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Personal Data Policy

1.

Hong Leong Insurance (Asia) Limited ("HLIA") is a member of the Hong Leong Group which is a leading conglomerate based in Malaysia with diversified businesses in banking and financial services, manufacturing and distribution, property development and investment as well as hospitality and leisure with presence in North and Southeast Asia, Western Europe and the UK, North America and Oceania. HLIA fellow group members in Hong Kong include Guoco Group Limited, Hong Leong Bank Berhad Hong Kong Branch and Lam Soon (Hong Kong) Limited.

 

2.

Hong Kong legislation controls the collection, use and storage of personal information ("data"). This policy is being provided to individuals dealing with HLIA in Hong Kong ("Relevant Persons") from whom data have been and/or may in the future be collected.

 

3.

From time to time, it is necessary for Relevant Persons to supply HLIA with data in connection with the provision of insurance services or related products.

 

4.

Failure to supply such data may result in HLIA being unable to provide insurance services or related products.

 

5.

It is also the case that data are collected from Relevant Persons in the ordinary course of carrying out HLIA's business with the Relevant Persons.

 

6.

The purposes for which data relating to a Relevant Person may be used are as follows: -

 

 

(i)

the daily operation of the insurance services provided to Relevant Persons including but not limited to:
 

 

(a) processing and evaluating the Relevant Persons' applications;
 

 

(b) administering and providing services in relation to the insurance products;
 

 

(c) investigating and processing claims;
 

 

(d) invoicing and collecting premiums; and
 

 

(e) contacting the Relevant Persons for any of the above purposes;

 

 

(ii)

carrying out matching procedures;

 

 

(iii)

ensuring ongoing credit worthiness of Relevant Persons;

 

 

(iv)

researching, designing, launching banking, financial, insurance services or related products for Relevant Persons' use and monitoring the provision, operation and use of such services or products;

 

 

(v)

marketing services, products and other subjects (please see further details in paragraph (8) below);

 

 

(vi)

determining amounts owed to or by Relevant Persons;

 

 

(vii)

the enforcement of Relevant Persons' obligations, including without limitation collection of amounts outstanding from Relevant Persons;

 

 

(viii)

complying with the obligations, requirements or arrangements for disclosing and using data that apply to HLIA or that it is expected to comply according to:

 

 

(a) any law binding or applying to it within or outside Hong Kong existing currently and in the future;
 

 

(b) any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers within or outside Hong Kong existing currently and in the future;
 

 

(c) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers that is assumed by or imposed on HLIA by reason of its business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;

 

 

(ix)

complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Hong Leong Group and/or any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

 

 

(x)

enabling an actual or proposed assignee of HLIA, or participant or sub-participant of HLIA's rights in respect of the Relevant Person to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;

 

 

(xi)

provision of reference (status enquiries); and

 

 

(xii)

purposes relating thereto.

 

7.

Data held by HLIA relating to a Relevant Person will be kept confidential but HLIA may provide such information to the following parties for the purposes set out in paragraph (6) above: -

 

 

(i)

claims investigators, medical advisors, reinsurers or the Relevant Person's insurance brokers;

 

 

(ii)

any agent, contractor or third party service provider who provides administrative, telecommunications, computer, legal, payment or clearing or other services to HLIA in connection with the operation of its business;

 

 

(iii)

any other person under a duty of confidentiality to HLIA including a member of the Hong Leong Group which has undertaken to keep such information confidential;

 

 

(iv)

any person to whom HLIA is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to HLIA, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers with which HLIA are expected to comply, or any disclosure pursuant to any contractual or other commitment of HLIA with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance services providers, all of which may be within or outside Hong Kong and may be existing currently and in the future;

 

 

(v)

any actual or proposed assignee of HLIA or participant or sub-participant or transferee of HLIA's rights in respect of the Relevant Person; and

 

 

(vi)

(a) any member of the Hong Leong Group;

 

 

 

(b) third party financial institutions, insurers, credit card companies, securities and investment services providers;

 

 

 

(c) external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that HLIA engages for the purposes set out in paragraph (6)(v) above; and

 

 

 

(d) any nominee, trustee, co-trustee, centralized securities depository or registrar, custodian, estate agent, solicitor or other person who is involved with the provision of services or products by a member of the Hong Leong Group to that Relevant Person.

 

 

Such information may be transferred to a place outside Hong Kong.

 

8.

USE OF DATA IN DIRECT MARKETING

 

HLIA intends to use a Relevant Person's data in direct marketing and HLIA requires the Relevant Person's consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

 

 

(i)

the name and contact details of a Relevant Person held by HLIA from time to time may be used by HLIA in direct marketing;

 

 

(ii)

the following classes of services, products and subjects may be marketed: insurance and related services;

 

 

(iii)

the above services, products and subjects may be provided by HLIA.

 

 

If a Relevant Person does not wish HLIA to use his data in direct marketing as described above, the Relevant Person may exercise his opt-out right by notifying HLIA.

 

9.

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (the "Ordinance") and the Code of Practice on Consumer Credit Data, any Relevant Person has the right: -

 

 

(i)

to check whether HLIA holds data about him and of access to such data;

 

 

(ii)

to require HLIA to correct any data relating to him which is inaccurate; and

 

 

(iii)

to ascertain HLIA's policies and practices in relation to data and to be informed of the kind of personal data held by HLIA.

 

10.

In accordance with the terms of the Ordinance, HLIA has the right to charge a reasonable fee for the processing of any data access request.

 

11.

The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows: -

 

 

The Data Protection Officer

 

Hong Leong Insurance (Asia) Limited

 

Units 807-810, 8/F Island Place Tower

 

510 King's Road, North Point, Hong Kong

 

12.

Nothing in this policy shall limit the rights of Relevant Persons under the Ordinance.

 

13.

To help us to provide a better service to you, please ensure that your contact details including your home and office addresses, your telephone numbers (including your mobile telephone number), e-mail address and other details registered with us are up to date.

 

14.

The provisions of this policy may form part of the account terms and conditions and/or the agreement or arrangements that you have or may enter into with HLIA. If any inconsistency is found, the provision of this policy shall prevail.

 

15.

This policy is subject to change from time to time and any changes will be posted on HLIA's website at www.hl-insurance.com.

 

16.

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

 

April 2016