Chubb Life Hong Kong Privacy Policy and Website Terms and Conditions

Chubb Life Hong Kong is committed to safeguarding your personal data and implementing and complying with the data protection principles under the requirements of the Personal Data (Privacy) Ordinance (Chapter 486), Laws of the Hong Kong Special Administrative Region, and other applicable laws. This Privacy Policy applies to all products and services provided by Chubb Life Hong Kong and sets out how Chubb Life Hong Kong may collect, use, hold, store, transfer and disclose your personal data.

Chubb Life Hong Kong collects personal data in a number of ways including but not limited to when you (i) submit an application or claim, (ii) request services or products, (iii) contact us in person, phone, mail, email or online, (iv) participate in our programs, or (v) access our website and/or receive services from us. When you visit this website, Chubb Life Hong Kong will not collect any of your personal data until you submit a completed on-line form to us, register as a member, file information for job application purposes, log into the on-line service(s), and/or submit personal data whilst using the on-line service(s).

The types of personal data Chubb Life Hong Kong collects from you will depend on the circumstances. Generally, Chubb Life Hong Kong may directly or indirectly collect personal data from you and/or your dependents, the insured, the beneficiaries, your authorized representatives and any other individuals whom you have provided personal data of (“relevant persons”), which personal data may include without limitation:-

1. Name (in Chinese and in English);
2. Date of Birth;
3. Identity card number;
4. Contact details (e.g. phone number, fax number, residential address, email address, etc.);
5. Policy details;
6. Transaction records;
7. Financial background;
8. Medical/health record and claims history;
9. biometric data (including but not limited to your voice pattern and facial images); and/or
10. location information based on your device.
     

Some of the personal data we collect may be considered sensitive personal data under applicable laws. This may include your transaction records, identity document number, marital status, medical/health records, biometric data, religion, specific social status, tracking/location information, credit information, financial details, bank account information, tax information and if applicable, data of minors under the legal age of your country of residence. You understand that the processing of this sensitive personal data is necessary for us to evaluate your eligibility for our life insurance services and products and for the purposes as set forth in “Main Purposes of the Collection of Personal Data”. We will take necessary security measures to protect your personal data to avoid any material harms to your legitimate rights and interests associated with your sensitive personal data.

When you provide personal data of the relevant persons to Chubb Life Hong Kong, you confirm you have obtained that relevant persons’ consent and have the authority to provide such personal data for use and transfer by Chubb Life Hong Kong for the purposes set out in this Privacy Policy.

The purposes for which your or relevant persons’ personal data will be used will depend on the circumstances under which that personal data is collected. Chubb Life Hong Kong will inform you of the purposes for which we intend to use your or your relevant persons’ personal data in our PICS at or before the time of such collection.

Your or your relevant persons’ personal data held or stored by us may be used for the following purposes:

1. evaluating or processing any insurance policy application;
2. administering and processing your insurance policy, payment instructions and premium collection;
3. performing medical, security and underwriting checks;
4. assessing insurance claims and processing payments;
5. providing insurance products and related services;
6. with your consent and where permissible by applicable laws, to promote and directly market to you: (a) the insurance products and services of Chubb Life Hong Kong; (b) mandatory provident fund-related products/services sponsored by the third party providers connected with us; (c) insurance, financial or investment related products/services, rewards, loyalty, co-branding and/or other privileges programs offered by us,  our affiliates, our co-branding partners, our business partners (please refer to “Use of personal data for direct marketing purposes” section below);
7. performing data matching and communicating with you and/or your relevant persons for such purposes;
8. cooperating with law enforcement bodies for law enforcement purposes, to prevent any serious threat to public safety; for police investigation purposes; or to comply with laws, rules, regulations, codes of practice, guidelines or requirements imposed by or agreed with government or regulatory bodies or for litigation;
9. applying registration of activities organized and/or sponsored by Chubb Life Hong Kong;
10. enabling industry associations, federations, government or regulatory bodies to carry out their functions and requirements that may be assigned to them from time to time as are reasonably required and in the interests of the insurance industry;
11. conducting research, surveys, data analytics and statistics, administration, communications, computer, security and other services (including medical services, mailing and IT services); in connection with the usual operations of the Company as a life insurance company; and
12. for any other purpose directly relating to any of the above or as notified at the time of collection.
     

It may be necessary and required for you to provide certain categories of personal data to us and we will specify such categories to you at the time of collection. If you do not provide such specified personal data as required, Chubb Life Hong Kong may not be able to issue policies, process your requests, applications or claims and/or provide you with our products and/or services.

Generally, your and your relevant persons’ personal data held by us will be kept confidential, but may be transferred to any of the following parties (whether within or outside the Hong Kong Special Administrative Region) where such disclosure is necessary to satisfy the purposes set out above:

1. any branch, subsidiary, holding company, associated company or affiliates of Chubb Life Hong Kong (“Group Companies”);
2. any agents, insurance intermediaries, third party providers or administrators such as medical and healthcare providers, hospitals, in connection with the distribution of our products and services, placement or handling of your insurance policy and any related claims and/or services;
3. any agents, contractors, advisors or third party service providers providing accounting, finance, legal, payment, data processing and storage, administration, telecommunications, mailing, printing, computer, technology, security, analytics, research, funds management, regulatory screenings, customer services, call centre services, and/or other services in connection with our operations;
4. reinsurers;
5. claims investigators;
6. loss adjudicators;
7. medical advisors; 
8. recovery agents;
9. credit reference agencies;
10. debt collection agencies;
11. law enforcing bodies and police;
12. insurance industry associations and federations;
13. organizations that consolidate underwriting and claims information for the insurance industry, fraud prevention/detection agencies, and databases or registers (and their operators) used by the insurance industry to analyze and check information provided against existing information;
14. government or judicial or competent regulatory bodies or any person to whom Chubb Life Hong Kong is under legal and/or regulatory obligations to make disclosure; and
15. other parties as notified to you at the time of collection.
     

For Mainland China residents, you understand that your personal data will be stored and processed in Hong Kong and other countries/regions outside the country/region where you are located, for the purposes listed in this Privacy Policy. We will take necessary steps to comply with applicable legal requirements in this respect. Check List of Recipients to learn more about the recipients of your personal data.

We may also purchase or sell one or more business(es) (or portions thereof), and where permissible by applicable laws, your or your relevant persons’ personal data may be transferred as a part of such purchase or sale, or proposed purchase or sale.

In respect of use of your personal data for direct marketing purposes, under applicable law, Chubb Life Hong Kong may, with your prescribed consent:

1. use your name, contact details and policy details (“Relevant Data”) for direct marketing of the following classes of products and services that Chubb Life Hong Kong, our Group Companies, our co-branding partners and/or our business partners may offer:
       (i)   insurance, financial or investment related products/services;
       (ii) rewards, loyalty, co-branding and/or other privileges programs related to health, wellness, medical, entertainment, media, social networking, recruitment, education, training, sport activities, travel, transportation, hospitality, household, food and beverages, telecommunications, charitable and non-profit making purposes.
2. provide your Relevant Data to any agents, contractors, or insurance intermediaries, for the purpose of carrying out direct marketing of the above classes of products or services on behalf of Chubb Life Hong Kong;
3. provide your Relevant Data to third party providers connected with us for their direct marketing of their mandatory provident fund-related products and services; and
4. for gain, provide your Relevant Data to any third party providers or companies (within or outside our Group Companies) for their direct marketing of any of the classes of products or services as described in paragraph 1 above.
    

Chubb Life Hong Kong may only use your Relevant Data or disclose the same to the above specified transferees and any other third parties for direct marketing purposes with your prescribed consent. Chubb Life Hong Kong will inform you of the details of any such proposed use in the PICS at or before the time of such collection. You will be provided with an opportunity to opt-out of 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 by writing to: The Data Protection Officer of Chubb Life Insurance Hong Kong Limited at 35/F, Windsor House, 311 Gloucester Road, Causeway Bay, Hong Kong.

This website may contain links to third party websites. You may be linked from this website to sites provided by the third-party organizations and should be aware that the information on those sites has been compiled and issued by those organizations. Chubb Life Hong Kong has no control over the content of such third-party websites or the way that the operators of those websites deal with your personal data. You should review the privacy policies applicable to those third-party websites to understand the ways in which those third parties may deal with your personal data. Chubb Life Hong Kong accepts no responsibility for the content of those websites and shall not be liable for any loss or damage arising from or related to their uses.

When you access this website, anonymous technical information may be collected about your activities on the website (e.g. your IP address, the date and time that you accessed the website, information relating to your browser and operating system, the pages visited etc.). Chubb Life Hong Kong may use "cookies" (pieces of information relating to your preferences sent by the website to your browser and stored on your computer hard drive). Cookies enable the website to remember you and your preferences when you visit the website and enable us to tailor the website to your needs. Our cookies will track only your activity relating to your online activity on our website and will not track your other internet activity. Our cookies do not identify you personally and do not gather any of your personal data. However, if you do not want to receive cookies you can disable this function by changing your browser settings.

Chubb Life Hong Kong will take all practical steps to implement appropriate organizational and technical safety measures to safeguard your personal data held by us against unauthorized or unlawful use, accidental access, alteration, disclosure, processing, erasure, loss or use, or other use not stipulated herein. Chubb Life Hong Kong provides a highly secure online infrastructure for activities conducted via our website, including SSL (secure socket layer) encryption, IDS (intrusion detection system) and the use of firewalls and anti-virus software. Chubb Life Hong Kong also adopts stringent security procedures with the use of your user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy. Our online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms.

We or our third party service providers may use artificial intelligence (AI) to assist us in providing products or services to you. This may involve the use of your personal data. We may also use AI to help improve our business and provide a better service, for example to assist in underwriting, pricing, claims handling, data analytics, as well as to enhance performance and user experience on our websites and applications. We use various types of AI, which vary based on your relationship with us and the relevant product or service offered. Where appropriate, additional information will be provided to help you understand where AI is being used and how any decisions based on AI are made.

Chubb Life Hong Kong will also take all reasonable steps to ensure that the personal data you provide to us are properly stored. Chubb Life Hong Kong will keep your personal data as long as necessary to achieve the purpose for which it was collected unless a longer retention period is necessary to perform any legal obligations or is permitted by applicable law. and to comply with legal and regulatory requirements. If Chubb Life Hong Kong no longer needs your personal data for any purpose, it will take reasonable steps to securely delete or destroy your personal data.

Chubb Life Hong Kong will also comply with other applicable laws, including any Do Not Call and Do Not Spam legislation, in relation to conducting business via the internet, email marketing, telemarketing, direct mail marketing and legislation regarding identifying numbers. You warrant that all personal data and other relevant information provided by you are true, complete and up-to-date and that you agree to notify Chubb Life Hong Kong of all changes to the information previously provided.

Chubb Life Hong Kong will take all practicable steps to ensure that the personal data kept about you is accurate. If you have any questions or requests regarding your personal data held by us, including requests for access to and/or for correction of any your personal data held by us, please make the request in writing to: 

• For all customers (except for Mainland China residents): The Data Protection Officer of Chubb Life Insurance Hong Kong Limited, 35/F, Windsor House, 311 Gloucester Road, Causeway Bay, Hong Kong or Enquiries.HKLife@chubb.com
  
  
• For Mainland China residents: The Data Protection Officer of Chubb Life Insurance Hong Kong Limited at Enquiries.prchkLife@chubb.com 
   

Any request for access to and correction of information will be dealt with promptly and Chubb Life Hong Kong will use its best endeavors to handle such requests before the expiry of 30 days after receipt of your written request. A reasonable charge may be imposed for processing your access request, where permitted by applicable laws; however no charge will be imposed for a correction request.

You may have additional rights as regards your personal data under other applicable laws (including the right to copy or supplement your personal data, withdraw consent to use of your personal data where consent is the lawful basis relied upon for its processing, and/or delete your personal data where permitted by applicable laws).

If you have any queries about our Privacy Policy and practices, please e-mail them to Enquiries.HKLife@chubb.com.

In the event of any ambiguity or inconsistency between the English and Chinese versions of this Privacy Policy or any PICS, the English version will prevail.