Privacy Policy

The management of personal information is fundamental to ASA REN’s services and we are committed to protecting your privacy.

ASA REN collects and uses personal information to identify you, establish eligibility, and to provide technology-enabled total health, wellbeing and human resources services (such as pensions and benefits, employee assistance programs, and health management programs), including through our websites and apps. We also use your information for our own purposes, including to analyze and improve our services and for communications.

Please see the headings below to get more detailed information on how ASA REN handles your personal information and on any topics of interest in our privacy policy.

About This Privacy Policy

We created this privacy policy to tell you:

What personal information we might collect about you;
What we might do with that personal information; and
Your choices about the personal information you provide.

This policy covers our websites, mobile apps, services provided through these platforms or otherwise accessed by a user (such as our counselling and wellbeing services) and any other interactions you may have with us (by telephone, email, or in person). This policy specifically covers our handling of personal information relating to identifiable individuals, and does not apply to proprietary business information.

Some of our services are provided on behalf of our clients, which means our client remains primarily responsible for your personal information. For instance, we may be providing services on behalf of your employer or plan sponsor. In these circumstances, we may redirect a query about our use of your personal information to our client.

Getting Your Consent

As part of using our services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes we’ve informed you of, or as may be otherwise permitted or required by law. Your consent can be expressed or implied. For example, by participating in your benefits plan, you consent to ASA REN’s collection and use of your personal information to provide services to that plan. In some situations, we may get consent directly from you (including as described in this privacy policy). In other situations, we may rely on the consent you provided to your employer or benefits sponsor.

You can withhold or withdraw your consent for us to collect, use or share your personal information, as long as there are no legal or contractual requirements for us to process your information. Depending on the circumstances, however, withdrawal of your consent may impact our ability to serve you, or in the case of administering benefits, it may prevent us from processing your claims.

Where We Get Your Information

We collect personal information in the following ways:

Directly from you;
From your use of ASA REN’s services, programs, websites and mobile apps;
When you attend a ASA REN’s site or event;
When you apply for a position at ASA REN;
If you contact us with a complaint or query;
From legally authorized third parties.

Children’s Information

We will not knowingly collect, use or share personal information if you are under the age of majority in your area without the permission of your parent or guardian. If you are under age and want to access our counselling and wellness services, your parent or guardian needs to contact ASA REN on your behalf.

What Information We Collect and Why

Our collection and use of your personal information depends on what products and services your sponsoring organization chooses to make available to you, which ASA REN products and services you choose to participate in, and what information you choose to provide to us.

We may collect and use the following types of information for the following purposes:

Personal Information Category	Types of Information We May Collect	How We May Use It
Identity information	Your name, email, username, employee number or similar identifier, marital status, date of birth and reported gender collected both in app and data form/consent form	To identify and authenticate you To communicate with you To create and administer your account when you register for our service, including through our websites and apps
Contact information	Your billing address, postal address, email address and telephone numbers	To communicate with you and respond to your inquiries To inform you of news about our products and services, as well as special promotions, offers or events To create and administer your account when you register for our service, including through our websites and apps
Employment information	Your job title, place of work, hire date, employment history, work address	To determine eligibility and process applications To administer the range of products and services that you have with us
Financial information	Your banking information, email linked to your electronic transfers, and payment information	For billing, administering claims and other financial and payment-related functions
Transaction information	Details about payments to and from you, and other details of products and services you have purchased from us, including customer account numbers	For administering services and auditing To understand how you use our products and services
		Note: For clients using absence and disability management services, LifeWorks or employee and family assistance programs, the personal health information collected for the purpose of providing one service will not be used or disclosed for the purpose of providing any other service. Although some health information may be used by ASA REN in data analytics, it will not be disclosed in a way that allows identification of any individual
Biometric information	Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you.	To administer products and services that you have with us
Lifestyle information	Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), cardiovascular disease risk, emotional wellbeing (e.g., depression and stress), and readiness to change	To administer products and services that you have with us
Claims information	Information disclosed to us with your permission by your insurance, health plan provider, or plan sponsor regarding claims you have made under your policy and/or other information, including health information	To determine eligibility To administer the full range of products and services that you have with us To process and administer claims To provide you with personalized services
Interaction information	Telephone recordings and transcripts, records of communications (emails, letters, online chat etc.)	For quality assurance and staff training purposes To retain a record of your interactions with ASA REN To provide you with the services and information which you request To communicate with you and respond to your inquiries To understand any concerns you may have, so that we can resolve disputes and improve your experience
DNA Report Information	DNA report information including of interpretation of your genetic’s result.	To proceed your DNA result information on Mobile Apps and Website based on our data protection.
Digital interaction information	Geolocation data, IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including the type of device used) and other technology, related to the devices you use to access our websites and/or our apps	To personalize your experience and understand how you use our sites and apps To notify you of any relevant issues relating to our website or app (e.g., push notifications) To measure how our apps and websites are performing To identify opportunities for new products/services or improvements to existing ones For system or product development and planning, audit and administrative purposes

We may also collect and use your information to:

Perform services on your behalf or your employer’s/benefits sponsor’s behalf (including total health and wellbeing, rewards and recognition services, employee and family assistance services, health management programs, group benefits and investment plans, and pension administration services);
Understand your needs, the suitability of our products and services, and assess future needs;
Provide services tailored to your requirements and to treat you in a more personal way;
Promote and market our products and services to you;
Improve our business operations and the quality of our products and services;
Develop and test new products and services;
Manage our business and operational needs;
Administer and protect the security of our business, and our websites, apps and other services;
Meet our legal and regulatory obligations, including to enforce our legal rights; and
Carry out other purposes related to any of the above.

De-identified, Aggregated, and Anonymized Information

We may use your personal information to generate de-identified, aggregated or anonymized information that does not reveal your identity. ASA REN uses this information to conduct research, compile aggregate data sets, statistics and reports, and to perform analytics on our services, service standards, business operations, and trends.

We may share de-identified, aggregated or anonymized information with our clients for reporting purposes, including usage of our services, and with third party service providers for use in creating marketing materials, case studies and statistical analyses. This allows ASA REN, its clients and our respective third-party service providers to understand how we are performing, or develop relevant products, services or offers.

When Does ASA REN Share Your Personal Information?

ASA REN may share your personal information with:

Other ASA REN entities in order to serve you, including for our internal management and administrative purposes.
Third-party service providers who are required to keep your information confidential and secure and are restricted from using or disclosing information for reasons other than performing services on our behalf or to complying with legal requirements.
Third parties and partners in the event of a potential merger or acquisition, transfer of assets, reorganization or bankruptcy. These parties are also required to keep your information confidential and secure and are restricted in their use of information to this purpose.
Government, regulatory and law enforcement agencies to meet our compliance, regulatory, and risk management obligations or to comply with the law.
The general public and other users when you post or share comments, blog postings, testimonials, or other similar information on our technology platforms
Your sponsoring organization or health plan provider when you provide your express or implied consent or if we are required to do so by law.

Storage of Your Information

ASA REN and/or it’s technology provider/vendor may store your personal information in its databases located in Singapore. Some of our service providers may also store or access personal information from countries other than where you reside or receive services, and in those circumstances, are subject to the laws of that jurisdiction. Because of this, there may be circumstances where other foreign governments, courts, law enforcement agencies or regulatory agencies are entitled to access the personal information collected and held by ASA REN and/or it’s technology provider/vendor.

If you are visiting our website from a country other than Singapore, your communication through our website or any of our services may result in the transfer of information across international boundaries. By using our website or any of our services, you consent to the collection, storage, and processing of your information in Singapore.

Retention of Your Information

We only keep your information as long as it is contractually, operationally or legally necessary. When we no longer need the information, it is either destroyed or de-identified.

Safeguards

We use reasonable physical, technological, organizational and contractual safeguards, appropriate to the sensitivity of the information, to protect personal information in our possession or under our control, from unauthorized access, disclosure or use

Accessing Your Information

When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain. We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for copies of your personal information.

Correcting Your Information

We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make appropriate updates needed to keep things running smoothly. You can review your personal information by looking at the correspondence we send to you, through your online accounts with us, or by requesting access to your personal information, as described above.

How We Secure Your Information

ASA REN implements the standard of data privacy policy. Your Personal Information may be saved in our database by our service providers as necessary for them to provide their services to us.

Data Protection

If you have feedback regarding your concern of Data Protection should be referred to our Legal Officer at mega.riana@asaren.ai.

Every complaint will be received by us. After that our Legal Officer would review and assess the complaint or feedback with the result of evaluation based on General Data Protection Regulation.

Governing Law

The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy, you must first contact our Legal Officer regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within thirty (30) days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

This policy was last revised in November 2021.