Annex A to the Addendum –
Rules on processing minors’ personal data (hereinafter “Annex A”)
This Annex A provides the rules of FTLife Insurance Company Limited’s (“FTLife”, “we”, “us” or “our”) activities in processing personal data of persons aged below eighteen (18) who are:
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
holding Mainland China passports and/or resident identity cards who visit the service centres or other physical premises of FTLife in Hong Kong or otherwise use FTLife’s products and/or services by phone or any other means in Hong Kong.
(The aforesaid persons aged below eighteen (18) hereinafter referred to as “Minor”, “Minors” or “Minor(s)”.)
2. Personal data
Clause 2 of the Addendum applies, save and except that the “sensitive personal data” involved in this Annex A includes all Minors’ sensitive personal data.
3. How we collect and process Minors’ personal data
The following shall apply to how we collect and process Minors’ personal data:
Minors’ personal data shall only be provided to us upon the consent of Minors’ parents or legal guardians. If the Minors’ parents or legal guardians subsequently withdraw the consent, they and the Minors shall immediately cease the provision of Minors’ personal data to us.
If Minors’ parents or legal guardians become aware that, without their consent, Minors under their care have provided personal data to us, please notify us to delete them by contacting our Data Protection Officer of FTLife via the contact details set out in Clause 10 of the Addendum.
Minor’s personal data will be processed by us for the purposes as further specified below only (“Purposes for Minors”). In particular, in order for us to carry out the Purposes for Minors, the personal data set out below is necessary. If such information are not available or not accurate, we may not be able to perform the Purposes for Minors:
|No.||Purposes for Minors||Minors’ personal data that we may collect|
|1||Administration of insurance or reinsurance related business, which includes processing and evaluation of applications, identity checking, claims processing, claims investigation, preparing statistics, data analysis and research||
|2||Data analytics, profiling, information management and database administration||
In general, we process Minors’ personal data with their parent’s or legal guardian’s consent, and, where appropriate, with separate consent from their parents or legal guardians for processing Minors’ personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. Besides, disclosure of Minors’ personal data as above mentioned will be conducted in accordance with the applicable data protection laws and regulations in Mainland China.
4. Minors’ rights as the personal data subjects
Clause 4 of the Addendum applies to the extent that you as the parents or legal guardians of the Minor(s), may exercise the Minor(s)’ rights as provided therein on their behalf.
5. Retention of personal data
Clause 5 of the Addendum applies only to the extent for the Purposes for Minors and save and except that Minors’ personal data collected and processed for the purposes of Clause 3 of this Annex A will not be stored in our systems and shall be deleted and/or anonymized (as the case may be) once the said purposes have been achieved.
In addition, we strictly control the access to Minors’ personal data and only allow authorized personnel that are strictly necessary to process Minors’ personal data to access such data.
6. How we entrust others to process, share and transfer Minors’ personal data
any insurance agent, broker, independent financial advisor acting on your/Minor’s behalf or your/Minor’s 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 for Minors as set out in Clause 3 of this Annex A above;
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 for Minors as set out in Clause 3 of this Annex A above;
any actual or proposed reinsurers of FTLife for any of the Purposes for Minors as set out in Clause 3 of this Annex A above;
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.
The agents, contractors, vendors, suppliers and/or service providers and other entities entrusted by us have no authority to use Minors’ personal data for any other purposes. If there is any change to the purpose of processing of Minors’ personal data, we will ask for the consent of Minors’ parents or legal guardians again and, where appropriate, with separate consent from their parents or legal guardians for processing Minors’ personal data under specific circumstances.
7. How we store and transfer Minors’ personal data
In principle, we collect, produce and process the Minors’ personal data in the PRC in accordance with the Purposes for Minors set out in Clause 3 of this Annex A 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 the Minor’s personal data outside Mainland China to our headquarters in Hong Kong, 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 Minors’ personal data (please refer to Index 3 of the Addendum for further details), due to business needs and solely for achieving the business purposes set out in Clause 3 of this Annex A 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 Minors’ personal data is adequately protected in accordance with the Addendum and this Annex A. If you would like to learn more about the storage and cross-border transfer of Minors’ personal data, withdraw your consent and/or exercise other rights of Minors in accordance with Clause 4 of this Annex A, please contact us via the means set out in Clause 10 of this Annex A and we will respond to your request to a reasonable extent.
We will not transfer Minors’ personal data to any company, organisation or individual, except under the following circumstances:
Transfer with separate consent. After obtaining your separate consent, we will transfer Minors’ personal data to other parties in accordance with the Addendum and this Annex A;
We may otherwise transfer Minors’ personal data in accordance with applicable laws and regulations, requirements under legal proceedings, compulsory administrative or judicial requirements.
8. This paragraph is intentionally left blank
Clause 9 of the Addendum applies.
10. How to contact us
Clause 10 of the Addendum applies to the extent that you as the parents or legal guardians of the Minor(s) may contact us or exercise the Minor(s)’ rights over their personal data as provided therein.
11. Inconsistency or conflict
Clause 11 of the Addendum applies.