Privacy policy

1. Introduction

QBE Hongkong & Shanghai Insurance Limited and QBE General Insurance (Hong Kong) Limited (“we”) are committed to protecting the personal data of our customers. We are bound by the Data Protection Principles set out in the Hong Kong Personal Data (Privacy) Ordinance (the PDPO).

We will only collect, use or disclose personal data in accordance with the PDPO and this Privacy Policy.

We may amend this Privacy Policy at any time and for any reason. The updated version will be available by following the “Privacy” link on our website homepage at qbe.com/hk. You should check the Privacy Policy regularly for changes.

In this Privacy Policy, “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.

2. When do we collect personal data?

We collect personal data in a number of ways. The most common circumstances in which we collect personal data are when your personal data is used for:

  • processing and assessing of applications for any insurance products and daily operation of the related services;
  • any alterations, variations, cancellation or renewal of any insurance and related services; and
  • any claims or investigation or analysis of such claims.

3. What personal data do we collect?

The types of personal data we collect from you will depend on the circumstances in which that information is collected.

We may collect details including but not limited to:

  • your name
  • Hong Kong identity card no./ passport no.
  • bank account details
  • mobile phone number
  • residential phone number
  • office phone number
  • residential address
  • correspondence address
  • email address
  • age
  • marital status
  • gender
  • personal interests
  • family
  • education
  • occupation
  • billing information, credit card no., credit card expiry date, credit card security code, or other payment information
  • policy data
  • information about your computer and device used by you to access our services
  • online footprints which include website(s) visited

4. What do we use personal data for?

The purposes for which your personal data will be used will depend on the circumstances in which that personal data is collected.

We will inform you of the purposes for which we intend to use your personal data in the Personal Information Collection Statement at or before the time we collect your personal data.

Generally, we may use your personal data for:

  • the purpose for which you provided it to us;
  • purposes which are directly related to the purpose for which you provided it to us; and
  • any other purposes to which you have consented.

The information you provide to us is collected to enable us to carry on insurance business and may be used for the purpose of any insurance or financial related product or service or any alterations, variations, cancellation or renewal of such product or service; any claim or investigation or analysis of such claim; and exercising any right of subrogation, and may be transferred to:

  1. any related company or any other company carrying on insurance or reinsurance related business or an intermediary or a claims or investigation or other service provider providing services relevant to insurance business for any of the above or related purposes;
  2. any association, federation or similar organization of insurance companies (“Federation”) that exists or is formed from time to time for any of the above or related purposes or to enable the Federation to carry out its regulatory functions or such other functions that may be assigned to the Federation from time to time and are reasonably required in the interest of the insurance industry or any member(s) of the Federation; and
  3. any members of the Federation by the Federation for any of the above or related purposes. Moreover, we are hereby authorized to obtain access to and/or to verify any of your data with the information collected by the Federation from the insurance industry.

5. Do we use personal data for direct marketing?

We do use some of the personal data we collect to send marketing material and special offers to our customers, but only in accordance with the rules about direct marketing contained in the PDPO.

If we intend to use your personal data for direct marketing purposes or provide your personal data to third parties for direct marketing purposes, we will inform you of that in the Personal Information Collection Statement at or before the time we collect your personal data. We will provide you with an opportunity to opt out of that direct marketing at that time if you so request.

If you do not opt out of direct marketing at that time, but you later decide that you no longer wish to receive direct marketing, you may ask us to cease any further direct marketing by contacting us via email or made in writing to the Personal Data Protection Officer:

  • QBE Hongkong & Shanghai Insurance Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong
    Email: info.hk@qbe.com.hk
    Tel: 852 2877 8488
    Fax: 852 3607 0300

  • QBE General Insurance (Hong Kong) Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King's Road, Quarry Bay, Hong Kong
    Email: info.gihk@qbe.com
    Tel: 852 2828 3188
    Fax: 852 3607 0555

6. To whom do we disclose personal data?

The third parties, agents or business partners to whom your personal data will be disclosed will depend on the purposes for which that personal data is used.

We will inform you of the third parties to whom your personal data will be disclosed in the Personal Information Collection Statement at or before the time we collect your personal data.

Generally, we may disclose your personal data as necessary for:

  • the purpose for which you provided it to us;
  • purposes which are directly related to the purpose for which you provided it to us; and
  • any other purposes to which you have consented.

The information you provide to us is collected to enable us to carry on insurance business and may be used for the purpose of any insurance or financial related product or service or any alterations, variations, cancellation or renewal of such product or service; any research and analysis to improve our services provided to you; any claim or investigation or analysis of such claim; and exercising any right of subrogation, and may be transferred to:

  1. any agent, advisor arranging the insurance policy on your behalf;
  2. any related company or any other company carrying on insurance or reinsurance related business or an agent or an intermediary or a claims or investigation or other service provider providing services relevant to insurance business for any of the above or related purposes;
  3. any association, federation or similar organization of insurance companies (“Federation”) that exists or is formed from time to time for any of the above or related purposes or to enable the Federation to carry out its regulatory functions or such other functions that may be assigned to the Federation from time to time and are reasonably required in the interest of the insurance industry or any member(s) of the Federation; and
  4. any members of the Federation by the Federation for any of the above or related purposes.

Moreover, we are hereby authorized to obtain access to and/or to verify any of your data with the information collected by the Federation from the insurance industry.

In exceptional circumstances, we may be required or permitted by law to disclose personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.

7. How is personal data secured?

We will take all reasonably practicable steps to ensure that your personal data is protected against unauthorised access, processing, erasure, loss or use. Our security measures include:

  • Before sending documents containing personal data to a customer, it is important to ensure that the address of the customer is accurate and up-to-date, otherwise the data is put to the risk of accidental disclosure to unrelated third parties.
  • We formulate their policies and practices to specify the period of retention of customers’ personal data.
  • Documents containing personal data such as insurance application form or policy should be securely kept against access by unauthorized parties. Personal data stored electronically in computers or portable storage devices should be protected with adequate IT security measures and access control.

8. Accessing and correcting your personal data

You may contact us to seek access to or seek to correct personal data which we hold about you. There are certain exemptions under the PDPO which may apply to personal data access and correction requests. We may require that you, the person requesting access or correction, provide suitable identification and we may charge a reasonable administration fee for complying with a data access request.

Requests for access to and/or correction of personal data held by us, should be sent by email or made in writing to the Personal Data Protection Officer:

  • QBE Hongkong & Shanghai Insurance Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong
    Email: info.hk@qbe.com.hk
    Tel: 852 2877 8488
    Fax: 852 3607 0300

  • QBE General Insurance (Hong Kong) Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong
    Email: info.gihk@qbe.com
    Tel: 852 2828 3188
    Fax: 852 3607 0555

9. Erasure of personal data

We will take all reasonable practicable steps to erase personal data which we hold about you where the personal data is no longer required for the purpose for which it was collected and used. There are certain exemptions under the PDPO which may apply to erasure of personal data, such as if any such erasure is prohibited under any law or it is in the public interest for the data not to be erased.

10. Data transfers

We may transfer personal data which we hold about you to a place outside Hong Kong in specified circumstances as set out in the PDPO.

11. Your consent and rights

By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this Statement.

12. Queries and comments

We welcome your queries or comments about our Privacy Policy and personal data collection and handling practices. Please contact us at info.gihk@qbe.com/ info.hk@qbe.com.hk.

Personal Information Collection Statement

QBE Hongkong & Shanghai Insurance Limited or QBE General Insurance Company Limited (“the Company”) may use the personal data collected or held about you, which may include your name, address and other contact details, date of birth, bank account or credit card details, Hong Kong identity card number, information about your dependents and health records, and which we may collect when, for example, you apply for, renew or make a claim under a policy and/or you correspond with us, for the following purposes:

Insurance Services (mandatory)

  1. processing and assessing of applications for any insurance products and daily operation of the related services;
  2. administering your insurance policy and providing services in relation to your insurance policy;
  3. any alterations, variations, cancellation or renewal of any insurance and related services;
  4. investigating, analysing, processing and paying claims made under your insurance policy;
  5. invoicing and collecting premiums and outstanding amounts from you;
  6. exercising any right under the insurance policy including right of subrogation, if applicable;
  7. complying with the requirements under any law and regulation, industry codes, guidelines, requests from regulators, industry bodies, government agencies and court orders;
  8. to conduct research, insurance survey and analysis for the purpose of product design and development and improvement of our services to you;
  9. for statistical or actuarial research undertaken by the Company, other members of the QBE Group, any agents, third parties or business partners of the Company or its regulators;
  10. for the operation and administration of the Company’s internal business including without limitation any corporate reorganization;
  11. contacting you for any of the above purposes; and
  12. other ancillary purposes which are directly related to the above purposes.

The Company may transfer your personal data, including but not limited to your name and contact details, to the following parties within or outside Hong Kong for the purposes set out above:

  1. any agent, advisor, contractor or third party service provider (whether within or outside the QBE Group) who provides administrative, telecommunications, computer, payment, debt collection, security, research, ratings, consulting services, product design, marketing (where you have consented to direct marketing as described below), data processing or storage or related services or any other company carrying on insurance or reinsurance related business, or an intermediary, or a claim or investigation or other service provider providing services relevant to insurance business, for any of the above or related purposes;
  2. any association, federation or similar organization of insurance companies (“Federation”) that exists or is formed from time to time for any of the above or related purposes or to enable the Federation to carry out its regulatory functions or such other functions that may be assigned to the Federation from time to time and are reasonably required in the interest of the insurance industry or any member(s) of the Federation;
  3. any members of the Federation by the Federation for any of the above or related purposes;
  4. government bodies, regulators or any other body to whom the Company or any company within the QBE Group is required to or has agreed to make disclosure under any applicable laws or regulations;
  5. lawyers;
  6. auditors; and
  7. other insurance companies within the QBE Group which have undertaken to keep such information confidential and solely for the purposes set out in the above paragraph.

Some of these persons may be located in countries overseas, namely Australia, Philippines, where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the data protection laws of Hong Kong. That means your personal data may not be protected to the same or similar level as in Hong Kong. However, the Company will only transfer your personal data to a service provider or overseas where the Company is satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws.

In the unlikely event that the Company, any companies within the QBE Group, or its or their brands or substantially all of any of its or their assets are acquired by an unrelated third party, your personal data may be one of the transferred assets. By providing your personal data to the Company, you agree that the Company may disclose your personal data, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business.

You do not have to provide your personal data to the Company, but if you do not provide certain personal data (for example, the information indicated as mandatory on the relevant application, registration or renewal forms, or your contact details if you send us an enquiry), it would not be possible for the Company to process your application and render the services or to otherwise correspond with you.

The Company is committed to ensuring your personal data is kept secure and confidential and not kept for longer than is necessary.

Direct Marketing of Products and Services

To provide a more comprehensive range of financial and insurance services, the Company would like to use your name and the contact details you provide to us (for example, your mobile phone number, residential phone number, office phone number, residential address, correspondence address and email address), alongside information that you provide (including but not limited to) about your age, gender, occupation, personal interests, marital status, family and education (the “Marketing Personal Data”), to provide you with direct marketing communications about the Company’s products and services including but not limited to the Company’s insurance, banking, financial services, provident schemes and general insurance products but the Company cannot do so without your consent.

The Company intends to share, from time to time, your Marketing Personal Data with any agents, third parties or business partners of the Company for the purpose of marketing to you their insurance, investment fund, provident schemes, and other financial products and services including general insurance products and services, but we will not do so without your written consent.

By taking out an insurance policy with the Company, you hereby provide your express consent to the transfer of your personal data outside of Hong Kong. You also understand that your personal data may be transferred to a place that may not have data protection laws that are substantially similar to, or service the same purposes as the Personal Data (Privacy) Ordinance so as to ensure the protection of your personal information.

If you do not agree to the use of your personal data for above purposes, it would not be possible for the Company to process your application and render the services.

Your Rights

You have the right to ascertain the Company’s policies and practices in relation to personal data, obtain access to and to request correction of any personal information concerning yourself held by the Company subject to payment of an administrative fee. Requests for such access or correction can be made in writing to the Privacy Data Protection Officer:

  • QBE Hongkong & Shanghai Insurance Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong
    Email: info.hk@qbe.com.hk
    Tel: 852 2877 8488
    Fax: 852 3607 0300
  • QBE General Insurance (Hong Kong) Limited
    Address: 33/F, Oxford House, Taikoo Place, 979 King's Road, Quarry Bay, Hong Kong
    Email: info.gihk@qbe.com
    Tel: 852 2828 3188
    Fax: 852 3607 0555

If you do not want to receive any sale or marketing of any of the products or services from the Company at any time, you may also contact the Company’s Privacy Data Protection Officer.

(November 2018)

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