Liberty International Insurance Limited (referred to hereinafter as the “Company”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”). The Company will take all practicable steps to ensure the security of the Personal Data and to avoid unauthorised or accidental access, erasure, or other use.
For the purpose of this Statement, "Personal Data" means any data:
- relating directly or indirectly to a living individual
- from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
- in a form in which access to or processing of the data is practicable
The Company’s products and services are intended for persons residing in Hong Kong and all payments are made in Hong Kong Dollars. The Company does not intend to or knowingly collect, hold, process, use or transfer Personal Data of any individual living within the European Union (“EU”) or monitor the behaviour of any EU-based individuals.
From time to time it is necessary for the Company to collect, or be provided by your agents and/or representatives, your Personal Data (including personal information such as but not limited to your credit, motor and health records and insurance claims history) such as Personal Data of our customers (including but not limited to our online account holders, policy owners, insureds, trustees, policy assignees, claimants, and beneficiaries) collected, transferred to or held by the Company which may be used, stored, processed, transferred or disclosed or shared by us for the following obligatory and other purposes (“Purposes”), such as:
- offering, providing and marketing to you the products/services of the Company, including related companies of the Company (“our affiliates”) or our business partners (see “Direct Marketing” below), and administering, supporting, maintaining, managing and operating such products/services including policies and handling your mobile and internet accounts
- Processing and determining any insurance applications, requests, insurance claims and providing ongoing insurance services
- Processing requests for payment and for direct debit authorisation including evaluating your financial needs
- Managing, investigating and analysing any claim, action and/or proceedings made by or against or otherwise involving you, and to exercise the Company’s rights as more particularly defined in the applicable policy wording, including but not limited to subrogation rights
- Compiling statistics or using for accounting purposes
- Meeting disclosure requirements of any local or foreign law, regulations, codes or guidelines binding on the Company, its parent and affiliated companies (“Liberty Mutual Group of Companies”)
- Complying with the legitimate requests or orders of the courts of Hong Kong Special Administrative Region and regulators including but not limited to the Insurance Authority, Hong Kong Federation of Insurers, auditors, governmental bodies and governmental-related establishments binding the Liberty Mutual Group of Companies
- Enabling an actual or proposed assignee of the Company to evaluate the transaction intended to be the subject of the assignment
- Conducting identity and/or credit checks and/or debt collection
- Conducting medical or health reference checks for relevant insurance products
- For the management of the IT environment and business operation
- Ensuring the security of our IT environment
- Detecting and investigating illegal activity, including fraud, money laundering or terrorism financing (whether such detecting and investigating is in relation to an application or insurance policy of the Company)
- Comply with legal, regulatory and other good governance obligations, including responding to requests from public and governmental authorities (including those outside your country of residence) or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere
- For monitoring and assessing compliance with the Company and Liberty Mutual Group of Companies policies and standards
- Achieve other legitimate business purposes, for example, to carry out insurance surveys, research, and analysis, including analysis of our customer base and other individuals whose personal information we to analyse behaviour, preferences, and interests, develop new products, improve our services, identify usage trends, understand the interests of our users, to plan and execute business transactions (including joint ventures and business sales) and for other legitimate business purposes
- Establishing, exercising or defending legal rights of any member of the Liberty Mutual Group of Companies
- assisting financial institutions with interests related to you and/or the products/services you have with the Company including enabling an actual or proposed assignee/mortgagee to evaluate the transactions you have with the Company intended to be the subject of the assignment/mortgage
- to facilitate authorised service providers to provide services to the Company and/or the customers for the above Purposes
- Providing third-party administration services and carrying out other services in connection with the operation of the Company’s business
- Facilitating the Company’s authorised service providers to provide services to the Company and/or customers for the above purposes
- Other purposes directly relating to any of the above; and
- Any other purposes we notify you at the time of obtaining your consent
Please note that if you do not provide us with your Personal Data, we may not be able to issue your policy, process claims, or provide insurance products or services to you or process your request.
Please also ensure that you provide complete and accurate Personal Data to us and keep us updated on any changes to your Personal Data. Kindly note that if you do not provide complete and accurate personal information to us as and when it is required, it may have adverse consequences for you.
Your Personal Data collected or held by the Company, in particular, names and contact information such as telephone number, email address and postal address may be used by the Company and/or the Liberty Mutual Group of Companies to provide marketing materials and conduct direct marketing activities (including but not limited to promoting, marketing or selling of the Company, Liberty Mutual Group of Companies or co-branded insurance or financial or investment-related products or services by electronic or other means) in relation to insurance and/or financial products and services of the Company, the Liberty Mutual Group of Companies and/or other financial services providers.
This may include the use of your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by the Company from time to time for direct marketing and to conduct direct marketing (including but not limited to providing reward, loyalty or privileges programmes of products and services that the Company, our affiliates, Liberty Mutual Group of Companies, our co-branding partners and our business partners may offer.
If you do not consent to receive such marketing communications, you may at any time withdraw your consent to the use and provision of your Personal Data for direct marketing by downloading the form below.
In the absence of any “opt-out” request from the customer, the Company shall treat the application and continuation of his/her policy(ies) held with the Company as an indication of no objection to the Company’s use of such Personal Data for this voluntary marketing purpose.
Transfer of Personal Data
Your Personal Data will be kept confidential and may be held or stored locally, regionally, or globally, whether in Hong Kong or out of Hong Kong.
Subject to the provisions of any applicable law, we may need to disclose your Personal Data to third parties, whether located within or outside Hong Kong for one or more of the above Purposes.
Your Personal Data may be made available to:
- Our Liberty Mutual Group of Companies: Other Liberty Mutual affiliates may have access to and use of Personal Data in connection with the conduct of our business where appropriate in order to fulfill one or more of the above Purposes.
- Our Liberty Mutual Group of Companies, or any other company carrying on insurance or reinsurance related business, or an intermediary
- Our Service Providers: External third-party service providers such as but not limited to agent, contractor, banker or third-party service provider who provides administrative, telecommunications, computer, payment, banking or other services to the Company in connection with the operation of its business and Liberty Mutual affiliates in a service provider role, such as accountants, auditors, lawyers and other outside professional advisors; call-center service providers; IT systems and management, IT support and security service providers; cloud providers, research and analytics service providers; claim investigators and adjusters; and similar third-party service providers that assist us in carrying out business activities
- Other Third-Parties Service Providers including brokers; employers; healthcare professionals; hospitals; organisations that consolidate claims and underwriting information for the insurance industry; fraud prevention organisations; other insurance companies (whether directly or through fraud prevention organisation or others named herein), the police and databases or registers (and their operators) used by the insurance industry to analyse and check information provided against existing information; legal advisors, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, emergency assistance companies, medical doctor panel groups, medical advisory consultants, surveyors, specialists, repairers, accountants, financial institutions, and data processors including any interested parties with legitimate legal and/or beneficial interests in your policies, the subject matter of your policies, and/or the products/services you have with the Company
- Other Third-Parties: To a third-party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); to reinsurance companies
- Credit reference agencies, financial institutions, and in the event of default, any debt collection agencies or companies carrying on claim or investigation services
- Any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or any of its associated companies for the purposes of any regulations, codes or guidelines issued by governmental, regulatory or other authorities with which the Company or any of its associated companies are expected to comply
- Any person pursuant to any order of a court of competent jurisdiction
- Any actual or proposed assignee of the Liberty Mutual Group of Companies or transferee of the Liberty Mutual Group of Companies’ rights in respect of the policy owners
- Supplied to the Data Center of Liberty Mutual Group of Companies or Liberty Mutual Group of Companies in the USA may host such respective servers or may utilise third-party servers which Liberty Mutual Group of Companies would be the controller for processing, storage, and/or backup of Personal Data. Such Data Centers and/or servers are/may be located in Singapore, elsewhere in Asia, the United States of America, Europe, and Latin America or such other countries/territories as determined by the Liberty Mutual Group of Companies from time to time
- Providers of risk intelligence for the purpose of customer due diligence or anti-money laundering screening
- Other banking/financial institutions, commercial or charitable organisations with whom the Company maintains business referral or other arrangements for marketing communication if “no objection” is provided
- Third-party marketing service providers and insurance intermediaries for marketing communication if “no objection” is provided.
- Made available to any actual or proposed purchaser of Company business or, in the case of a merger, acquisition or other public offerings, the purchaser or subscriber for shares in Liberty Mutual Group of Companies
- Supplied to an organisation involved in maintaining, reviewing and developing our business systems, procedures, and infrastructure including testing or upgrading our computer systems
- Provided to your representatives including your legal advisers
- Made available to anyone to whom you have given your consent
- Made available to other Company’s authorised service providers to provide services to you for the above purposes for which the Personal Data are to be used
- As we believe to be necessary or appropriate: To comply with legal process, to respond to requests from public and government authorities including public and government authorities outside your country of residence, to enforce our terms and conditions, to protect our operations, to protect our rights, privacy, safety or property, and/or that of you or others; to detect and prevent fraud, and to allow us to pursue available remedies or limit the damages that we may sustain
Data Processing Outside Hong Kong
We may share Personal Data with one or more of our affiliated Liberty Mutual Group Companies, service providers, or with third parties for the Purposes described above. Some of these affiliated companies, service providers, and third parties may be based in other countries and may not be subject to the laws of Hong Kong.
Access and Correction of Personal Data
According to the Ordinance, you have the right to ascertain whether the Company holds your Personal Data, to access, obtain, correct and/or change any of your Personal Data held by the Company by contacting the Company’s Personal Data Privacy Officer. Requests for access and correction or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:
Data Privacy Officer
Liberty International Insurance Limited
13/F Berkshire House
25 Westlands Road
Quarry Bay, Hong Kong
using the Data Access Request Form found at:
In accordance with the Ordinance, a reasonable fee may be charged by the Company to offset the Company’s administrative and actual costs incurred in complying with your data access requests.
In the event of any discrepancy or inconsistencies between the English and Chinese versions of this notice, the English version shall prevail.