Personal Information Collection Statement
At FTLife Insurance Company Limited (“FTLife”, “we”, “us” or “our”), we hold as one of our core values the protection of privacy of our customer’s personal data. As a provider of insurance products and services, collection and use of personal data of our customers is at the heart of our business. FTLife respects the privacy of your personal data and are committed to fully complying with the Personal Data (Privacy) Ordinance (Cap. 486). This Personal Information Collection Statement (this “Statement”) is made by FTLife, and applies between us and you (“you”, or “your”). This Statement should be read together with the terms and conditions (if any) of any instrument, documentation, form (the “Documentation”) and/or software application (the “Application”) (as applicable), and the website at https://www.ftlife.com.hk (the “Website”) that refers to and/or contains this Statement (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.
FTLife is a related company of the New World group of companies including New World Development Company Limited (“NWD”) and its affiliated or related companies from time to time (the “New World Group”, or “NWG”) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, loyalty programmes, department stores, jewelleries and luxury products, e-commerce, hospitality services, food and beverages, convention and exhibition centres, sports and recreational facilities, education, health care and senior care, other health and wellness products and services, financial services and insurance, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), corporate innovation, accelerator and incubation programmes, organization of competitions, conferences and events, start up and social innovation programmes and charitable pursuits including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion, and other purposes that are beneficial to the community (the “Goods and Services”) (the New World Group and joint venture companies together referred to as “Affiliates”).
In order to enable us to perform the Purposes (as defined in the “Purposes for using personal data collected” section below), you are required to provide all the requested/mandatory personal data in the Documentation, the Application, and/or the Website (as applicable) that refers to and/or contains this Statement. If you do not provide the required personal data, then we may not be able to perform the Purposes and/or provide goods or services to you.
Kinds of personal data collected
Purposes for using personal data collected
The personal data to be collected from you and/or from other sources as mentioned below in this Statement will be used and retained by us (and/or our Affiliates and/or our Marketing Partners as defined in the “Direct Marketing” section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):
- Administration of insurance or reinsurance related business, which includes underwriting, processing and evaluation of applications, identity and credit checking, suitability checking, policy servicing, collateral assignment arrangement (e.g. for premium financing purpose), claims processing, claims investigation, claims settlement, fraud detection and prevention (whether or not relating to the policy issued in respect of this application), account/debt collection, litigation, communications, preparing statistics, data analysis and research, internal and external audit, maintaining quality services, sales and marketing, corporate brand building and customer loyalty building;
- Identifying and verifying your identity and/or as a member;
- Registering you as a user of the Application and/or the Website (as the case may be);
- To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Application and/or the Website (as the case may be);
- Following registration as a user, accessing your account information (including, but not limited to, your name, membership number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
- Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour (subject to your consent for direct marketing, if/where applicable) to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining;
- For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
- Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
- Improving the Documentation, the Application and/or the Website, the Purposes, and our and our Affiliates’ and Marketing Partners ‘Goods and Services;
- Direct marketing and cross-marketing for the Marketing Subjects, subject to consent (see below section entitled “Direct marketing”);
- Data analytics, profiling, information management and database administration;
- Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal;
- Compliance with the obligations, requirements or arrangements for disclosing and using data that apply to FTLife or with which it is expected to comply according to:
- any law binding or applying to it within or outside Hong Kong existing currently and in the future;
- 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 Hong Kong existing currently and in the future; and
- 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.
- Collection or recovery of any debt owed by you to us or our Affiliates;
- The normal management, operation, and maintenance of the Application and/or the Website and the provision of the Goods and Services to you;
- Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above (and subject to your consent in the event that transfer to any or all such data transferees for direct marketing are involved); and/or
- Other purposes ancillary or related to the above.
The personal data you provide to FTLife will be kept confidential, except that it may be disclosed/shared with the following parties:
- 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;
- 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;
- any actual or proposed reinsurers of FTLife for any of the Purposes;
- 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.
Your personal data may be transferred to and/or stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with our Affiliates and/or our Marketing Partners (see below) located within or outside Hong Kong. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the country or place in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates and our Marketing Partners (see below) do the same.
Subject to your consent, we may use your personal data to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future.
Subject to your consent, we may also use your personal data for, or provide your personal data to, our Affiliates and/or our Marketing Partners (see below) so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, and/or other media whether now known or available in the future.
Our “Marketing Partnersinclude 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.
As we may share your personal data with our Affiliates and/or our Marketing Partners, we may also receive your personal data from them. Subject to your consent given to our Affiliates and/or our Marketing Partners, we may also use such personal data to send you direct marketing about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects (see below).
The types of products, services, events and charitable initiatives that we, our Affiliates and/or our Marketing Partners may market to you include the following (together, the “Marketing Subjects”):
- goods and services offered by us and/or our Affiliates in relation to the Goods and Services;
- finance, banking, securities, mortgage, insurance and other related services and products by banks, financial and investment institutions, securities companies and insurance companies;
- access and privileges at private clubs;
- professional consultation on customer services, including but not limited to event planning, holidays, hotels, travel, and tickets reservation;
- consumer products and services by retail outlets and/or online businesses, including clothing, shoes, fashion, fashion accessories and beauty,health and personal cares, luxury, home and living, household products, food, wine, liquor and beverages, confectionary, groceries, books and stationery, toys, cigarettes and cigars, fragrances and cosmetics, baby products, telephones and mobile devices, electronics and electrical appliances, computer software, and games, bags and luggage, furniture, sports and leisure equipment;
- pharmaceutical products, medical and pharmaceutical services, therapeutical products and services, and therapy services by therapists;
- tutoring, mentoring, home cleaning, janitor services, landscape and plant maintenance services, agricultural services, part time housekeeping,plumbing services, locksmiths, barber and salon services, gym and fitness services, laundry services, florists, vehicle towing, and motor vehicle services;
- reward, loyalty, privileges programmes and promotions at shopping malls and department stores;
- reward, loyalty, privileges programmes and promotions for customers and/or potential customers of the New World Group;
- watches, jewelleries and accessories;
- restaurants, catering services on food, wine and beverage;
- travel, hospitality and accommodation services and products, including but not limited to hotels and serviced apartments, holiday package products and services offered by travel agents, tickets to attractions;
- transportation and logistics services, including but not limited to air travel and non-air transportation services such as hotel transfers, car rentals, bus operators, train operators and cruise operators, and courier services and shipping services ;
- conference and exhibition management services, consultancy and marketing research services, supply chain management, event and project management services, gaming services, advertising and public relations services, media production services;
- tickets for concerts, galleries, exhibitions, films, theatricals, sporting, special and cultural events;
- green and nature activities;
- technology, telecommunication, internet and mobile communication services, social networking and media;
- graphic and interior design services, photography services, printing and publishing services;
- legal services, medical services, accounting, auditing, bookkeeping and taxation services, engineering services, architectural services, surveying services, equipment rental services, hospitality services;
- professional advice and/or consultation on education and/or personal enhancement;
- charitable initiatives which support areas including sports, recreation, art and cultural programmes, relief of poverty, advancement of education,advancement of religion and other purposes that are beneficial to the community.
- Apart from your right to opt out of direct marketing as mentioned above, you have the following additional rights to check whether we hold any of your personal data;
- access your personal data held by us;
- require us to correct any personal data which is inaccurate; and
- ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.
- our collection and/or use of Log Files (data relating to your use of/visits to the Application and/or the Website (as the case may be), including but not limited to your IP address, domain name, browser type and access time);
- retention of your personal data;
- third party merchants and/or websites that may be contained in the Application and/or the Website (as the case may be);
- how we keep your personal data secure;
- use of your personal data in legal proceedings.
If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.
This Statement may be updated from time to time to reflect changes to our policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application and/or the Website (as the case may be) for updates to this Statement on a regular basis.
Nothing in this Statement shall limit your rights under the PDPO.
If you are:
(i) 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
(ii) 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,
This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.