Company Policy | Tahoe Life Insurance Company Limited

Tahoe Life Insurance Company Limited (Incorporated in Bermuda with limited liability) (“the Company”) recognise their responsibilities in relation to the collection, holding, processing or use of personal data under the Personal Data (Privacy) Ordinance. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental access, erasure or other use. The Company will not provide your personal data to third parties for direct marketing or other unrelated purposes without your consent. The Personal Information Collection Statement set out below also forms part of this Privacy Policy Statement.  

CONDITIONS OF USE OF THE WEBSITE AND COOKIES POLICIES

The Company is committed to safeguard any personal data provided by our customers. The Company will strictly comply with the requirements of the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong Special Administrative Region. It has been our commitment to train and enforce our staff to practice this Privacy Policy.

The Company collects no personal data from any person who simply browses our website. Throughout the website, only the necessary information for applications / enquiry will be collected, and the customers will be informed of the purposes and uses, possible transfer and disclosure and the right of access to and correction of the collected information. In order to ensure the security and confidentiality of personal data we collect, encryption techniques have been applied for data transmission. The Company will not collect any information from customers without notice.

From time to time, with your consent, the Company may send promotional materials regarding our products to customers according to the collected information. The Company will obtain your consent before we send any promotional materials and stop sending the materials to customers on request.

By using this website, you indicate your acceptance of the Company’s Privacy Policy. The Company reserves the right to modify, alter or otherwise update this Policy from time to time.

Use of Cookies and Third Party Links

The Company may use "cookies" to improve our internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by the Company’s website. Cookies enable The Company’s website to remember you and your preferences and enable us to tailor the content based on your needs and limit the frequency of displaying advertisements. The information collected by cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser. However, disabling the cookies might affect your user experience while browsing the Company’s website and proper functions of website.

In addition, certain cookies on the website are managed by third parties, including features such as advertising networks, videos, maps and social media, as well as external website providers (such as web traffic analysis services, reCAPTCHA, etc.). These cookies may be basic, performance, functional or advertising cookies types. You should refer to the cookies and privacy policies of such third parties to obtain information about how the third parties use your information.

The Company’s website may include hyperlinks to third party websites. The Company has no control over the content, accuracy, opinion expressed, and other links provided at these third party websites or how these third party websites deal with your personal data. You should visit these third party websites for details of their privacy policies in relation to their handling of your personal data.

PERSONAL INFORMATION COLLECTION STATEMENT (“PICS”)

The provision of your personal data is voluntary. Please note that if you do not provide the Company with the required personal data, the Company may not be able to provide your requested information, products or services.

Purpose: From time to time it is necessary for us to use your personal data for the following purposes:

1. offering, providing and marketing to you the products / services of the Company and its subsidiaries (see “Use of Personal Data for Direct Marketing Purposes” below) and administering, maintaining, managing and operating such products / services;
2. processing and evaluating any applications or requests made by you for products / services offered by the Company and its subsidiaries;
3. processing payment instructions;
4. collect, use and disclose your personal information (including credit information and claims history) for the purposes necessary to process your application, investigate and settle claims and detect and prevent fraud (whether or not relating to the policy issued in respect of this application);
5. providing subsequent services to you and administering the policies issued e.g. additions, alterations, variations, cancellation, renewal or reinstatement;
6. any purposes in connection with any claims made by or against or otherwise involving you or other claimants in respect of any products/services provided by the Company and / or its subsidiaries, including investigation of claims;
7. for our data matching, internal business and administrative purposes;
8. designing new or enhancing existing products/services of the Company and its subsidiaries;
9. conducting market or actuarial research for statistical or similar purposes undertaken by the Company and its subsidiaries, the financial services industry or our respective regulators;
10. matching any data held which relate to you from time to time for any of the purposes listed herein;
11. meeting requirements imposed by any applicable law, rules, regulations, codes of practice or guidelines or assisting with law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere including Mainland China;
12. conducting identity and/or credit checks and/or debt collection;
13. sending out administrative communications about any account you may have with the Company or about future changes to this Personal Information Collection Statement; and
14. other purposes directly relating to any of the above.

Transfer of personal data: Personal data will be kept confidential but, subject to the provisions of any applicable law, may be transferred to:

1. any of the subsidiaries of the Company in Hong Kong or elsewhere including Mainland China;
2. any person (including private investigators and claims investigation companies) in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by the Company and / or its subsidiaries;
3. any agent, contractor or third party who provide services in connection with the product / services provided by the Company and / or its subsidiaries in the following classes of business: reinsurance, insurance intermediary, fund management or finance;
4. any agent, contractor or third party who provides administrative, technology, data processing, telecommunications, computer, payment, debt collection, call centre services, direct marketing services or other services to the Company and / or its subsidiaries in connection with the operation of its business within or outside Hong Kong (such as Mainland China);
5. other companies who help gather your information or communicate with you, such as research companies and credit reference agencies or, in the event of default, debt collection agencies;
6. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business;
7. any government department or other appropriate governmental or regulatory authority, whether within or outside Hong Kong (such as Mainland China), to whom the Company and / or its subsidiaries are requested or required by any applicable law, rules, regulations, codes of practice or guidelines to make disclosures; and
8. transfer personal information to the following persons who may collect and use this information only as reasonably necessary to carry out the purposes described above: [insurance adjusters, licensed insurance intermediaries; employers; health care professionals; hospitals; accountants; financial advisors; solicitors; 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 other persons named in this paragraph), the police and databases or registers (and their operators) used by the insurance industry to analyse and check information provided against existing information.

Your personal data may be provided to any of the above parties who may be located in Hong Kong or outside of Hong Kong (such as Mainland China), and in this regard you consent to the transfer of your data outside of Hong Kong including but not limited to Mainland China.

Transfer of your personal data will only be made for one or more of the purposes specified above. For our policy on using your personal data for promotional or marketing purposes, please see the section entitled “Use of Personal Data for Direct Marketing Purposes”.

Use of Personal Data for Direct Marketing Purposes: The Company intends to:

1. Use 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 in Hong Kong and outside Hong Kong (such as Mainland China);
2. Conduct direct marketing (including providing reward, loyalty or privileges programmes) in relation to the following classes of products and services that the Company and its subsidiaries may offer:
   1. insurance, annuities, banking, wealth management, retirement plans, investment, financial services, credit cards, securities and related products and services; and
   2. health, wellness and medical, food and beverage, sporting activities, memberships and related products and services;
3. The above products and services may be provided by:
   1. the Company or any of its subsidiaries;
   2. any agent, contractor or third party service provider who provides administration, data processing, telecommunications, computer, payment, debt collection or securities clearing, technology outsourcing, call center services, mailing and printing services in connection with the operation of the Company’s business and provision of our services to you;
   3. agents, contractors or third party service providers including companies to help deliver our services, such as reinsurance companies, investment management companies, claims investigation companies, industry associations or federations; and
   4. other companies who help gather your information or communicate with you, such as research companies and ratings agencies.
4. The Company requires your written consent (which includes an indication of no objection) for the Company to use and to provide the data to the third parties as set out above for any promotional or marketing purpose.

You may withdraw your consent for the Company to use and to provide to a third party of your personal data for direct marketing purposes at any time, and thereafter the Company shall, without charge to you, cease to use such data for direct marketing purposes. If you wish to withdraw your consent, please contact the Data Protection Officer (details below).

Amendment to the PICS

The Company reserves the right at anytime, with or without notice, amends this PICS which will be found in our website or in writing to notify you how the Company will collect, use and transfer your personal data. Should there be any amendment to this PICS in the future, such amendment will become effective with immediate effect.

Access and correction of personal data: Under the Personal Data (Privacy) Ordinance, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, to correct any data that is inaccurate, and to ascertain the Company’s policies and practices in relation to personal data. You may also request the Company to inform you of the type of personal data held by it.

Requests for access and correction or for information regarding policies and practices and types of data held should be addressed in writing to:

Data Protection Officer, Tahoe Life Insurance Company Limited (Incorporated in Bermuda with limited liability), 19/F, 1111 King’s Road, Taikoo Shing, Hong Kong, Telephone: (852) 3767 8777.

A reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your access requests.

This Privacy Policy Statement and the Personal Information Collection Statement have been translated into Chinese. If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.