privacy

PRIVACY POLICY

The Chubb Life Company in your jurisdiction (collectively “we”, “us” or “our”) is authorized by the relevant Insurance Regulator to carry on a long term insurance business in your jurisdiction.

We are committed to protecting your privacy. Our policies and procedures have been designed to ensure that your Personal Data is protected and comply with the applicable Personal Data legislation in your jurisdiction when collecting, holding, processing or using your Personal Data.

In this Privacy Policy, “You” (or “Your”) refers to you, being a user of our mobile application and/or the Website (the “Chubb LifeBalance”), and who provides Personal Data to us. “Personal Data” means personally identifiable information, as more specifically defined in the Personal Data legislation, including but not limited to certain clinical health data, family history, tracked activities and your lifestyle.

This Privacy Policy contains the following important information regarding your interaction with us:

The Principles

Collection of Personal Data
Use of Personal Data
Data Quality
Data Security
Openness
Access and Correction

Principle 1 – Collection of Personal Data

We will only collect your Personal Data that is necessary for, and directly related to, the Purposes as set out in our Personal Information Collection Statement ("Primary Purpose").

We will only collect your Personal Data by lawful and fair means. Some information is collected automatically when you use our Chubb LifeBalance because your IP address needs to be recognised by the server. We may use the IP address information to monitor and analyse how Chubb LifeBalance is used.

We may use cookies for a number of purposes as set out in our terms of use. Our cookies will track only your activity on Chubb LifeBalance and will not track your other internet activity. Our cookies do not gather personally identifiable information. Please refer to our Personal Information Collection Statement for our policy on the use of cookies.

At or before the time we collect Personal Data from you, we will take practical steps to ensure you are aware of:

the purposes for which your Personal Data is collected and used;
the classes of persons to whom we may transfer your Personal Data;
whether it is obligatory or voluntary for You to provide the Personal Data;
if it is obligatory for you to provide the Personal Data, the consequences for you if Personal Data is not provided;
your rights to request access to and to request the correction of the Personal Data; and
the name and address of the individual to whom any such request may be made.

Principle 2 – Use of Personal Data

We will only use your Personal Data for a purpose other than the Primary Purpose of collection (a "Secondary Purpose") if:

the Secondary Purpose is directly related to the Primary Purpose of collection; or
you consent to the use or disclosure; or
the Secondary Purpose is direct marketing and we will give you the express opportunity at the time of first contact to decline to receive any further direct marketing communications; or
any of the relevant exemptions under the Personal Data legislation apply.

We may share your Personal Data we have collected with the persons or entities set out in our Personal Information Collection Statement.

Principle 3 – Data Quality

We will take practical steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up to date, having regard to the purpose (including any directly related purpose) for which the Personal Data is or is to be used. Please refer to Principle 6 below for details on how you can obtain and correct any Personal Data relating to you that we may hold.

We will retain your Personal Data for as long as is necessary for the purposes set out in Principles 1 and 2 above as well as for purposes set out in the Personal Information Collection Statement in compliance with all statutory and regulatory requirements in your jurisdiction concerning the retention of personally identifiable information. We will take reasonable steps to destroy or permanently de-identify Personal Data if it is no longer needed for such purposes.

Principle 4 – Data Security

We will take all practical steps to ensure that your Personal Data we hold is protected against unauthorised or accidental access, processing, erasure or other use. A highly secure online infrastructure is provided for activities conducted via Chubb LifeBalance, including SSL (secure socket layer) encryption, IDS (intrusion detection system) and the use of firewalls and anti-virus software. Stringent security procedures with the use of user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy, are adopted. The online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms.

Principle 5 – Openness

We have clearly expressed policies and practices on our management of Personal Data. These policies are set out in this document, which we make available to anyone who requests it.

Principle 6 – Access and Correction

Under the Personal Data legislation, you have the right (subject to certain exemptions) to:

check whether we hold any Personal Data relating to you and request access to such Personal Data; and
request us to correct any Personal Data relating to you which is inaccurate.

Subject to certain exemptions under the applicable Personal Data legislation, we will grant access to and correct Personal Data as requested by you. If we hold Personal Data about you and you are able to establish that the Personal Data is not accurate, complete and up to date, we will take reasonable steps to correct your Personal Data so that it is accurate, complete and up to date. We will provide reasons for any denial of access or a refusal to correct your Personal Data.

Your requests to access or correct your Personal Data will be actioned according to the time limit provided under the applicable Personal Data legislation of your jurisdiction of our receipt of your request and copies of the requested Personal Data or Personal Data so corrected will be posted to your current address.

Practical Steps

If You wish to be provided with a copy of your Personal Data, please send your request to:

Attn: Data Protection Officer of
To the address of the Chubb Life Company in your jurisdiction below.

We prefer to receive data access and correction requests by post or by email. When submitting a data access or correction request, please provide us with documentary proof of your identity. We need proof of your identity so we do not release Your Personal Data to unauthorised persons.

Charges

Your requests for access or correct your Personal Data generally will not incur a charge. There may be some instances where we may charge a reasonable administration fee to cover the costs of providing you with your Personal Data but we will inform you of the amount in advance.

Further Information

If You have any question about our Privacy Policy and practices, please contact us at:

Attn: Data Protection Officer of Chubb Life CompanyChubb Life Company
Chubb Life Company
To the address of the Chubb Life Company in your jurisdiction below.

In the event of any ambiguity or inconsistency between the English version and the local language of your jurisdiction with this Privacy Policy, the English version will prevail.

HONG KONG

Chubb Life Insurance Hong Kong Limited
33^rd Floor, Windsor House,
311 Gloucester Road,
Causeway Bay, Hong Kong

Hotline: +852 2894 9833

E-mail: Enquiries.HKLife@chubb.com

THAILAND

Chubb Life Assurance Public Company Limited
130-132 Sindhorn Building, Tower 1,
11th-12th Floor, Wireless Road, Lumpini, Pathumwan,
Bangkok 10330, Thailand

Telephone: 0-2615-6860

E-mail: CHC.THLife@chubb.com

MYANMAR

Chubb Life Insurance Myanmar Limited
18F Myanmar Centre Tower 2, 192 Kabar Aye Pagoda Road, Bahan Township, Yangon, Myanmar

Telephone: +95 9 7500 66 908

Email: InfoChubbLifeMyanmar@chubb.com

PERSONAL INFORMATION COLLECTION STATEMENT

We are committed to protecting your privacy. We collect, use and retain your Personal data in accordance with the Data Protection Principles set out in the Personal Data legislation of your jurisdiction. Our Privacy Policy is available at the top of this page.

In this Statement, “You” (or “Your”) refers to you, being a user of our mobile application and/or the Website (the “Chubb LifeBalance”), and who provides Personal Data to us. “Personal Data” means personally identifiable information, as more specifically defined in the Personal Data legislation, including but not limited to certain clinical health data, family history, tracked activities and your lifestyle.

Purpose

We collect your Personal data for the purposes of using the data:

to create or reconfigure your account in our mobile application and/or the Website (the “Chubb LifeBalance”);
to provide you with the Health Score and various information about your health, including the potential health risks based on your clinical background and lifestyle for information purposes only;
to enhance and improve the functionality and performance of Chubb LifeBalance;
to contact you with respect to all matters related to your activity on Chubb LifeBalance, including but not limited to sending motivational messages and reminders;
for statistical and analytical purposes to support the design and roll out of engagement activities on Chubb LifeBalance;
to record and analyse your interactions within Chubb LifeBalance as part of our continuous effort to improve your user experience;
for statistical and analytical purposes to develop new insurance propositions or refine existing insurance propositions, including but not limited to enhancing benefits and features, underwriting process and pricing of products and services;
to maintain and manage your participation in our rewards and loyalty points scheme which includes but is not limited to insurance product and services offered by us or on our behalf;
for analytics and profiling in relation to our product and service promotion and campaign engagement;
to connect and share with your social media account your use and activity on Chubb LifeBalance; and
for other purposes as notified at the time of collection.

Your Obligation

If you do not provide us with your Personal Data, we may not be able to provide you access to use the Chubb LifeBalance and the service.

Possible transferees

Please note that we will share your name and profile picture with all other registered users of the Chubb LifeBalance within your jurisdiction. For all other data, you control and decide the Personal Data that will be accessible by others. You can change the privacy settings of your account at any time and thereby determine who can see your Personal Data. The types of Personal Data that may be distinguished are: Health Score, workouts, pictures (workout, profile and profile background pictures) and achievements gained. We will not share sensitive personal data such as weight or blood pressure with others except in an anonymized form as further described below.

The following types of sharing options are available:

Public: All users registered on Chubb LifeBalance within your jurisdiction will be able to see the Personal Data, meaning your name, profile picture, Chubb Health Score, workouts, pictures and achieved goals.
Groups: If you are part of a corporate health program, you will be allocated to a specific company group, which will contain fellow employees with whom you are friends on Chubb LifeBalance, and other employees with whom you are not yet friends on Chubb LifeBalance. If you select the group option, all group members, friends or not, will be able to see your Personal Data.
Friends: Your friends will be able to see the Personal Data.
None: Only you as the user of your account will be able to see the Personal Data. According to our default settings, only you will be able to see all the above-mentioned Data. You can change the privacy settings of your account at any time after your registration. Please note that due to the linking option to other social networks, such as Facebook, your Personal Data may be made available to other persons through your friends.

We may use, store, disclose and/or transfer your Personal Data to third parties for or in connection with the Purpose referred to in the heading above, including to service providers engaged by us to deliver our services, law enforcing bodies, competent regulatory authorities, any individuals/organizations associated with us (whether within or outside of your jurisdiction) for the purposes as specified above and regulatory and law enforcement agencies (where required by law). Those third parties may be located outside your jurisdiction. If we transfer all or a substantial part of our business we may also disclose and transfer your Personal Data to the transferee of that business who may then use your Personal Data to carry out that business as our successor.

We use “cookie” technology to collect additional website usage data and to improve the website, but we do not require cookies for many parts of our services. A cookie is a small data file created by a web server and transferred to and stored on your computer’s persistent memory. The cookies created by the web servers contain data that uniquely identifies you during your use of the website. We use session cookies to better understand how you interact with our services, to monitor aggregate usage by our users and to improve our services. Most internet browsers automatically accept cookies. However, you have the option of using your browser software to stop accepting cookies or to warn you before accepting a cookie from the websites you visit. However, if you disable or choose not to accept cookies, some of the functionality of the website may be impaired or you may not have access to areas of the website that require this type of identification. When you use the App, your Personal Data may be stored and processed temporarily on your mobile device. These data may be transferred to us to help us understand how you interact with our services, to monitor aggregate usage by our users and to improve our services.

For academic and statistical purposes, we may de-identify your Personal Data and subsequently copy, process, use, publicly disclose and distribute them in anonymized form. Such anonymized data shall no longer be considered as your Personal Data With your consent, we may also use your name, contact and demographics to contact you with marketing information regarding our insurance products by mail, email, phone or SMS. We will inform you of that at or before the time of such collection. You will be provided with an opportunity to opt-out of that direct marketing at that time. If you do not opt-out of direct marketing at that time, but you later decide that you no longer wish to receive direct marketing, you may ask us to cease any further direct marketing

Direct Marketing

With your consent, we may also use your name, contact and demographics to contact you with marketing information regarding our insurance products by mail, email, phone or SMS. We will inform you of that at or before the time of such collection. You will be provided with an opportunity to opt-out of that direct marketing at that time. If you do not opt-out of direct marketing at that time, but you later decide that you no longer wish to receive direct marketing, you may ask us to cease any further direct marketing.

Rights of Access and Correction & Contact Person

You have the right to access a copy of and/or correct your Personal Data, subject to certain exemptions. If you would like to access or correct your Personal Data, please write to us at:

Attn: Data Protection Officer of Chubb Life Company
To the address of the Chubb Life Company in your jurisdiction below.

In the event of any ambiguity or inconsistency between the English version and the local language of your jurisdiction with this Personal Information Collection Statement, the English version will prevail.