Privacy Notice

At Chow Tai Fook Life Insurance Company Limited of the Penthouse Floor, 5 Reid Street, Hamilton, HM11, Bermuda (“CTF Life”, “we”, “us” or “our”), we hold as one of our core values the protection of privacy of our customer’s personal information. “personal information” means any information about an identified or identifiable individual; an identifiable individual is one who can be identified directly or indirectly, in particular by reference to an identifier or to one or more factors specific to the identity of such individual. If you provide personal information about another individual (e.g. your partner or other members of your family), you must (unless we agree otherwise) inform the individual about the content of this privacy notice (“Privacy Notice”).

As a provider of insurance products and services, collection and use of personal information of our customers is at the heart of our business. CTF Life respects the privacy of your personal information and are committed to fully complying with the Personal Information Protection Act 2016 (“PIPA”). This Privacy Notice is made by CTF Life, and applies between us and you (“you”, or “your”). This Privacy Notice should be read together with the terms and conditions (if any) of any instrument, documentation, form (the “Documentation”) and/or software application (the “Application”) (as applicable), and the website at https://bermuda.ctflife.com (the “Website”) that refers to and/or contains this Privacy Notice (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Privacy Notice and the Terms and Conditions concerning matters relating to personal information, this Privacy Notice shall prevail.

CTF Life is a related company of the New World group of companies including New World Development Company Limited (“NWD”) and its affiliated or related companies from time to time (the “New World Group”, or “NWG”) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, loyalty programmes, department stores, jewelleries and luxury products, e-commerce, hospitality services, food and beverages, convention and exhibition centres, sports and recreational facilities, education, health care and senior care, other health and wellness products and services, financial services and insurance, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), corporate innovation, accelerator and incubation programmes, organization of competitions, conferences and events, start up and social innovation programmes and charitable pursuits including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion, and other purposes that are beneficial to the community (the “Goods and Services”) (the New World Group and joint venture companies together referred to as “Affiliates”).

In order to enable us to perform the Purposes (as defined in the Purposes for using personal information collected section below), you are required to provide all the requested/mandatory personal information in the Documentation, the Application, and/or the Website (as applicable) that refers to and/or contains this Privacy Notice. If you do not provide the required personal information, then we may not be able to perform the Purposes and/or provide Goods and Services to you.

Kinds of personal information collected

The kinds of personal information we may collect from you and/or from other sources as mentioned below in this Privacy Notice and/or hold (whether pursuant to the Documentation or any other contracts, agreements or other binding arrangements which you have entered into or intend to enter into with CTF Life), use and/or disclose/share with (whether contained here or otherwise obtained) include your name, gender, age (or age range), date of birth, identity/ travel document details, nationality, contact details, e-mail address, mailing/residential/correspondence address, contact number, policy details, transaction records, credit information, membership number, marital status, family status, educational and training details, employment details, financial details, tax details, medical and health records, claims history and information on your family, lifestyle and social circumstances, occupation details, username and password, Log Files (see below), interests and favourite activities, tracking information about your use of the Application and/or the Website (as the case may be) and transaction information (including your characteristics and transaction behaviour) (“Tracking Data”), social media account information and etc. as well as information in relation to your insured, policy beneficiaries, assignees, trustees, third party payor (if applicable). For Tracking Data collected through the use of cookies and other tracking mechanisms, please also refer to our related policies (including but not limited to the CTF Life Privacy Policy Statement) for further details as to how we collect, use and process Tracking Data.

Purposes for using personal information collected

The personal information to be collected from you and/or from other sources as mentioned below in this Privacy Notice will be used and retained by us (and/or our Affiliates and/or our Marketing Partners as defined in the Direct Marketing section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes"):

Administration of insurance or reinsurance related business, which includes underwriting, processing and evaluation of applications, identity and credit checking, suitability checking, policy servicing, collateral assignment arrangement (e.g. for premium financing purpose), claims processing, claims investigation, claims settlement, fraud detection and prevention (whether or not relating to the policy issued in respect of this application), account/debt collection, litigation, communications, preparing statistics, data analysis and research, internal and external audit, maintaining quality services, sales and marketing, corporate brand building and customer loyalty building;
Identifying and verifying your identity and/or as a member;
Registering you as a user of the Application and/or the Website (as the case may be);
To serve you better and/or maintain your personal information across multiple pages within or across one or more sessions when using the Application and/or the Website (as the case may be);
Following registration as a user, accessing your account information (including, but not limited to, your name, membership number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour (subject to your consent for direct marketing, if/where applicable) to provide other Goods and Services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal information for statistical analysis, data science studies and data mining;
For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
Improving the Documentation, the Application and/or the Website, the Purposes, and our and our Affiliates’ and Marketing Partners ‘Goods and Services;
Direct marketing and cross-marketing for the Marketing Subjects, subject to consent (see below section entitled “Direct marketing”);
Data analytics, profiling, information management and database administration;
Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal;
Compliance with the obligations, requirements or arrangements for disclosing and using data that apply to CTF Life or with which it is expected to comply according to:
1. any law binding or applying to it within or outside Bermuda existing currently and in the future;
2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Bermuda existing currently and in the future; and
3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on CTF Life by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations.
Collection or recovery of any debt owed by you to us or our Affiliates;
The normal management, operation, and maintenance of the Application and/or the Website and the provision of the Goods and Services to you;
Storing your personal information (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal information with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above (and subject to your consent in the event that transfer to any or all such data transferees for direct marketing are involved); and/or
Other purposes ancillary or related to the above.

Those with whom we share personal information

The personal information you provide to CTF Life will be kept confidential, except that it may be disclosed/shared with the following parties:

any insurance agent, broker, independent financial advisor acting on your behalf or your assignee, adjusters, employers, health care professionals, hospitals, accountants, financial advisors, solicitors, and/or organizations that consolidate claims and underwriting information for the insurance industry; fraud prevention organizations; other insurance companies (whether directly or through fraud prevention organization or other persons named in this paragraph), the police and databases or registers (and their operators) used by the insurance industry to analyse and check information provided against existing information) for any of the Purposes;
loss adjusters, private investigators, letter shopping service providers, debt collectors, and any other agent, contractor or third party service provider, in each case, that provides risk intelligence, administrative, telecommunications, computer, internet or payment services to CTF Life for any of the Purposes;
any actual or proposed reinsurers of CTF Life for any of the Purposes;
any person to whom CTF Life is under an obligation or otherwise required to make disclosure under the requirement of any law binding on or applying to CTF Life or any of its Affiliates, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which CTF Life is expected to comply or any disclosure pursuant to any contractual or other commitment of CTF Life with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Bermuda and may be existing currently and in the future.

We may also engage agents, contractors, suppliers and service providers (whether within or outside Bermuda) in connection with the Purposes and/or the provision of the Goods and Services, e.g. IT/software solutions/technology services providers, marketing agents, social media, research companies, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services, and may transfer to or share your personal information with them for the Purposes within or outside Bermuda. We may also share your personal information (subject to your consent, if/where applicable) with our Affiliates, our Marketing Partners (see below) and the social media platforms that we and/or our Affiliates/our Marketing Partners (see below) use for such Purposes. Where we are required by the law of any country or place or requested by any court, regulatory body or governmental body of any country or place, we may also disclose your personal information as required. In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our Affiliates or our Affiliates' businesses, your personal information may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Privacy Notice and continues to exercise the same level of care, in respect of your personal information, as we would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal information.

Your personal information may be used, transferred to and/or stored by us in physical locations and/or servers located within or outside Bermuda and/or shared with our Affiliates and/or our Marketing Partners (see below) located within or outside Bermuda. However, we will take all reasonable measures to ensure that your personal information is used, stored and processed securely, regardless of the country or place in which it is used and/or stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates and our Marketing Partners (see below) do the same.

Direct marketing

Subject to your consent, we may use your personal information to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future.

Subject to your consent, we may also use your personal information for, or provide your personal information to, our Affiliates and/or our Marketing Partners (see below) so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, and/or other media whether now known or available in the future.

Our “Marketing Partners” include property developers, banks, financial and investment institutions, insurance companies, insurance brokerage companies, insurance corporate agencies, private clubs, concierge and customer service providers, retail outlets and online businesses (products and services including fashion and beauty, health and personal cares, luxury, home and living, food, wine and beverage, books and stationery), shopping malls, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, catering services providers, healthcare and senior care, services and/or products providers including health and wellness, art and culture, gallery and exhibition, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication, media and information technology, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, pre-school, primary, secondary and/or tertiary education institutions.

As we may share your personal information with our Affiliates and/or our Marketing Partners, we may also receive your personal information from them. Subject to your consent given to our Affiliates and/or our Marketing Partners, we may also use such personal information to send you direct marketing about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects (see below).

The types of products, services, events and charitable initiatives that we, our Affiliates and/or our Marketing Partners may market to you include the following (together, the “Marketing Subjects”):

goods and services offered by us and/or our Affiliates in relation to the Goods and Services;
finance, banking, securities, mortgage, insurance and other related services and products by banks, financial and investment institutions, securities companies and insurance companies;
access and privileges at private clubs;
professional consultation on customer services, including but not limited to event planning, holidays, hotels, travel, and tickets reservation;
consumer products and services by retail outlets and/or online businesses, including clothing, shoes, fashion, fashion accessories and beauty, health and personal cares, luxury, home and living, household products, food, wine, liquor and beverages, confectionary, groceries, books and stationery, toys, cigarettes and cigars, fragrances and cosmetics, baby products, telephones and mobile devices, electronics and electrical appliances, computer software, and games, bags and luggage, furniture, sports and leisure equipment;
pharmaceutical products, medical and pharmaceutical services, therapeutical products and services, and therapy services by therapists;
tutoring, mentoring, home cleaning, janitor services, landscape and plant maintenance services, agricultural services, part time housekeeping, plumbing services, locksmiths, barber and salon services, gym and fitness services, laundry services, florists, vehicle towing, and motor vehicle services;
reward, loyalty, privileges programmes and promotions at shopping malls and department stores;
reward, loyalty, privileges programmes and promotions for customers and/or potential customers of the New World Group;
watches, jewelleries and accessories;
restaurants, catering services on food, wine and beverage;
travel, hospitality and accommodation services and products, including but not limited to hotels and serviced apartments, holiday package products and services offered by travel agents, tickets to attractions;
transportation and logistics services, including but not limited to air travel and non-air transportation services such as hotel transfers, car rentals, bus operators, train operators and cruise operators, and courier services and shipping services;
conference and exhibition management services, consultancy and marketing research services, supply chain management, event and project management services, gaming services, advertising and public relations services, media production services;
tickets for concerts, galleries, exhibitions, films, theatricals, sporting, special and cultural events;
green and nature activities;
technology, telecommunication, internet and mobile communication services, social networking and media;
graphic and interior design services, photography services, printing and publishing services;
legal services, medical services, accounting, auditing, bookkeeping and taxation services, engineering services, architectural services, surveying services, equipment rental services, hospitality services;
professional advice and/or consultation on education and/or personal enhancement; and
charitable initiatives which support areas including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion and other purposes that are beneficial to the community.

We cannot use or provide your personal information for direct marketing purposes and/or provide your personal information to third parties (whether to our Affiliates and/or our Marketing Partners) for their direct marketing purposes unless there is an applicable condition of use under PIPA or you consent. Even if you give your consent, you can opt out of direct marketing at any time (or you may request that we cease to provide your personal information to third parties, at which point we will cease to do so), free of charge, by emailing csc@bermuda.ctflife.com or writing to our Privacy Officer.

Your rights

Apart from your right to opt out of direct marketing as mentioned above, you have the following additional rights to:

check whether we hold any of your personal information;
access your personal information held by us;
request us to erase or destroy any personal information held by us;
Request us to limit or block the use of any personal information held by us;
require us to correct any personal information which is inaccurate; and
ascertain our policies and practices (from time to time) in relation to personal information and the types of personal information held by us.

If you would like to make a request in relation to the above (or make any general enquiries), please email csc@bermuda.ctflife.com or contact our Privacy Officer. In accordance with PIPA, we have the right to charge you a reasonable fee for the processing of a personal information access request, except where any such request results in the correction of an error or omission in such personal information.

Inconsistency or conflict

If there is any inconsistency or conflict between the English and Chinese version of this Privacy Notice, the English version shall prevail

Miscellaneous

This Privacy Notice may be updated from time to time to reflect changes to our policy with respect to personal information protection and/or changes to personal information /data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application and/or the Website (as the case may be) for updates to this Privacy Notice on a regular basis.

Nothing in this Privacy Notice shall limit your rights under PIPA.

I, as the Policy Owner and/or the Insured (if applicable) and/or the parent or legal guardian of the Minor (if applicable), confirm my respective consent by signing below in relation to (i) the collection, use and processing of personal information (including sensitive personal information) of myself as the Policy Owner and/or the Insured (if applicable) and/or the Minor (if applicable) in connection with the Purposes set out in the “Addendum” and “Annex A” and/or (ii) the transfer of personal information (including sensitive personal information) of myself as the Policy Owner and/or the Insured (if applicable) and/or the Minor (if applicable) to outside Bermuda and/or (iii) providing personal information (including sensitive personal information) of myself as the Policy Owner and/or the Insured (if applicable) and/or the Minor (if applicable) to third parties, shall be applicable to all existing policies which are in-force and/or waiting for reinstatement of myself as the Policy Owner and/or the Insured (if applicable) and/or the Minor (if applicable) as the Policy Owner and/or the Insured at CTF Life (if applicable).

This Privacy Notice shall be governed by, and construed in accordance with, the laws of Bermuda.