PERSONAL INFORMATION COLLECTION STATEMENT
China Pacific Life Insurance (H.K.) Company Limited (the “CPIC Life (HK) ”, “we”, “us” or “our”) respects and protects your privacy and pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong Special Administrative Region ("Hong Kong")) (the “Ordinance"). This statement applies to all products and services provided by CPIC Life (HK) and sets out why the Company collects the personal data about the customer(s), how it is intended to be used, to whom it may be provided to and how to access, review and correct the personal data. “Customer(s)” in this statement means data subjects (as defined under the Ordinance) and includes existing and prospective insurance policy owners, insureds, beneficiaries and other persons designated or entitled to receive moneys and/or other benefits under an insurance policy.
1. Personal data collected and / or held by CPIC Life (HK)
In this statement, “personal data” bears the same meaning as defined under the Ordinance. It includes any data (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. The personal data that the Company collects and/or holds includes but is not limited to name, identity card number, contact information, family history, policy details, education details, employment details, financial details, health and medical information.
CPIC Life (HK) will keep the personal data for as long as necessary to achieve the purpose for which it was collected and to comply with prevailing legal requirements. If CPIC Life (HK) no longer needs the personal data for any purposes, the Company will take reasonable steps to securely delete or destroy personal data.
2. Consequence of failing to provide personal data
The provision of the personal data is voluntary. If you do not provide us with the requested personal data, it may inhibit our ability to provide or continue to provide your requested products and services.
3. Purposes of personal data collected by CPIC Life (HK)
Personal data held by CPIC Life (HK) may be used for the following purposes:
- a.processing applications and verifying the eligibility for insurance products or services;
- b.designing new or enhancing existing insurance products, services and related products provided by CPIC Life (HK);
- c.administering the policies issued;
- d.processing payment instructions;
- e.processing any insurance claims;
- f.conducting statistical and actuarial research;
- g.data matching, or conducting matching procedure (as defined in the Ordinance, but broadly includes comparison of two or more sets of the data subject's data, for purposes of taking actions adverse to the interests of the data subject, such as declining an application), internal business and administrative purposes;
- h.determining amount of indebtedness owed to or by you, and performing your obligations including the collection of amounts outstanding from you or any person who has provided any security or undertaking for your liabilities owing to the Company (if any);
- i.sending out administrative communications about any accounts you may have with the company or about future changes to this statement;
- j.direct marketing;
- k.performing policy review and needs analysis;
- l.meeting obligations and requirements imposed by any applicable laws, regulations, codes of practice or guidelines or assisting with law enforcement purposes, investigations by regulatory authorities in Hong Kong or elsewhere;
- m.other purposes as notified at the time of collection;
- n.other purposes directly relating to any of the above.
4. Transfer
The personal data collected by CPIC Life (HK) will be kept confidential but may be transferred and disclosed to any of the following parties, whether within or outside Hong Kong, for the purposes as specified in a) to n) above:
- i. China Pacific Insurance (Group) Co., Ltd (“CPIC Group”) and any other companies within the Group;
- ii. any companies carrying on insurance and/or reinsurance related business;
- iii. any licensed insurance intermediaries who have an agreement with CPIC Life (HK);
- iv. any insurance claim investigators;
- v. any partnering financial institutions;
- vi. any agents, contractors or third party administrators who provide administration, technology, data processing, telecommunications, computers, payment, debt collection, call center services, direct marketing services, or other services to CPIC Life (HK) in connection with the operation of its business;
- vii. any applicable and relevant associations and federations of the insurance industry that exist from time to time;
- viii. any other service providers providing insurance and / or reinsurance related business;
- ix. any governmental and judicial bodies or regulators;
- x. any other parties as notified to you at the time of collection.
5. Access and Correction
In accordance with the provision of the Ordinance, you have the right to request access to and / or correction of your personal data held by CPIC Life (HK). If you want to access and / or correct your personal data held by CPIC Life (HK), please make such a request by writing to our Data Protection Officer at Room 1802, 18/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong.
6. Direct Marketing
CPIC Life (HK) would like to keep in touch with you regarding product offers and promotional materials. Without your consent, CPIC Life (HK) will not use or provide your personal data to any external parties for any direct marketing purposes.
CPIC Life (HK) will use your name, residential address, contact address, email and phone number (“Information”) from time to time and/or provide the Information to (i) CPIC Group; (ii) CPIC Group member companies; and/or (iii) third-party service providers (whether or not in return for gain) for direct marketing of the following:
-insurances, annuities, wealth management, fund investment services, retirement schemes and other financial related products and services:
-products and services in relation to health, wellness and medical, healthy ageing and retirement, sporting activities and membership, fitness or similar leisure activities, travel and transportation, social networking, media, medical care services; and
- reward, customer loyalty or privilege programme and related products and services.
Please notify the Data Protection Officer of CPIC Life (HK) in writing to Room 1802, 18/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong if you wish to access or withdraw your consent to the use and provision of Information for direct marketing purposes.
CPIC Life (HK)’s Privacy Addendum for Mainland China
This Addendum only applies to you if you are located in Mainland China. This Privacy Addendum forms part and parcel of CPIC Life (HK)’s Personal Information Collection Statement and specific to individual customers who are located in Mainland China and receiving our product(s) and/or service(s) associated with the product(s) from Hong Kong. If there is any conflict or inconsistency between the terms of this Addendum and any terms set forth in CPIC Life (HK)’s Personal Information Collection Statement, the terms of this Addendum shall prevail.
CPIC Life (HK) (hereinafter also referred to as “we”, “us” or “our”), the issuer of your insurance policy, is the processor of your personal data and you may reach us via wecare@cpiclife.com.hk in accordance with the applicable data protection laws of Mainland China. As required by the laws of Mainland China, when we provide you with the product(s) and the service(s), we may need to seek your consent on how we use your personal data and, in relation to certain personal data which is considered sensitive based on the laws of Mainland China, we may need your separate consent. Your personal data will be collected, accessed, processed, used, stored, and/or transferred outside of Mainland China, with the types, purposes, methods, way of right exercise and contact information set out in our Personal Information Collection Statement. If you do not consent to this Privacy Addendum, we may not be able to provide you with the product(s) you are purchasing from us and offer you with the service(s).
To ensure security, you are required to provide a written request or otherwise verify your identity. We may ask you to verify your identity before processing your request.
Under the following circumstances, we will be unable to respond to your above requests as required by applicable laws and regulations:
- • Where the request is related to the personal information controller fulfilling obligations prescribed by laws and regulations;
- • Where the request is directly related to national security or defense security;
- • Where the request is directly related to public safety, public health, or major public interests;
- • Where the request is directly related to criminal investigation, prosecution, judicial proceedings, or enforcement of judgments;
- • Where we have sufficient evidence that you are acting in bad faith or abusing your rights (for example, if your request would endanger public safety or the legitimate rights and interests of others, or if your request exceeds the scope reasonably covered by standard technical means and commercial costs);
- • Where responding to the data subject's request would seriously harm your legitimate rights and interests or those of other individuals or organizations;
- • Where the request involves trade secrets.
Under the applicable data protection laws in Mainland China, we will process your personal data based on your consent, unless your personal data are:
- • necessary to conclude or perform a contract in which you are a party;
- • necessary for us to comply with legal obligations;
- • necessary to respond to public health emergencies;
- • necessary to protect individuals’ life, health, and property safety;
- • reasonably processed in news reporting and public opinion oversight for public interests; or
- • publicly available, because of your voluntary disclosure or a legal requirement, and reasonably processed.
Certain personal data that we collect about you is sensitive personal data as defined in the applicable data protection laws in Mainland China ("Sensitive Personal Data"), which is personal data that may materially impact your rights and interests, cause harm to your dignity, personal or property safety, if leaked or unlawfully used, including but not limited to financial accounts, national identification number, medical or health-related information, biometric identification, religious belief, specific identity, individual location tracking or any personal data of minors under the age of fourteen. We collect the Sensitive Personal Data only for specific purposes, such as assessing your application for the issuance of an insurance policy to you, processing your request of changes in personal data and investigation on any claims applications submitted to us. We will not be able to provide you with the product(s) and/or service(s) if we fail to process your Sensitive Personal Data. We generally do not directly collect personal data from a child under the age of fourteen but may collect such personal data from the parent or legal guardian of the child where such processing necessary for providing relevant services while the parent or legal guardian may exercise the minor's rights and consent to us. We generally do not directly collect personal data from the minors who are 14 years of age or older but may collect such personal data from the parent or legal guardian of the minors where such processing necessary for providing relevant services while the parent or legal guardian may exercise the minor's rights and consent to us. We adopt and implement strict security policies to protect the confidentiality and privacy of your sensitive personal information. We adopt and implement strict security policies to protect the confidentiality and privacy of your sensitive personal information.
We will retain your personal data for the period necessary to fulfill the necessary purposes of processing your personal data as outlined in our Personal Information Collection Statement and this Privacy Addendum. The criteria used to determine our retention periods may include one or more of the following: as long as we have an ongoing relationship with you; as required by a legal obligation to which we are subject; and as advisable in light of our legal position (such as in regard of the applicable statute of limitation, litigation, audits or regulatory investigation). Your personal data will be securely deleted or disposed of thereafter. Unless we have to retain certain data due to legal reasons, we will only process such data to the extent required by laws and regulations and will not use it in our daily business activities.
We may also provide your personal data to other recipients, within or outside Mainland China as set out in our Personal Information Collection Statement including but not limited to any licensed insurance intermediaries, insurers, third party service providers, medical institutions such as hospitals, medical clinics and laboratory testing facilities, China Pacific Insurance (Group) Co., Ltd ("CPIC Group") and any other companies within the Group, auditors, legal advisors, financial advisors, reinsurers, governmental and judicial bodies, regulators, associations and federations of the insurance industry, banks, payment settlement agents, third party payment service providers and claims investigation organizations, for the purpose of the administration of your insurance policies and the provision of product(s) and service(s) to you. Currently, we provide your personal data to China Pacific Life Insurance Co., Ltd. (life.cpic.com.cn/xrsbx/) which is located in Mainland China for processing for the purpose of providing you with the product(s) and service(s), with the types, purposes and methods as set out in our Personal Information Collection Statement.
The recipient(s) of your personal data may collect and process your personal data and return to us for the purpose of the administration of your insurance policies. The types of personal data that we provide to the recipients include without limitation personally-identifiable information, your medical information, your past health records/information, and your financial information. We may deliver your personal data through electronic means or other mode of dispatch to the recipients to process such information for us in accordance with our instructions and in compliance with our privacy policy as well as any other appropriate confidentiality and security measures. In compliance with the applicable rules and regulations of Mainland China, we implement maximum security in controlling, processing and transferring of your personal data and Sensitive Personal Data. We also adopt our own security policies to safeguard your personal data and Sensitive Personal Data.
In addition to the access rights set forth in our Personal Information Collection Statement, you have the right to obtain a copy of your personal data held by us, the right to withdraw consent to use of such personal data, the right to restrict or object processing of such personal data and the right to request us to delete such personal data under any of the following circumstances:
- • where the purposes of processing your personal data have been achieved or have failed to be achieved, or the personal data is no longer necessary for achieving the purposes;
- • where we have ceased to provide the product(s) or service(s), or the retention period has expired;
- • where you have withdrawn your consent; and
- • where we have violated the applicable data protection laws and regulations.
You may withdraw your consent to our use of your personal data by contacting us through the contact details set out in this Privacy Addendum. If you withdraw your consent to our processing of your personal data, we may not be able to provide the relevant product(s) and/or service(s) to you. If you wish to exercise any of your rights under the Personal Information Protection Law of China, you may make your request by writing to our Data Protection Officer at Room 1802, 18/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong.
To the extent inconsistent with the provisions of this Privacy Addendum, including but not limited to definitions (e.g., Sensitive Personal Data), China's Cybersecurity Law, Personal Information Protection Law, Data Security Law, their implementing measures and other Chinese laws and regulations in relation to cybersecurity and data protection will prevail.
We have the right to update this Privacy Addendum from time to time and we will notify you of our updates to this Privacy Addendum by posting it on our website or application platforms (as the case may be).
I have read and understood this Privacy Addendum and agree that CPIC Life (HK) can process, use and transfer my personal data and Sensitive Personal Data as set out in this Privacy Addendum.