Disclaimer and Privacy Policy

The People’s Republic of China Addendum (this “Addendum”)

1. Application
   
   FTLife Insurance Company Limited (“FTLife”, “we”, “us” or “our”) in Hong Kong is a related company of the New World group of companies including New World Development Company Limited and its affiliated or related companies from time to time in Hong Kong (the “New World Group” or “NWG”) is committed to protecting personal data of individuals in territories where we do business.
   
   If you are:
   
   
   1. an individual located in Mainland China who visits FTLife’s relevant website(s) or uses relevant mobile application(s) of FTLife, or otherwise uses FTLife’s products and/or services by phone or any other means from Mainland China; and/or
   2. an individual holding a Mainland China passport and/or resident identity card who visits the service centres or other physical premises of FTLife in Hong Kong or otherwise uses FTLife’s products and/or services by phone or any other means in Hong Kong,
   your personal data will be processed by FTLife in accordance with this Addendum in addition to (i) FTLife Privacy Policy Statement and (ii) the FTLife Personal Information Collection Statement (“PICS”) , as well as the applicable data protection laws and regulations in Mainland China.
   
   Therefore, before using FTLife’s products and/or services or providing any personal data to us, please ensure that you have carefully read, understood and agree to the PICS, the FTLife Privacy Policy Statement and this Addendum.
   
   For the purpose of this Addendum, “Mainland China” refers to the People’s Republic of China excluding the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the Macau Special Administrative Region of the People’s Republic of China and Taiwan. Unless defined otherwise, all defined terms (capitalised terms) in this Addendum shall have the same meaning as the defined terms in the PICS.
   
   In the event of any conflict or inconsistency, they shall be resolved in the following order of precedence (from higher to lower) in respect of such conflict or inconsistency: - (a) this Addendum; (b) the PICS and (c) FTLife Privacy Policy Statement.
2. Personal data
   
   In this Addendum, “personal data” refers to various information related to an identified or identifiable natural person recorded electronically or by other means and does not include anonymized information. Personal data involved in this Addendum includes those set out in Clause 3 of this Addendum, Clause 5 of the FTLife Privacy Policy Statement and the section of “Kinds of personal data collected” in the PICS.
   
   In addition, “sensitive personal data” refers to “personal data” that, once leaked or illegally used, may easily lead to violation of the personal dignity of a natural person or harm of personal or property safety. The “sensitive personal data” involved in the FTLife Privacy Policy Statement, the PICS and this Addendum includes identity/travel document details, credit information, financial details, income, bank account information, tax information, marital status, medical and health records, claims history, accident information, family medical history, user name and passwords, Log Files, insurance policy details, transaction records, Tracking Data, transaction information (including your characteristics and transaction behavior).
   
   “Process” or “processing” of “personal data” includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of “personal data”.
3. How we collect and process your personal data
   
   Apart from Clauses 5 and 6 of the FTLife Privacy Policy Statement and the sections of “Kinds of personal data collected” and “Purposes for using personal data collected” in the PICS, the following also applies to how we collect and process your personal data:-
   
   
   1. We may collect personal data from you directly and/or from other sources including our Affiliates, Marketing Partners and/or other third parties (including but not limited to our business partners, other insurance and reinsurance companies, brokers and other intermediaries, credit reference agencies, financial institutions, healthcare service providers, authorities, and persons that you may be associated with such as joint applicants, employers and family members) where permitted by you or according to applicable laws and regulations.
   2. Before providing to us any personal data about a person other than you (including but not limited to your family members, policy owner, insured, beneficiary, assignee, trustee, third-party payor), you shall ensure and warrant that such person (or the parents or legal guardians of such person, as the case may be) has carefully read, understood and agreed to this Addendum, the PICS and the FTLife Privacy Policy Statement, and in particular, notify such person (or the parents or legal guardians of such person, as the case may be) of how we collect and process his/her personal data and obtain all necessary consent from such person.
   3. The personal data will be processed by FTLife for the purposes as further specified below and set out in the PICS (“Purposes”). In particular, for us to carry out the Purposes and provide you with the relevant products/services, the personal data (including sensitive personal data) set out below is necessary. If such information are not available or not accurate, we may not be able to provide the relevant products/services to you:
      
      Purposes and personal data FTLife may collect:https://www.ftlife.com.hk/en/disclaimer/prcaddendum/table/
      
      
   4. To comply with the obligations, requirements or arrangements that apply to FTLife or with which FTLife is expected to comply with, we may also process and use your personal data according to:
      
      
      1. any law binding or applying to it within or outside Mainland China existing currently and in the future;
      2. 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 financial services providers within or outside the Mainland China existing currently and in the future; and
      3. 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 financial services providers that is assumed by or imposed on FTLife by reason of its financial, commercial, 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 authorities, or self-regulatory or industry bodies or associations.
   5. In general, we process your personal data with your consent, and where appropriate, with separate consent from you for processing your personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. You acknowledge and agree that under the following situations, we are not required to obtain your consent to process your personal data:
      
      
      1. the processing is necessary for the conclusion or performance of a contract to which you are a party, or where it is necessary to conduct human resources management according to lawfully formulated labour rules and lawfully concluded collective contracts;
      2. the processing is necessary for the performance of our duties or obligations under any applicable laws and regulations, including those directly related to:
         
         (1) National security and national defence;
         
         (2) Criminal investigation, prosecution and trial and execution of court orders, judgments or related matters; or
         
         (3) Public security, public health, or major public interest;
      3. the processing is necessary for responding to public health emergencies, or for the protection of life, health and property safety of natural persons under emergency circumstances;
      4. the personal data is processed within a reasonable scope to conduct news reporting, supervision by public opinion and other activities in the public interest;
      5. the personal data is made available to the public by you or the personal data about you from legitimate public sources is processed within a reasonable scope in accordance with the laws and regulations; or
      6. other circumstances as provided by the laws and regulations.
4. Your rights as the personal data subject
   
   
   1. Please refer to Clause 15 of the FTLife Privacy Policy Statement and the section of “Your rights” in the PICS in relation to your rights to access, correct your personal data and withdraw your consent. Further, in accordance with the applicable data protection laws and regulations in Mainland China, we will ensure that you may exercise the following rights over your personal data, including:
   1. You may request to delete your personal data if:
      1. our processing of your personal data breaches laws or regulations;
      2. we collect or use your personal data without your consent;
      3. our processing of your personal data breaches our agreement with you;
      4. you no longer use our products and/ or services, or the purposes described in Clause 3 of this Addendum have been achieved or accomplished;
      5. you withdraw your consent;
      6. we no longer provide products and/or services to you;
   2. Change the scope of your consent;
   3. Obtain a copy of your personal data; or
   4. Request to transfer your personal data to another personal data processor provided that such request is compliant with the applicable laws and regulations.
   2. Such requests shall be made to the Data Protection Officer of FTLife via the contact details set out in Clause 10 of this Addendum. We will endeavour to reply to your reasonable requests in relation to the above within fifteen (15) working days from the day we receive your request.
   3. However, please note we may refuse your requests under the following circumstances:-
   1. Circumstances relevant to the fulfilment of our obligations under laws and regulations, including our provision of your personal data (including your sensitive personal data) generated during the transaction between you and us to the regulatory authority(ies) and or other governmental departments under the laws and regulations of Mainland China;
   2. The data retention period required by any law or administrative regulation has not expired, or it is difficult to delete personal data technically (in such cases, we will take necessary security protection measures to ensure the security of your personal data or anonymize such personal data);
   3. Circumstances directly related to national security and defence security;
   4. Circumstances directly related to public security, public health, or significant public interest;
   5. Circumstances directly related to criminal investigation, prosecution and trial, and execution of court decision;
   6. Circumstances where we have sufficient evidence to prove that you have subjective malice, or you are abusing your rights;
   7. Circumstances where protection of your or other individual’s life, property and other important lawful rights is involved;
   8. Circumstances where responding to your request will cause serious harm to the lawful rights and interests of you or other individuals or organisations (including us); or
   9. Circumstances where trade secrets are involved.
5. Retention of personal data
   
   Your personal data will be kept by us for no longer than necessary for the fulfillment of the Purposes. Please refer to Clause 8 of the FTLife Privacy Policy Statement for further details.
6. How we entrust others to process, share, transfer and publicly disclose your personal data
   
   
   1. To achieve the Purposes under Clause 3 of this Addendum, you understand and agree that we may entrust the processing of your personal data (including sensitive personal data) to agents, contractors, vendors, suppliers and service providers as set out in Clauses 9 and 11 of the FTLife Privacy Policy Statement as well as the following parties:
      
      
      1. any insurance agent, broker, independent financial advisor acting on your behalf or your assignee, adjusters, employers, health care professionals, hospitals, accountants, financial advisors, solicitors, and/or organizations that consolidate claims and underwriting information for the insurance industry; fraud prevention organizations; other insurance companies (whether directly or through fraud prevention organization or other persons named in this paragraph), the police and databases or registers (and their operators) used by the insurance industry to analyse and check information provided against existing information) for any of the Purposes as set out in the PICS and Clause 3 above;
      2. loss adjusters, private investigators, letter shopping service providers, debt collectors, and any other agent, contractor or third party service provider, in each case, that provides risk intelligence, administrative, telecommunications, computer, Internet or payment services to FTLife for any of the Purposes as set out in the PICS and Clause 3 above;
      3. any actual or proposed reinsurers of FTLife for any of the Purposes as set out in the PICS and Clause 3 above;
      4. any person to whom FTLife is under an obligation or otherwise required to make disclosure under the requirement of any law binding on or applying to FTLife or any of its Affiliates, 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 financial services providers with which FTLife is expected to comply or any disclosure pursuant to any contractual or other commitment of FTLife with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Hong Kong and may be existing currently and in the future.
   2. The agents, contractors, vendors, suppliers, and/or other service providers and the parties as mentioned in Clause 6 a) of this Addendum entrusted by us have no authority to use your personal data for any other purposes. If there is any change to the purpose of processing of your personal data, we will ask for your consent again.
   3. Your personal data may also be shared with the New World Group and joint venture companies together referred to as “Affiliates” and our “Marketing Partners” (as defined in the PICS) located within or outside Mainland China, which include property developers, banks, financial and investment institutions, insurance companies, insurance brokerage companies, insurance corporate agencies, private clubs, concierge and customer service providers, retail outlets and online businesses (products and services including fashion and beauty, health and personal cares, luxury, home and living, food, wine and beverage, books and stationery), shopping malls, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, catering services providers, healthcare and senior care, services and/or products providers including health and wellness, art and culture, gallery and exhibition, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication, media and information technology, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, pre-school, primary, secondary and/or tertiary education institutions etc., the details of which are set out in Index 1 of this Addendum.
7. How we store and transfer your personal data
   
   In principle, we collect, produce and process the personal data in the PRC in accordance with the business purposes set out in Clause 3 of this Addendum and they will be stored in various geographical locations including Mainland China, Hong Kong and Singapore. You understand, authorise and consent that we may transfer your personal data outside Mainland China to our headquarters in Hong Kong, our Affiliates, Marketing Partners and other entities outside Mainland China (please refer to Index 2 of this Addendum for further details), and to the servers and/or data centres in various geographical locations including Mainland China, Hong Kong and Singapore of our partners, co-operators, agents, contractors, vendors, suppliers, service providers and other parties set out in Clause 6(a) above whom we have entrusted to process your personal data (please refer to Index 3 of this Addendum for further details), or New World Development Company Limited and New World Corporate Services Limited may access your personal data from Hong Kong, due to business needs and solely for achieving the business purposes set out in Clause 3 of this Addendum and to the maximum extent permitted by law and in accordance with the mandatory requirements under the laws and regulations of the PRC. The relevant jurisdictions including Mainland China, Hong Kong and Singapore have enacted personal data protection laws, and we will also ensure that your personal data is adequately protected in accordance with this Addendum. If you would like to learn more about the storage and cross-border transfer of your personal data, withdraw your consent and/or exercise your other rights in accordance with Clause 4 of this Addendum, please contact us via the means set out in Clause 10 of this Addendum and we will respond to your request to a reasonable extent.
   
   We will not transfer your personal data to any company, organisation or individual outside of NWG, its Affiliates and/or Marketing Partners, except under the following circumstances:
   
   
   1. Transfer with separate consent. After obtaining your separate consent, we will transfer your personal data to other parties in accordance with this Addendum;
   2. When we are involved in any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer or purchase of FTLife’s business (please refer to Clause 18 of the FTLife Privacy Policy Statement and the section of “Those with whom we share personal data” in the PICS);
   3. We may otherwise transfer your personal data in accordance with applicable laws and regulations, requirements under legal proceedings, compulsory administrative or judicial requirements.
8. How we process minors’ personal data
   
   
   1. We generally do not directly collect personal data of persons who are below the age of eighteen (18) unless it is necessary for the provision of products or services and it is agreed by their parents or guardians (for example, where the minors are the beneficiaries of the insurance products purchased by their parents).
   2. If you are under the age of eighteen (18), you should read this Addendum, the PICS and the FTLife Privacy Policy Statement as well as Annex A to this Addendum (“Annex A”) together with your parents or guardians and agree to the terms thereof and obtain consent from your parents or guardians before submitting any personal data to us or using any of our products or services. Generally speaking, we will only accept your personal data or your request to use our products or services submitted via your parents or guardians.
   3. If you are the parent or guardian of a minor under the age of eighteen (18), you should carefully read and agree to this Addendum, the PICS and the FTLife Privacy Policy Statement as well as Annex A before submitting any personal data of the minor or using our products or services for the minor. If you are aware that we have collected personal data of your child who is below the age of eighteen (18) without your consent, please notify us immediately via contact details set out in Clause 10 of this Addendum, so as to allow us to take effective measures to delete such data as soon as practicable.
   4. For the minors’ data collected by us, we will only use or disclose such data to the extent allowed by the applicable laws and regulations or expressly consented to by their parents or guardians, or where required for protecting the interests of the minors.
9. Miscellaneous
   
   The section of “Miscellaneous” in the PICS shall apply in respect of the update of this Addendum.
   
   Further, the following Clauses in the FTLife Privacy Policy Statement shall apply:-
   
   
   1. Clause 4 shall apply in respect of the use of cookies and other tracking mechanisms;
   2. Clause 12 shall apply in respect of the security of personal data;
   3. Clause 13 shall apply in respect of liability exclusion for disclosure of your personal data, which will be subject to the applicable laws and regulations in Mainland China.
   4. Clause 17 shall apply in respect of the update of the FTLife Privacy Policy Statement and this Addendum.
10. How to contact us
    
    If you have any questions, comments or suggestions regarding this Addendum, or wish to exercise your rights over your personal data in accordance with the FTLife Privacy Policy Statement, the PICS or this Addendum, please feel free to contact our Data Protection Officer, FTLife Customer Service Centre, FTLife Insurance Company Limited at FTLife, 7/F, NEO, 123 Hoi Bun Road, Kowloon, Hong Kong SAR or email us at csc@ftlife.com.hk (marked Confidential).
11. Inconsistency or conflict
    
    If there is any inconsistency or conflict between the English and Chinese versions of this Addendum, the English version shall prevail.
Index 1,2 and 3

Index 1: https://www.ftlife.com.hk/en/disclaimer/prcaddendum/appendix1/



Index 2: https://www.ftlife.com.hk/en/disclaimer/prcaddendum/appendix2/



Index 3: https://www.ftlife.com.hk/en/disclaimer/prcaddendum/appendix3/



Annex A to this Addendum

Annex A to this Addendum: https://www.ftlife.com.hk/en/disclaimer/prcaddendum/annexA/