Privacy Policy
Effective date: June 2023
General policy statement
We pledge to meet fully data privacy protection requirements in accordance with the Personal Data (Privacy) Ordinance of Hong Kong. In doing so, we will ensure compliance by our staff or agents with the strictest standards of security and confidentiality.
This website may contain hyperlinks to other websites in which different privacy policies may apply. You should be fully conversant with such privacy policies before you release your personal data in such websites.
Data collection and use
Personal data is collected from our users on a voluntary basis. Personal data may include name, address, telephone number, fax number, e-mail address etc. The information is used by us for the purposes stated on the respective screens on which we request for the provision of your personal data. Refusal to supply personal data may result in us being unable to process the request. Personal data will not be used for any other purposes without your consent unless such use is permitted or required by law.
Technical data
When you visit our website, we automatically collect metadata about your browsing session such as your browser, your internet service provider, the site from which you navigate to this website, the duration of your visit to this website, your browser location data and what type of device you are using (e.g. a computer, a smart phone or a tablet and the respective operating system). A record of your visit is made as a "hit" that shows your Internet Protocol Address and the pages you have visited. No personally identifiable information is collected from you. The "hit" information allows us to compile statistics about the number and types of visitors to our website.
Cookie or similar technology like Google Analytics, Google Signals, Adobe Analytics or Webtrends may be used in our website for the purposes of website improvement.
Retention and accuracy
Personal data collected is retained for such period as may be necessary for the proper discharge of our services and to comply with various legal requirements.
Security
We have in place additional security measures for all personal data you provide to us from any misuse and unauthorized access. Access is limited to our authorized staff or agents. Staff or agents designated to handle personal data will be made acquainted with this Privacy Policy Statement and told how to fulfill our obligations to you. However, we do not encrypt any information transmitted online.
Direct marketing
From time to time, we may conduct direct marketing of our products or services via fax, e-mail, direct mail, telemarketing and/or other forms of communication you submit to us for such purposes. We are not allowed to use or transfer to others your personal data for direct marketing purposes without your consent. By providing us your personal data in response to our requests for direct marketing purposes, you consent to your personal data so provided being used or transferred to a third party by us for such specified purposes.
You may choose to opt out from our marketing lists via writing to customer@hk.zurich.com.
Access, correction and enquiries
If you wish to request access to or correction of your personal data held by us and/or make any enquiries about our privacy policy and practices, you may do so by addressing to:
Personal Data Privacy Officer
26/F, One Island East,
18 Westlands Road, Island East,
Hong Kong
Cookies
Cookies are small data files that contain and collect data. Typically, they are sent by a website, like ours, and stored on the user's computer. Whenever the user requests a page from the website, the cookies are sent back to the site. We do not use cookies without your knowledge to get your e-mail address or other personal information.
Our aim is to use cookies on this site responsibly as a way to better serve you:
- So you don't have to identify yourself every time you re-enter our website
- To personalize our website so as to save you time
- To determine previous or subsequent sites visited by those visiting our site
- To determine which parts of our website are of most use to our visitors and customers and thus improve them accordingly
If you have provided us with personal information on this site, this information may be linked with the data stored in the cookie so we are able to serve you as described above.
You have a choice on cookies
If you prefer not to receive cookies or be alerted each time a cookie is sent, you can set your web browser accordingly. If you disable cookies, you should be able in most cases to visit and make use of our website. But you may be unable to benefit from some of our site's features or functions and your visit may be less speedy.
Job application
If you apply for a job vacancy with our website you will automatically be navigated to an IT-infrastructure independent of this website. The job application process is subject to separate privacy rules than those of our website. They are automatically displayed when you apply online.
Links to external websites and social media plugins
This website may contain hyperlinks to other websites in which different privacy policies may apply. You should be fully conversant with such privacy policies before you release your personal data in such websites. We are not responsible for the privacy practices of such other websites.
This website uses social media plugins. They are displayed with the logo of the corresponding social network. If you are logged into a social network (with your user credentials) when you visit this website, the respective network will automatically be notified of your visit to this website. The data processing associated with social media plugins is the responsibility of the respective social media network, and is subject to their privacy policies and outside our control.
Notice to customers relating to the Personal Data (Privacy) Ordinance (“Ordinance”)
Effective date: December 2019
1. The personal information of customers (including policyholders, insured persons, beneficiaries, premium payors, trustees, policy assignees and claimants) collected or held by Zurich Insurance Company Ltd ("Company") from time to time, which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer (such as claim information and medical history received from third parties), may be used by the Company and/or a company within its group (“Zurich Insurance Group”) for the following purposes necessary in providing services to the customers (“necessary purposes”) (otherwise the Company is unable to provide services to customers who fail to provide the required information):
a) to process, investigate (and assist others to investigate) and determine insurance applications, benefits and claims, perform reinsurance arrangements and provide ongoing services;
b) to manage any claim, action and/or proceedings brought by or against or otherwise involving the customers, and to exercise the Company’s rights as more particularly defined in applicable policy wording, including but not limited to the subrogation right;
c) to process requests for payment, and for direct debit authorization;
d) to provide subsequent services and administer the policies issued, such as to arrange medical examination, process additions, alterations, variations, assignments, cancellation, renewal or reinstatement of the relevant policies;
e) to compile statistics or database or conduct market or actuarial research or insurance surveys or perform customer analysis, profiling and segmentation undertaken by the Company and/or a company within the Zurich Insurance Group, respective regulators or industry recognized bodies, or to enhance existing or design new products and services of the Zurich Insurance Group, or for customer relationship building;
f) use for accounting and actuarial purposes;
g) to enable the Company and/or any company within the Zurich Insurance Group to fulfill any services or contract of insurance that a customer has requested, and/or to form a single overall view of the customer’s relationship with the Zurich Insurance Group and of the customer’s record, such as underwriting and claims history, for present and future reference in processing, assessing, determining and investigating insurance applications, benefits and claims, administering the customer’s policy, performing reinsurance arrangements and providing ongoing services;
h) to meet the disclosure requirements of any local or foreign law, rules, regulations, codes or guidelines binding on the Zurich Insurance Group and conduct matching procedures where necessary;
i) to comply with the requirements, orders or legitimate requests of, or contractual or other commitment or arrangement with the courts of Hong Kong, local and foreign regulators, tax or law enforcement authority, self-regulatory or industry recognized bodies such as federations or associations of insurers or financial services providers, including but not limited to the Insurance Authority, Hong Kong Federation of Insurers, auditors, credit reference agencies, governmental bodies and government-related establishments;
j) to collect (and assist other companies within the Zurich Insurance Group to collect) debts;
k) to prevent and detect (and assist other companies within the Zurich Insurance Group to prevent and detect) fraud;
l) to facilitate the Company’s authorized service providers to provide services to the Company and/or the customers for the above purposes;
m) to enable an actual or proposed assignee of the Company to evaluate the transaction intended to be the subject of the assignment; and
n) to fulfil any other purposes directly related to any of the above purposes.
2. The Company may provide any personal information of customers to the following parties, within or outside of Hong Kong, for the necessary purposes:
a) companies within the Zurich Insurance Group, any other company carrying on insurance or reinsurance related business, an intermediary, or an industry recognized body;
b) any agent, contractor or third party service provider who provides administrative, telecommunications, technology, computer, payment, policy administration, support, storage, cloud, record management, call center, mailing and printing, data processing, customer satisfaction analysis, outsourcing or other services to the Zurich Insurance Group in connection with the operation of its business;
c) third party service providers including insurers, bankers, legal advisors, accountants, fund management companies, financial institutions, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, hospitals, surveyors, specialists, repairers, emergency service providers, research and analysis companies and data processors;
d) credit reference agencies, and, in the event of default, any debt collection agencies or companies carrying on claim or investigation services;
e) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on the Zurich Insurance Group or any of its associated companies and for the purposes of any regulations, codes or guidelines issued by local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities with which the Zurich Insurance Group or any of its associated companies are expected to comply;
f) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities that is assumed by or imposed on the Zurich Insurance Group or any of its associated companies;
g) any person pursuant to any order of a court of competent jurisdiction;
h) organizations that consolidate claims and underwriting information for the insurance industry, fraud prevention organizations, employers, the police and databases or registers (and their operators); and
i) any actual or proposed assignee of the Zurich Insurance Group or transferee of the Zurich Insurance Group’s rights in respect of the policyholders.
3. Certain personal information of policyholders and insured persons collected or held by the Company from time to time (which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer), in particular, names, contact information, age, gender, identity document reference, marital status, financial background, demographic data, transaction pattern and behavior, policy information, claim information, and medical history may be used by the Company for the following marketing-related purposes (“marketing purposes”):
a) to provide marketing materials and conduct direct marketing activities in relation to insurance and/or financial products and services of the Zurich Insurance Group and/or other financial services providers, and/or other related services of business partners, with whom the Company maintains business referral or other arrangements (such as reward, loyalty, co-branding or privileges programs and related services and products, services and products offered by the Company’s business or co-branding partners, donations or contributions for charitable and/or non-profit making purposes).
The Company may use the personal information of any customer for the marketing purposes only with such customer’s consent. In the absence of any “opt-out” request, the Company shall treat the insurance application and continuation of the policy(ies) held with the Company as an indication of no objection of such policyholder and insured person to the Company’s use of their personal information for the marketing purposes. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time.
4. The Company may provide certain personal information, in particular, name, contact information, age, gender and policy information of a policyholder and an insured person, upon such policyholder’s and insured person’s written consent, to be used by the following parties, within or outside of Hong Kong, for their own and/or the Company’s marketing purposes:
a) companies within the Zurich Insurance Group;
b) other banking/financial institutions, commercial or charitable organizations with whom the Company maintains business referral or other arrangements;
c) third party reward, loyalty, co-branding or privileges program providers;
d) third party marketing-related service providers and insurance intermediaries.
The Company is not allowed to provide to any third party the personal information of any customer, specifically, policyholders or insured persons, for the marketing purposes without their written consent. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time. The Company may receive money or other property in return for providing the personal information to the parties set out in paragraph 4(a) to (d) above.
5. Customers’ personal information may from time to time be provided to any of the parties set out in paragraph 2 (and paragraph 4 for customers who consented to the marketing purposes) above (including cloud providers) which may be located in Hong Kong or elsewhere for necessary purposes (and marketing purposes for customers who have given their consent) and in this regard customers consent to the transfer of their personal information outside Hong Kong and understand that their personal data may not be protected to the same or similar level compared to Hong Kong.
6. All customers have the right to access, correct, or change any of their own personal information held by the Company, and in the case of policyholders and insured persons, opt-out of the Company’s use and transfer of their personal information for the marketing purposes, by request in writing to the Company’s Personal Data Privacy Officer at the address below. Requests for opt-out must state clearly the full name, identity document number, policy number, telephone number and address of the person making such request.
Personal Data Privacy Officer
26/F, One Island East
18 Westlands Road
Island East
Hong Kong
7. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for processing any data access request.
8. In the event of any discrepancy or inconsistencies between the English and Chinese versions of this notice, the English version shall prevail.
9. The Company reserves the right to change or update this Notice at any time without prior notice. The changes or updates will be notified to customers on Company’s website or in writing (which may include electronic format) and any such change or update will be effective immediately upon posting. The continuation of insurance or other business relationship with the Company signifies a customer’s agreement to the changes and updates in relation to the uses of such customer’s personal information for the necessary purposes, otherwise the Company is unable to continue the insurance or other business relationship with the customer.
In compliance with the Personal Information Protection Law of the People’s Republic of China, an Addendum to Personal Information Collection Statement (“Addendum”), which supplements and forms part of the Personal Information Collection Statement of the Company, is available on our website.
The Addendum applies to you if you are located in Mainland China.
By purchasing, renewing or continuing your policy or relationship with the Company, you confirm that you have read and understood the Addendum and agree to the use and transfer of your personal data and sensitive personal data as set out in the Addendum. We may not be able to provide you with the relevant product(s) and/or service(s) if you do not consent to the Addendum or if you subsequently withdraw your consent.
Notice to customers relating to the Personal Data (Privacy) Ordinance (“Ordinance”)
Effective date: December 2019
1. The personal information of customers (including policyholders, insured persons, beneficiaries, premium payors, trustees, policy assignees and claimants) collected or held by Zurich Assurance Ltd (the “Company”) from time to time, which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer (such as claim information and medical history received from third parties), may be used by the Company and/or a company within its group (“Zurich Insurance Group”) for the following purposes necessary in providing services to the customers (“necessary purposes”) (otherwise the Company is unable to provide services to customers who fail to provide the required information):
a) to process, investigate (and assist others to investigate) and determine insurance applications, benefits and claims, perform reinsurance arrangements and provide ongoing services;
b) to manage any claim, action and/or proceedings brought by or against or otherwise involving the customers, and to exercise the Company’s rights as more particularly defined in applicable policy wording, including but not limited to the subrogation right;
c) to process requests for payment, and for direct debit authorization;
d) to provide subsequent services and administer the policies issued, such as to arrange medical examination, process additions, alterations, variations, assignments, cancellation, renewal or reinstatement of the relevant policies;
e) to compile statistics or database or conduct market or actuarial research or insurance surveys or perform customer analysis, profiling and segmentation undertaken by the Company and/or a company within the Zurich Insurance Group, respective regulators or industry recognized bodies, or to enhance existing or design new products and services of the Zurich Insurance Group, or for customer relationship building;
f) use for accounting and actuarial purposes;
g) to enable the Company and/or any company within the Zurich Insurance Group to fulfill any services or contract of insurance that a customer has requested, and/or to form a single overall view of the customer’s relationship with the Zurich Insurance Group and of the customer’s record, such as underwriting and claims history, for present and future reference in processing, assessing, determining and investigating insurance applications, benefits and claims, administering the customer’s policy, performing reinsurance arrangements and providing ongoing services;
h) to meet the disclosure requirements of any local or foreign law, rules, regulations, codes or guidelines binding on the Zurich Insurance Group and conduct matching procedures where necessary;
i) to comply with the requirements, orders or legitimate requests of, or contractual or other commitment or arrangement with the courts of Hong Kong, local and foreign regulators, tax or law enforcement authority, self-regulatory or industry recognized bodies such as federations or associations of insurers or financial services providers, including but not limited to the Insurance Authority, Hong Kong Federation of Insurers, auditors, credit reference agencies, governmental bodies and government-related establishments;
j) to collect (and assist other companies within the Zurich Insurance Group to collect) debts;
k) to prevent and detect (and assist other companies within the Zurich Insurance Group to prevent and detect) fraud;
l) to facilitate the Company’s authorized service providers to provide services to the Company and/or the customers for the above purposes;
m) to enable an actual or proposed assignee of the Company to evaluate the transaction intended to be the subject of the assignment; and
n) to fulfil any other purposes directly related to any of the above purposes.
2. The Company may provide any personal information of customers to the following parties, within or outside of Hong Kong, for the necessary purposes:
a) companies within the Zurich Insurance Group, any other company carrying on insurance or reinsurance related business, an intermediary, or an industry recognized body;
b) any agent, contractor or third party service provider who provides administrative, telecommunications, technology, computer, payment, policy administration, support, storage, cloud, record management, call center, mailing and printing, data processing, customer satisfaction analysis, outsourcing or other services to the Zurich Insurance Group in connection with the operation of its business;
c) third party service providers including insurers, bankers, legal advisors, accountants, fund management companies, financial institutions, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, hospitals, surveyors, specialists, repairers, emergency service providers, research and analysis companies and data processors;
d) credit reference agencies, and, in the event of default, any debt collection agencies or companies carrying on claim or investigation services;
e) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on the Zurich Insurance Group or any of its associated companies and for the purposes of any regulations, codes or guidelines issued by local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities with which the Zurich Insurance Group or any of its associated companies are expected to comply;
f) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities that is assumed by or imposed on the Zurich Insurance Group or any of its associated companies;
g) any person pursuant to any order of a court of competent jurisdiction;
h) organizations that consolidate claims and underwriting information for the insurance industry, fraud prevention organizations, employers, the police and databases or registers (and their operators); and
i) any actual or proposed assignee of the Zurich Insurance Group or transferee of the Zurich Insurance Group’s rights in respect of the policyholders.
3. Certain personal information of policyholders and insured persons collected or held by the Company from time to time (which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer), in particular, names, contact information, age, gender, identity document reference, marital status, financial background, demographic data, transaction pattern and behavior, policy information, claim information, and medical history may be used by the Company for the following marketing-related purposes (“marketing purposes”):
a) to provide marketing materials and conduct direct marketing activities in relation to insurance and/or financial products and services of the Zurich Insurance Group and/or other financial services providers, and/or other related services of business partners, with whom the Company maintains business referral or other arrangements (such as reward, loyalty, co-branding or privileges programs and related services and products, services and products offered by the Company’s business or co-branding partners, donations or contributions for charitable and/or non-profit making purposes)
The Company may use the personal information of any customer for the marketing purposes only with such customer’s consent. In the absence of any “opt-out” request, the Company shall treat the insurance application and continuation of the policy(ies) held with the Company as an indication of no objection of such policyholder and insured person to the Company’s use of their personal information for the marketing purposes. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time.
4. The Company may provide certain personal information, in particular, name, contact information, age, gender and policy information of a policyholder and an insured person, upon such policyholder’s and insured person’s written consent, to be used by the following parties, within or outside of Hong Kong, for their own and/or the Company’s marketing purposes:
a) companies within the Zurich Insurance Group;
b) other banking/financial institutions, commercial or charitable organizations with whom the Company maintains business referral or other arrangements;
c) third party reward, loyalty, co-branding or privileges program providers;
d) third party marketing-related service providers and insurance intermediaries.
The Company is not allowed to provide to any third party the personal information of any customer, specifically, policyholders or insured persons, for the marketing purposes without their written consent. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time. The Company may receive money or other property in return for providing the personal information to the parties set out in paragraph 4(a) to (d) above.
5. Customers’ personal information may from time to time be provided to any of the parties set out in paragraph 2 (and paragraph 4 for customers who consented to the marketing purposes) above (including cloud providers) which may be located in Hong Kong or elsewhere for necessary purposes (and marketing purposes for customers who have given their consent) and in this regard customers consent to the transfer of their personal information outside Hong Kong and understand that their personal data may not be protected to the same or similar level compared to Hong Kong.
6. All customers have the right to access, correct, or change any of their own personal information held by the Company, and in the case of policyholders and insured persons, opt-out of the Company’s use and transfer of their personal information for the marketing purposes, by request in writing to the Company’s Personal Data Privacy Officer at the address below. Requests for opt-out must state clearly the full name, identity document number, policy number, telephone number and address of the person making such request.
Personal Data Privacy Officer
26/F, One Island East
18 Westlands Road
Island East
Hong Kong
7. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for processing any data access request.
8. In the event of any discrepancy or inconsistencies between the English and Chinese versions of this notice, the English version shall prevail.
9. The Company reserves the right to change or update this Notice at any time without prior notice. The changes or updates will be notified to customers on Company’s website or in writing (which may include electronic format) and any such change or update will be effective immediately upon posting. The continuation of insurance or other business relationship with the Company signifies a customer’s agreement to the changes and updates in relation to the uses of such customer’s personal information for the necessary purposes, otherwise the Company is unable to continue the insurance or other business relationship with the customer.
In compliance with the Personal Information Protection Law of the People’s Republic of China, an Addendum to Personal Information Collection Statement (“Addendum”), which supplements and forms part of the Personal Information Collection Statement of the Company, is available on our website.
The Addendum applies to you if you are located in Mainland China.
By purchasing, renewing or continuing your policy or relationship with the Company, you confirm that you have read and understood the Addendum and agree to the use and transfer of your personal data and sensitive personal data as set out in the Addendum. We may not be able to provide you with the relevant product(s) and/or service(s) if you do not consent to the Addendum or if you subsequently withdraw your consent.
Personal Information Collection Statement for Zurich International Life Limited
Effective date: November 2023
1. The Company collects, stores and processes, by electronic or other means, customer’s personal information, including but not limited to: title, family name, forename(s), country and place of birth, nationality, date of birth, residential address, place/places of residence, health information if applicable, tax identification number if applicable, email address, telephone number, gender, marital status and employment and financial details.
2. The personal information of customers (including policyholders, insured persons, beneficiaries, premium payors, trustees, policy assignees and claimants) collected or held by the Company may be used by the Company for the following purposes necessary in providing insurance services to the customers (otherwise the Company is unable to provide services to customers who fail to provide the required information):
a) to process, investigate (and assist others to investigate) and determine insurance applications, insurance claims and provide ongoing insurance services;
b) to process requests for payment, and for direct debit authorization;
c) to manage any claim, action and/or proceedings brought against the customers, and to exercise the Company’s rights as more particularly defined in applicable policy wording, including but not limited to the subrogation right;
d) to compile statistics or database or conduct market or actuarial research or insurance surveys undertaken by the Company and/or its group (“Zurich Insurance Group”), the financial services industry, respective regulators or industry recognized bodies, or use for accounting and actuarial purposes;
e) to meet the disclosure requirements of any local or foreign law, regulations, codes or guidelines binding on the Company and/or the Zurich Insurance Group and conduct matching procedures where necessary;
f) to comply with the legitimate requests or orders of the courts of Hong Kong and regulators including but not limited to the Insurance Authority, Hong Kong Federation of Insurers, auditors, governmental bodies and government-related establishments;
g) to perform customer analysis, profiling and segmentation;
h) to collect debts;
i) to facilitate the Company’s authorized service providers to provide services to the Company and/or the customers for the above purposes; and
j) to enable an actual or proposed assignee of the Company to evaluate the transaction intended to be the subject of the assignment.
3. The Company may provide any personal information of customers to the following parties, within or outside of Hong Kong, for the purposes necessary in providing insurance services set out in paragraph 2 above:
a) companies within the Zurich Insurance Group, or any other company carrying on insurance or reinsurance related business, or an intermediary;
b) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to the Zurich Insurance Group in connection with the operation of its business;
c) third party service providers including legal advisors, accountants, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, surveyors, specialists, repairers, and data processors;
d) credit reference agencies, and, in the event of default, any debt collection agencies or companies carrying on claim or investigation services;
e) any person to whom the Zurich Insurance Group is under an obligation to make disclosure under the requirements of any law binding on the Zurich Insurance Group or any of its associated companies and for the purposes of any regulations, codes or guidelines issued by governmental, regulatory or other authorities with which the Zurich Insurance Group or any of its associated companies are expected to comply;
f) any person pursuant to any order of a court of competent jurisdiction; and
g) any actual or proposed assignee of the Zurich Insurance Group or transferee of the Zurich Insurance Group’s rights in respect of the policyholders.
As a global business, the Company will adopt contractual safeguard as applicable where it transfers personal information to other locations. A copy of the standard contractual safeguard is available on request from the Personal Data Privacy Officer.
4. Certain personal information of policyholders and insured persons collected or held by the Company, in particular, names, contact information, age, gender, identity document reference, marital status, policy information, claim information and medical history may be used by the Company for the following marketing-related purposes (the Company is not allowed to use the personal information of any customer for the purposes set out under this paragraph without such customer’s consent):
a) to provide marketing materials and conduct analysis and direct marketing activities in relation to insurance and/or financial products and services of the Zurich Insurance Group and/or other financial services providers, and/or other related services of business partners, with whom the Company maintains business referral or other arrangements.
5. The Company may provide certain personal information as set out in paragraph 4 above of a policyholder and an insured person, upon such policyholder’s and insured person’s written consent, to the following parties, within or outside of Hong Kong, for the marketing-related purposes set out in paragraph 4 above:
a) companies within the Zurich Insurance Group;
b) other banking/financial institutions, commercial or charitable organizations with whom the Company maintains business referral or other arrangements; and
c) third party marketing service providers and insurance intermediaries.
The Company is not allowed to provide to any third party the personal information of any customer, specifically, policyholders or insured persons, for the marketing-related purposes set out in paragraph 4 above without their written consent.
6. All customers have the right to access, correct, erase, obtain in digital format, restrict or object to processing of any of their own personal information held by the Company, not to be subject to automated individual decision making processes, withdraw consent at any time where processing is based on consent without affecting the lawfulness of processing based on consent before its withdrawal (including to opt-out of the Company’s use and transfer of their personal information for the marketing-related purposes), by request in writing to the Company’s Personal Data Privacy Officer at the address below. The Company may not be able to continue providing services to customers who have their personal information erased or have the processing of personal information restricted, or withdraw their consent on the processing personal information. Requests for opt-out must state clearly the full name, identity document number, policy number, telephone number and address of the person making such request.
Data Privacy Contact
Personal Data Privacy Officer
26/F, One Island East, 18 Westlands Road, Island East, Hong Kong
7. The Isle of Man Information Commissioner www.inforights.im can be contacted if there is any cause for complaint regarding the Company’s processing of personal information.
8. Where a data access request is made under this statement, the Company may process it free of charge. However, under particular circumstances, the Company may charge a reasonable fee or refuse to act on the request.
9. The Company retains personal information for as long as is necessary to meet the purposes for which it was originally collected or to satisfy the Company’s legal or regulatory obligations.
10. In the event of any discrepancy or inconsistencies between the English and Chinese versions of this statement the English version shall prevail.
In compliance with the Personal Information Protection Law of the People’s Republic of China, an Addendum to Personal Information Collection Statement (“Addendum”), which supplements and forms part of the Personal Information Collection Statement of the Company, is available on our website.
The Addendum applies to you if you are located in Mainland China.
By purchasing, renewing or continuing your policy or relationship with the Company, you confirm that you have read and understood the Addendum and agree to the use and transfer of your personal data and sensitive personal data as set out in the Addendum. We may not be able to provide you with the relevant product(s) and/or service(s) if you do not consent to the Addendum or if you subsequently withdraw your consent.
Notice to customers relating to the Personal Data (Privacy) Ordinance (“Ordinance”)
Effective date: April 2020
1. The personal information of customers (including policyholders, insured persons, beneficiaries, premium payors, trustees, policy assignees and claimants) collected or held by Zurich Life Insurance (Hong Kong) Limited ("Company") from time to time, which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer (such as claim information and medical history received from third parties), may be used by the Company and/or a company within its group (“Zurich Insurance Group”) for the following purposes necessary in providing services to the customers (“necessary purposes”) (otherwise the Company is unable to provide services to customers who fail to provide the required information):
a) to process, investigate (and assist others to investigate) and determine insurance applications, benefits and claims, perform reinsurance arrangements and provide ongoing services;
b) to manage any claim, action and/or proceedings brought by or against or otherwise involving the customers, and to exercise the Company’s rights as more particularly defined in applicable policy wording, including but not limited to the subrogation right;
c) to process requests for payment, and for direct debit authorization;
d) to provide subsequent services and administer the policies issued, such as to arrange medical examination, process additions, alterations, variations, assignments, cancellation, renewal or reinstatement of the relevant policies;
e) to compile statistics or database or conduct market or actuarial research or insurance surveys or perform customer analysis, profiling and segmentation undertaken by the Company and/or a company within the Zurich Insurance Group, respective regulators or industry recognized bodies, or to enhance existing or design new products and services of the Zurich Insurance Group, or for customer relationship building;
f) use for accounting and actuarial purposes;
g) to enable the Company and/or any company within the Zurich Insurance Group to fulfill any services or contract of insurance that a customer has requested, and/or to form a single overall view of the customer’s relationship with the Zurich Insurance Group and of the customer’s record, such as underwriting and claims history, for present and future reference in processing, assessing, determining and investigating insurance applications, benefits and claims, administering the customer’s policy, performing reinsurance arrangements and providing ongoing services;
h) to meet the disclosure requirements of any local or foreign law, rules, regulations, codes or guidelines binding on the Zurich Insurance Group and conduct matching procedures where necessary;
i) to comply with the requirements, orders or legitimate requests of, or contractual or other commitment or arrangement with the courts of Hong Kong, local and foreign regulators, tax or law enforcement authority, self-regulatory or industry recognized bodies such as federations or associations of insurers or financial services providers, including but not limited to the Insurance Authority, Hong Kong Federation of Insurers, auditors, credit reference agencies, governmental bodies and government-related establishments;
j) to collect (and assist other companies within the Zurich Insurance Group to collect) debts;
k) to prevent and detect (and assist other companies within the Zurich Insurance Group to prevent and detect) fraud;
l) to facilitate the Company’s authorized service providers to provide services to the Company and/or the customers for the above purposes;
m) to enable an actual or proposed assignee of the Company to evaluate the transaction intended to be the subject of the assignment; and
n) to fulfil any other purposes directly related to any of the above purposes.
2. The Company may provide any personal information of customers to the following parties, within or outside of Hong Kong, for the necessary purposes:
a) companies within the Zurich Insurance Group, any other company carrying on insurance or reinsurance related business, an intermediary, or an industry recognized body;
b) any agent, contractor or third party service provider who provides administrative, telecommunications, technology, computer, payment, policy administration, support, storage, cloud, record management, call center, mailing and printing, data processing, customer satisfaction analysis, outsourcing or other services to the Zurich Insurance Group in connection with the operation of its business;
c) third party service providers including insurers, bankers, legal advisors, accountants, fund management companies, financial institutions, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, hospitals, surveyors, specialists, repairers, emergency service providers, research and analysis companies and data processors;
d) credit reference agencies, and, in the event of default, any debt collection agencies or companies carrying on claim or investigation services;
e) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on the Zurich Insurance Group or any of its associated companies and for the purposes of any regulations, codes or guidelines issued by local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities with which the Zurich Insurance Group or any of its associated companies are expected to comply;
f) any person to whom the Zurich Insurance Group is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign governmental, regulatory, tax or law enforcement authority, industry recognized bodies or other authorities that is assumed by or imposed on the Zurich Insurance Group or any of its associated companies;
g) any person pursuant to any order of a court of competent jurisdiction;
h) organizations that consolidate claims and underwriting information for the insurance industry, fraud prevention organizations, employers, the police and databases or registers (and their operators); and
i) any actual or proposed assignee of the Zurich Insurance Group or transferee of the Zurich Insurance Group’s rights in respect of the policyholders.
3. Certain personal information of policyholders and insured persons collected or held by the Company from time to time (which also includes data collected or generated in the ordinary course of the Company’s business and the continuation of relationship with the customer), in particular, names, contact information, age, gender, identity document reference, marital status, financial background, demographic data, transaction pattern and behavior, policy information, claim information, and medical history may be used by the Company for the following marketing-related purposes (“marketing purposes”):
a) to provide marketing materials and conduct direct marketing activities in relation to insurance and/or financial products and services of the Zurich Insurance Group and/or other financial services providers, and/or other related services of business partners, with whom the Company maintains business referral or other arrangements (such as reward, loyalty, co-branding or privileges programs and related services and products, services and products offered by the Company’s business or co-branding partners, donations or contributions for charitable and/or non-profit making purposes).
The Company may use the personal information of any customer for the marketing purposes only with such customer’s consent. In the absence of any “opt-out” request, the Company shall treat the insurance application and continuation of the policy(ies) held with the Company as an indication of no objection of such policyholder and insured person to the Company’s use of their personal information for the marketing purposes. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time.
4. The Company may provide certain personal information, in particular, name, contact information, age, gender and policy information of a policyholder and an insured person, upon such policyholder’s and insured person’s written consent, to be used by the following parties, within or outside of Hong Kong, for their own and/or the Company’s marketing purposes:
a) companies within the Zurich Insurance Group;
b) other banking/financial institutions, commercial or charitable organizations with whom the Company maintains business referral or other arrangements;
c) third party reward, loyalty, co-branding or privileges program providers;
d) third party marketing-related service providers and insurance intermediaries.
The Company is not allowed to provide to any third party the personal information of any customer, specifically, policyholders or insured persons, for the marketing purposes without their written consent. For the avoidance of doubt, the latest instruction (for example, consent or indication of no objection, or request for opt-out) received from a customer shall override any previous instruction given to the Company in this regard in relation to all personal information of the customer collected or held by the Company from time to time. The Company may receive money or other property in return for providing the personal information to the parties set out in paragraph 4(a) to (d) above.
5. Customers’ personal information may from time to time be provided to any of the parties set out in paragraph 2 (and paragraph 4 for customers who consented to the marketing purposes) above (including cloud providers) which may be located in Hong Kong or elsewhere for necessary purposes (and marketing purposes for customers who have given their consent) and in this regard customers consent to the transfer of their personal information outside Hong Kong and understand that their personal data may not be protected to the same or similar level compared to Hong Kong.
6. All customers have the right to access, correct, or change any of their own personal information held by the Company, and in the case of policyholders and insured persons, opt-out of the Company’s use and transfer of their personal information for the marketing purposes, by request in writing to the Company’s Personal Data Privacy Officer at the address below. Requests for opt-out must state clearly the full name, identity document number, policy number, telephone number and address of the person making such request.
Personal Data Privacy Officer
26/F, One Island East
18 Westlands Road
Island East
Hong Kong
7. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for processing any data access request.
8. In the event of any discrepancy or inconsistencies between the English and Chinese versions of this notice, the English version shall prevail.
9. The Company reserves the right to change or update this Notice at any time without prior notice. The changes or updates will be notified to customers on Company’s website or in writing (which may include electronic format) and any such change or update will be effective immediately upon posting. The continuation of insurance or other business relationship with the Company signifies a customer’s agreement to the changes and updates in relation to the uses of such customer’s personal information for the necessary purposes, otherwise the Company is unable to continue the insurance or other business relationship with the customer.
In compliance with the Personal Information Protection Law of the People’s Republic of China, an Addendum to Personal Information Collection Statement (“Addendum”), which supplements and forms part of the Personal Information Collection Statement of the Company, is available on our website.
The Addendum applies to you if you are located in Mainland China.
By purchasing, renewing or continuing your policy or relationship with the Company, you confirm that you have read and understood the Addendum and agree to the use and transfer of your personal data and sensitive personal data as set out in the Addendum. We may not be able to provide you with the relevant product(s) and/or service(s) if you do not consent to the Addendum or if you subsequently withdraw your consent.
Addendum to Personal Information Collection Statement (“Addendum”)
Effective date: June 2023
This Addendum applies to you if you are located in Mainland China. These terms are set out in addition to and form part of the Personal Information Collection Statement for each of Zurich Insurance Company Ltd/Zurich Assurance Ltd/Zurich International Life Limited/Zurich Life Insurance (Hong Kong) Limited (each a “Company”, herein also referred to as “we”, “us” or “our”) in respect of their respective customers. If there is any conflict or inconsistency between the terms of this Addendum and any terms set forth in the Company’s Personal Information Collection Statement, the terms of this Addendum shall prevail.
The Company is the processor of your personal data, and you may contact us via customer@hk.zurich.com in accordance with the applicable data protection laws of Mainland China, we will only process your personal information with your prior consent, unless your personal information is:
- necessary for the conclusion or performance of a contract to which you are a contracting party; or
- necessary for fulfilling statutory responsibilities or obligations; or
- necessary for responding to public health emergencies; or
- necessary for protecting an individual’s life, health, and property safety in an emergency; or
- reasonably processed to carry out news reporting and supervision by public opinions for public interests; or
- publicly disclosed by you or otherwise legally disclosed and processed within a reasonable scope.
Your personal information is collected, stored, and processed for purposes as set out in the Company’s Personal Information Collection Statement. We will only retain your information for the period as we require to fulfil the purposes stated in the Company’s Personal Information Collection Statement and this Addendum, or for the period as we are required to under applicable laws and regulations, whichever is longer.
Sensitive personal information
Certain personal data that we collect and process may include sensitive personal information, which is personal information that, if leaked or used illegally, may easily cause harm to the dignity of natural persons, or the safety of individuals and properties. Sensitive personal information includes information relating to biometric identification, religious belief, specific identity, medical and health, financial account, and individual location tracking, as well as personal information of minors under the age of 14.
We will collect and process your sensitive personal information only when necessary to provide you with insurance services or to fulfil the purposes as set out in the Company’s Personal Information Collection Statement; for instance, to process, investigate, and determine insurance applications, insurance claims and provide ongoing services. We will not be able to provide you with the relevant product(s) and/or service(s) if we fail to process your sensitive personal information. We adopt and implement strict security policies to protect the confidentiality and privacy of your sensitive personal information.
Data transfer
We may provide your personal data to other recipients, within or outside Mainland China, as stated in the Company’s Personal Information Collection Statement including but not limited to companies within the Zurich Insurance Group, any agents, contractors, third party service providers, and credit reference agencies, for the purposes stated in the Company’s Personal Information Collection Statement and this Addendum. You may find a list of recipients below:
| Recipients | Types of personal information | Purpose and method | Contact details |
| Zurich Assurance Ltd | All personal information specified in the Company’s Personal Information Collection Statement | Purpose and method specified in the Company’s Personal Information Collection Statement | customer@hk.zurich.com |
| Zurich International Life Limited | |||
| Zurich Insurance Company Ltd | |||
| Zurich Life Insurance (Hong Kong) Limited | |||
| Zurich Services (Hong Kong) Limited |
Your rights
Under the applicable data protection laws of Mainland China, you are entitled to the following rights:
- Right to access and obtain a copy of your personal information;
- Right to request a transfer of your personal information to your designated information processors who meet the conditions prescribed by the relevant cybersecurity authority;
- Right to correct and supplement your personal information if you discover that it is inaccurate or incomplete;
- Right to require an explanation of our rules for the processing of personal information;
- Right to withdraw consent;
- Right to restrict or deny processing of your personal information by others;
- Right to request us to delete your personal information under one of the following situations:
a. the purpose of processing has been fulfilled, cannot be fulfilled or the personal information is no longer necessary for fulfilling the purpose of processing;
b. we have ceased to provide products or services;
c. the retention period has come to an end;
d. you have withdrawn your consent;
e. we have violated the laws, regulations or agreements when processing personal information.
You may exercise the above rights by making a request in writing to the Company’s Personal Data Privacy Officer at the address below:
Personal Data Privacy Officer
26/F, One Island East
18 Westlands Road
Island East
Hong Kong
Your consent
By purchasing, renewing or continuing your policy or relationship with the Company, you confirm that you have read and understood this Addendum and agree with the Company’s use and transfer of your personal data and sensitive personal data as set out in this Addendum.
We may not be able to provide you with the relevant product(s) and/or service(s) if you do not consent to this Addendum or if you subsequently withdraw your consent. This would also include our inability to provide the relevant products and/or services to a corporate customer which is your employer if you (as an employee) do not consent to this Addendum or if you later withdraw your consent.
We reserve the right to change or update this Addendum at any time without prior notice. We will notify you of the changes or updates by posting it on our website or in writing (which may include electronic format) and any such change or update will be effective immediately upon posting.