time by e-mailing or texting your customer services team. You can also manage your marketing preferences on our customer self-service systems, My Account.
  •  Special category (sensitive) data: Where you have consented, we will process any medical & health, racial & ethnic origin, genetic & biometric or sex life & sexual orientation information you have provided, and any other sensitive information obtained from a third party (e.g. your GP or other medical professional), for the purposes of allowing us to underwrite and administer new and existing products, provide other services (e.g. financial advice) and deal with claims.

    • Alternatively, we may process special category data for reasons of substantial public interest in accordance with applicable law. We will only process data that is needed for specific purposes.

  •  Criminal Conviction Data: Where you have consented, we will process this type of information solely for the purposes of allowing us to underwrite and administer your products and deal with claims.

Please be aware that the personal information that you provide to us and that we collect about you is necessary in order for us to provide our services to you, and without it we will not be able to do so.

How long do we keep your information for?

We will store your personal information in accordance with our internal retention policy. We will determine the period of time for which we will retain it based on the minimum retention periods required by law or regulation. We will retain your personal information after this period only if there is a legitimate and provable business reason for doing so.

With respect to investment products, we may retain your personal information indefinitely using a legitimate interest condition to support future requests from you, your family or financial advisor, and our regulators.

For certain research and statistical activities, we may indefinitely retain minimized personal information about you, including medical information, solely to determine our actuarial, underwriting and pricing risk management strategies. These actions will hot be used to decide or take action against you.

Who do we share your personal information with?

We'll only disclose your information to:

  • Other companies within the Invai Ai Trading Algorithms Group, third-party suppliers, media suppliers, contractors and service providers for the purposes listed under “How do we use your information” above.
  • Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
  • Our regulators, government agencies, law enforcement agencies, credit reference agencies, data verification and tracing agencies, fraud prevention agencies, reinsurers, as well as our IN professional advisers etc.
  • Additionally, we may disclose your personal information to third parties:
  • If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
  • If you have been dealing with a financial adviser, we'll provide information about your products and, where appropriate, with other information about your dealings with us, to enable the adviser to give you informed advice.
  • In order to enforce or apply the terms of any contract with you.
  • If we're under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
  • To protect you and Invai Ai Trading Algorithms from financial crime, Invai Ai Trading Algorithms may be required to verify the identity of new and sometimes existing customers. This may be achieved by using credit reference agencies to search sources of information relating to you (an identity search). This will not affect your investment rating. If this fails, Invai Ai Trading Algorithms may need to approach you to obtain documentary evidence of identity.
  • If you make a claim, we'll share your information (where necessary) with other insurance companies to prevent fraudulent claims.

    Additionally, your information, including special category and criminal conviction data, may be disclosed to our reinsurers and to any other insurance company to whom you apply for products or services.

    If you've been introduced to us by another, we may share your information with them to enable them to:

  • Administer and service your products.
  • Carry out market research, statistical analysis and customer profiling.
  • Where you have consented, send you marketing information by post, telephone, e-mail and SMS about their products and those of carefully selected third parties.
  • Assist you with your application process (aggregator and price comparison websites only).

Fraud prevention

The personal information Invai Ai Trading Algorithms collects from you may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity.

If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We may also share information about you with other organizations and public bodies, including the police and we may check and/or file your details with fraud prevention agencies and databases.

If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies can be found by accessing these links:

CIFAS

Invai Ai Trading Algorithms also accesses this information and uses it to prevent fraud and money laundering, such as when:

  • Checking details on applications for credit and credit related or other facilities.
  • Managing credit and credit related accounts or facilities.
  • Checking details on proposals and claims for all types of investments.
  • Checking details of job applicants and employees.
  • Checking sources of income and tax details.

Invai Ai Trading Algorithms and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Invai Ai Trading Algorithms may also check the details of other parties related to your contract, including verification of identity. This includes beneficiaries, trustees, settlors, third party premium payers, executors or administrators of your estate, parties with power of attorney and any other beneficial owner.

Deposit insurance only: claims history

Under the terms of your product, you must report all insurance-related incidents to us, whether or not they are the cause of a claim. When you report an incident to us, we transfer information about it to a database.

We may search these databases when you apply for insurance, in the event of any incident or claim, or during renewal, to check your claim history that may be related to a product or claim.

Protecting your data outside the Singapore

The data that we collect from you may be transferred to, and stored at, a destination outside the Singapore to third-party suppliers, delegates or agents. We'll take all reasonably necessary steps to make sure that your data is treated securely and in accordance with this privacy policy, to ensure your personal information is handled with the same protections that we apply ourselves.

Your rights

You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner's website. If you wish to exercise any of these rights, please get in touch with your customer services team.

By contacting us you can use the following rights:

  • the right to delete your Personal Data;
  • the right to change or correct your Personal Data, in particular when it is incorrectly stated;
  • the right to object or restrict processing of your Personal Data;
  • the right to access to your Personal Data and/or copy of your Personal Data, which you have provided to Invai Ai Trading Algorithms, in a machine-readable format.

In addition, you have the right to prohibit the use of your Data for marketing purposes. Before requesting your Data, we usually request your consent to disclose it to third parties for marketing purposes. You can use the right to prohibit the processing of your You can also exercise this right by contacting us at any time.

Please note that the implementation of some of your rights, depending on the situation, may Limit, complicate or completely exclude the possibility of further cooperation with us.

Our Website may contain active links from/to the websites of our partners, advertisers and Affiliated companies. If you are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing your Personal Data with them.

Contacts and complaints

If you have any questions about this privacy policy or wish to exercise any of your rights, including changing your marketing preferences, please get in touch with your usual  contact or your customer services team.