Privacy Policy

This Privacy Policy sets out how YAS DIGITAL LIMITED ("YAS", "we", "us," or "our") collect, use and manage your personal data (collectively referred to as “Data”) and how it is shared with insurers ("Insurers") offering insurance on YAS’s mobile applications ("Apps") and websites ("Sites").

When we collect your personal data, our commitment to the protection and privacy of your personal data is a priority. Our Privacy Policy provides details about the management of your personal data including:

• How we collect and hold it;
• Purposes for which we collect, hold, use and disclose it
• How you can access your personal data, seek correction of it

Steps we take to protect your information:

• Your personal data is stored on computer systems which are protected by a combination of firewalls, secure logon processes, encryption and intrusion monitoring technologies.
• We use a recognised payment service provider to process any insurance payments you make using the Apps or the Sites. This service provider is committed to protecting your personal data on our behalf.
• In certain circumstances we will collect and use your IP address to protect the security of our website.
• We regularly test our websites and infrastructure for vulnerabilities and take action where needed.
• We apply security patches to software provided by vendors.
• For any payments you make using our Apps or our Sites, we use a recognised payment service provider to process such payments. This service provider is committed to protecting your personal information on our behalf.

Steps you can take to protect your information.

It's still very important that you take some steps to help keep up security when you're online:

• Protect your personal data, such as usernames and passwords by not allowing anyone to see you entering them, and avoid public Wi-Fi usage.
• Notify us as soon as possible if you become aware of any breaches or hacks into your account.
• Use a strong password for your account. Try to think of something that is easy to remember, but hard to guess, such as a passphrase.
• Change your password regularly and try not to reuse the same password on more than one site.
• Don't let your browser save your password for our websites.
• Be wary of websites, emails or phone calls that claim to be from us. Please contact us if you are unsure.
• Keep an eye on your accounts and check for any unauthorized transactions.
• Keep your devices up to date with firewall enabled, anti-malware software, anti-virus software and security updates.

What information do we collect when you interact with us online?

The personal data we collect from you including but not limited to

• Contact details including name, email, mobile number and billing address
• Login and account information, including password
• Personal details including gender, hometown, date of birth and purchase history
• Payment, credit card information
• Location activity provided by you or generated through YAS MicroInsurance (i.e., geographical location, speed, direction, and time and date of recording.)

Therefore you can use the Apps or the Sites to purchase insurance products from Insurers, access information about the insurance products purchased and make any claims on any insurance products ("Services").

How we collect and use personal data?

Personal data is only collected with your consent on YAS’s Apps and Sites. When we collect Data from you, we provide you with a Personal Information Collection Statement (PICS) during or before collection in the same electronic form that collects the personal data. The Apps will ask you for permission before we have access to your location.

Why and how do we use your personal data?

We will also use your personal data to administer, manage and contact you about your account and our Services; to maintain a profile in relation to you, including but not limited to information regarding any purchases or claims made via the Apps or the Sites; and to provide you with a more personalised experience in relation to our Apps, Sites and Services.

When you use the Apps, we will use your personal data to provide the requested product or service. For example, if you make a purchase on the Apps, we will use the contact information you give us to communicate with you about the purchase. If you contact our customer service, we will use information about you, such as payment information, or the product you have purchased to help you resolve a problem or question.

Another example, if you are using RYDE with YAS on YAS MicroInsurance app to insure your rides, we will collect Data such as geographical location, speed, direction, and time and date of recording. This Data is used to track and insure your ride according to your trip start and end location. In the event of a claim, this Data will be used upon your consent to process your claim submission. Your name, mobile number, and HKID are used solely for identity verification for your insurance policy. Your payment information will be used to send claim benefits to you in the event of a successful claim.

Other purposes of collection including but not limited to performing market research and statistical analysis to improve the Services provided; and responding to your queries and feedback regarding the Apps and the Sites. If you choose to post any comments or reviews regarding any Insurer or insurance products or services via our Apps or our Sites, you understand and agree that such comments or reviews shall be made publicly available, but we will not post your name or any contact details. Please refer to the Personal Information Collection Statement for further information.

We will transfer your personal data to Insurers (who may be located inside or outside the jurisdiction in which you are located), so that the Insurers can:

(a) Process your insurance application;

(b) Arrange a contract of insurance with you and administer the policy issued;

(c) Handle, investigate and analyse claims;

(d) Design products and/or services for customers;

(e) Promote, improve and further the provision of the Insurers' products and/or services; and

(f) Comply with any legal or regulatory requirements applicable to the Insurers.

In order to enable them to carry out the above purposes, the Insurers may transfer your personal data to their parent company, subsidiaries, affiliates or service providers, or any reinsurers, intermediaries (including brokers, and insurance agents), claims investigators, loss adjustors and other professional advisors, insurance industry association or federation and their respective members, or any other person necessary to comply with applicable legal or regulatory requirements, or orders issued by any competent authorities (each of whom may be located inside or outside the jurisdiction in which you are located).

For the purposes set out above, we may also transfer your personal data to our own parent companies, subsidiaries and/or affiliates ("Group"), to any service provider appointed by us or any member of our Group, or any legal or regulatory authority or court of competent jurisdiction (in each case whether located inside or outside the jurisdiction in which you are located).

We will ask for your consent on the use, transfer, disclosure, processing and retention of your personal data pursuant to a Personal Information Collection Statement, which will be provided to you at the time we collect your relevant personal data. We will only transfer your personal data to the Insurer(s) providing insurance products to you.

You must provide us with any personal data we indicate as being mandatory, from time to time. If you do not provide such mandatory personal data then we may not be able to provide the Services to you and/or the Insurers may not be able to provide any insurance products or services or to process any claims. All other personal data that is not indicated as being mandatory can be provided by you voluntarily.

You confirm that if you provide any personal data of other persons(s), they have consented to the provision and use of such data pursuant to the relevant Personal Information Collection Statement provided to you at the time of collection.

Firebase Crashlytics

We use a third-party issue logging service, Firebase Crashlytics to monitor the performance of our app and ease error tracing when required. Currently only your user ID on our system is passed to Firebase Crashlytics for identification purposes, while all personal data is kept within our own systems.

For more information on Firebase Crashlyics’ data handling, please consult the following link: https://firebase.google.com/terms/crashlytics-app-distribution-data-processing-terms.

Stripe

We use a third-party payment gateway, Stripe to offer payment processing. When you make a payment using Stripe, your payment data is forwarded to Stripe via an interface on our app so that the payment can be processed. Stripe may use other personal information such as your phone number and information of installed applications on your device. For details about this process, please consult Stripe’s Data Protection Policy under the following link: https://stripe.com/en-gb-hk/privacy.

Direct Marketing

Subject to your consent, we may use your personal data to send you direct marketing materials regarding our Apps, our Sites, our Services, and insurance products or services offered by any Insurer.

The Insurers may use your personal data for the purposes of direct marketing of insurance products or services and to send you promotional materials or updates of their insurance products or services.

Neither we nor the Insurers may use your personal data for direct marketing if you have indicated your objection to such use or transfer by ticking the relevant box during the registration process.

You may also at any time request that we cease to use your personal data for direct marketing by contacting us via the contact details set out below. If requested by you, we will also notify the Insurers to cease using your personal data for direct marketing, but we are not responsible for the Insurers' failure to do so. You may contact the Insurers directly to request that the Insurer cease using your personal data for direct marketing purposes, via the details and opt-out methods provided by the Insurers.

Where your personal data is stored?

Any personal data we hold about your account (including, but not limited to, your name and phone number) will be stored in our servers which are located in Singapore and Hong Kong. Any personal data collected for purchase of insurance products that are transferred to Insurers are stored by Insurers. Your credit card information will be stored in your mobile device rather than in-App or in our servers.

Use of Provided Information

YAS obtains the information you provide when you use and register the Apps or the Sites. Registration with us is not mandatory. However, please keep in mind that you may not be able to use some of the features offered by the Apps or the Sites unless you are registered with us.

We may use the information you provided us to contact you from time to time to provide you with important information, required notices and marketing promotions.

Information and data collected are used for the followings: monitoring use of the Application and the Website to help for further development; compiling aggregate statistics about our users to analyze usage; communicating with the user in respect of matters related to the use of the services offered; providing information related to YAS’s products, services and other privileges, benefits and advantages from time to time.

Automatically Collected Information

In addition, YAS may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, and information about the way you use YAS.

Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Use of Cookies

Information that is not capable of identifying you, such as the number of users visiting the Apps or the Sites, is collected through code embedded in the webpages of the Apps or the Sites. You cannot disable the code on these pages. Other information, such as browser type, is included in a 'cookie' that is sent to your mobile device when you are completing certain tasks on the Apps or the Sites. A cookie contains bits of information that enables our servers (i.e. the computers that house this Apps or this Sites) to identify and interact efficiently with your device. Cookies are designed to provide a better, more customised website experience, and to make it easier for you to use the Apps or the Sites.

Revisions to this Privacy Policy

As we evolve, we may need to update this Privacy Policy. No matter what we change, we will always maintain our commitment to protecting your privacy. We will post all revisions, along with their effective dates. We recommend that you check on our privacy policy every so often to make sure you're familiar with the latest policy. We will ask for your consent to policy changes if required by applicable law; in other cases, please note that your continued use of the Service after any change means that you agree with, and consent to be bound by, the new Privacy Policy.

General

We reserve the right to discontinue or modify any aspect of the Services at any time. This Privacy Policy, together with our Terms of Service and any other legal notices published by us on our Apps, our Site, in the Apps and in the Sites, shall constitute the entire agreement between us concerning the Services. If any provision of this Privacy Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Privacy Policy, which shall remain in full force and effect, provided, however, that in such event this Privacy Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

Access Requests and Corrections

You can request access to and correction of personal data we hold about you using the contact details below. You may also update or correct personal data on your profile at any time directly through the Apps or the Sites. If we no longer hold this data, we will pass your request to the Insurer holding such data. Any questions or requests or any complaints may be made to rylie@hk.yas.io.

In case of discrepancies between the English and Chinese versions, the English version shall prevail.

Purpose of Collection and Use by YAS DIGITAL LIMITED

YAS DIGITAL LIMITED ("YAS", "we", "us", or "our") may collect and use your personal data including your name, identification number or passport details, address, email, phone number and other contact details, date of birth, payment, credit card and bank account details, photo and policy number, information about your dependents and health records, and which we may collect when, for example, you apply for, renew or make a claim under a policy and/or you correspond with us, for the following purposes:

• Your use of the application ("Apps") or the website ("Sites") to purchase insurance products from the insurers offering insurance products on the Apps or the Web ("Insurers") and for you to access information about the insurance products purchased;
• Your use of the Apps to make claims on any insurance products;
• Administering, managing and contacting you about your user account on the Apps, the Sites and related records;
• Maintaining a profile in relation to you (including, without limitation, information regarding any purchases or claims made via the Apps or the Sites), and providing you with a more personalised experience in relation to our Apps, our Sites and Services (as defined in the Privacy Policy located here);
• Performing market research or statistical analysis to better understand customer behaviour and to improve our Services (as defined in the Privacy Policy);
• Responding to your queries and feedback regarding the Apps or the Sites; and
• Complying with any legal or regulatory requirements applicable to YAS.

You must provide us with any personal data we indicate as being mandatory, from time to time. If you do not provide such mandatory personal data, we may not be able to provide the Services to you and/or the Insurers may not be able to provide any insurance products or services or to process any claims. All other personal data that is not indicated as being mandatory can be provided voluntarily.

Transfer to Insurers and Use by Insurers

We will transfer your personal data to the Insurers so that they can:

• Process your insurance application;
• Arrange a contract of insurance with you and administering the policy issued;
• Claims handling, investigation and analysis;
• Design products and/or services for customers;
• Promote, improve and further the provision of the Insurers' products and/or services; and
• Comply with any legal or regulatory requirements applicable to the Insurers.

Other Transferees

Data held by the Insurers relating to you may, for the purposes set out above, transfer your personal data to:

• Their group companies;
• Reinsurers;
• Intermediaries including insurance brokers and insurance agents;
• Claims investigators, loss adjustors and other professional advisors;
• Their other appointed service providers, including for the following services: telecommunication, information technology, administration, data processing, payment processing, emergency assistance, legal and medical;
• Any insurance industry association or federation and their respective members; and
• Any other person necessary to comply with applicable legal or regulatory requirements, or orders of competent authorities, in each case both within and outside of the jurisdiction in which you are located.

We may also transfer your personal data for the purposes set out above to any of our own parent companies, subsidiaries and/or affiliates ("Group"), to any service provider appointed by us or any member of our Group, or any legal or regulatory authority or court of competent jurisdiction (in each case whether located inside or outside the jurisdiction in which you are located).

Marketing and Promotion by YAS

YAS may use your name, contact details, profile, previous purchase history, activity information and/or claims information collected in relation to your use of the Apps, the Sites or Services, to send you direct marketing materials relating to the Apps, the Sites and our Services.

YAS will not use your personal data for direct marketing if you have indicated objection to such use by ticking the opt-out box below.

You may also, at any time, request YAS to cease the use of your personal data for direct marketing purposes, by sending a request to the contact details set out below.

Marketing and Promotion by Insurers

The Insurers who you have purchased any products or services from via the Apps or the Sites, may use your name, contact details, profile, previous purchase history, claims information, and/or activity information collected in relation to your use of the Apps, the Sites or Services, for the purposes of sending you direct marketing materials relating to the Insurers' insurance products, services and offers and for sending you the promotional materials or updates of such products, services or offers when they become available.

You may contact the Insurers directly to request that the Insurer cease using your personal data for direct marketing purposes, via the details and opt-out methods provided by the Insurers.

Accuracy and Retention of Personal Data

By providing us with your Personal Data or that of a family member, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility. When you give us Personal Data about another person (or persons) such as a family member, you should have the authority to act on such person’s behalf (whether by appointment or by law in your capacity as legal guardian). This includes providing consent to our processing of their Personal Data. If for any reason you are concerned as to whether you are permitted to provide us with another person’s information, please contact us at the email address listed below before sending us anything.

All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as permissible by applicable law(s).

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

You have the right to request access to and correction of your Personal Data as held by us. You may update or correct personal data on your profile at any time directly through the Apps or the Sites. You may also contact us at rylie@hk.yas.io at any time if you wish to correct, amend or update your personal data. We aim to acknowledge and act upon your request promptly. To help us respond in the most timely and appropriate way, please be as specific as possible in your request or inquiry.

Acceptance of PICS and Opting-In of Direct Marketing

By clicking "accept", you indicate:

(i) your agreement to this PICS; and

(ii) your consent to the use of your personal data for direct marketing purposes in accordance with the above, unless you have ticked the relevant opt-out box below indicating that you object to such use.

In case of discrepancies between the English and Chinese versions, the English version shall prevail.