Personal Information Collection Statement - Hong Kong

International Planning Group Insurance Brokers, Ltd. (referred to hereinafter as the “Company”) recognises its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and applicable data protection laws. The Company shall be the data user (also known as data controller) of personal data for the purposes of applicable data protection laws. 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.

In order to provide you with our insurance brokerage services and other services set out in the "Purpose" section below, we may collect personal data directly from you or from other third parties.  The provision of your personal data is necessary for the purposes of entering into a contract with us or to receive the information, products or services you request. Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.

Purposes:  From time to time it is necessary for the Company to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by us for purposes (“Purposes”), including:

1.    providing insurance brokerage services to you, including assessing and evaluating your needs on insurance, wealth management, estate planning, business planning or other financial matters; 

2.    advising, facilitating or acting for you on matters relating to insurance, wealth management, estate planning, business or financial planning (including obtaining financing), or arranging insurance contracts on your behalf;

3.    offering, providing and marketing to you insurance products/services of local or offshore insurance companies or other insurance service providers (see “Use and provision of personal data in direct marketing” below);  

4.    preparing for you any applications for insurance, health and annuity products/services.  This will entail providing your personal data to insurance carriers for the purpose of obtaining life cover, as well as health, annuity and other insurance products;

5.    providing subsequent services to you, including but not limited to conducting face-to-face meetings or phone discussions for the purposes of reviewing and administering any products/services you have purchased; any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services you have purchased, including investigation of claims;

6.    any other reasonable purposes in connection with the provision of our brokerage services;

7.    designing products/services for customers;

8.    conducting market research for statistical or other purposes;

9.    matching any data held which relates to you from time to time for any of the purposes listed herein (with your consent where required by applicable law);

10.    making disclosures as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government, regulatory or tax authorities in Hong Kong or elsewhere;

11.    conducting identity checks;
 
12.    complying with the laws of any applicable jurisdiction;

13.    carrying out other services in connection with the operation of the Company’s business.

Under applicable data protection laws, we process your personal data for the Purposes set out above on the basis of one of the following legal bases: (a) where the processing of your personal data is necessary for the performance of the contract with you or to take steps at your request prior to entering into a contract with you; (b) where the processing is necessary for us to comply with a legal obligation that we are subject to; (c) where the processing is necessary for the purposes of our legitimate interests, which includes without limitation providing you with direct marketing, market research, providing you with products/services and designing products/services for customers; (d) where required under applicable laws, your consent; or (e) where permitted under applicable laws, notification to you. 

We do not normally ask you to specifically provide us with “Special Categories” of personal data but in some cases, special categories of personal data for purposes of identity verification. “Special Categories” of personal data are personal data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership, health, including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.

Transfer of Personal Data:  Personal data will be kept confidential and subject to the provisions of any applicable law.  Your personal data may be provided to the following recipients for the Purposes listed above:

1.    any of our affiliates, any person associated with the Company, third party insurance or reinsurance companies, claims investigation companies, industry associations or federations, or third party financial institutions (including referral bank partners) in Hong Kong or elsewhere and in this regard you consent to the transfer of your data outside of Hong Kong;

2.    any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to the Company and/or our affiliates in Hong Kong or elsewhere and who has a duty of confidentiality to the same;

3.    any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; 

4.    any government department or other appropriate governmental or regulatory authority in Hong Kong or elsewhere; and

5.    any affiliated entity of yours, as instructed by you.

For our policy on using your personal data for marketing purposes, please see the section below “Use and provision of personal data in direct marketing”.

Transfer of your personal data will only be made for one or more of the Purposes specified above.

Please note that if you are located in the European Economic Area (EEA) or UK, your personal data may be transferred to, and stored at, a jurisdiction outside the EEA, which may not provide the same level of data protection under applicable data protection laws in your jurisdiction. However, we will take steps that are reasonably necessary to ensure that your personal data is treated in accordance with applicable data protection laws, including, where relevant, entering into appropriate arrangements with the party outside the EEA receiving the personal data and you can request further information regarding the arrangements we have in place for this purpose by contacting us as set out below (under the section on "Your Rights"). 

Retention of Personal Data: We only store and process your personal data for the time necessary to achieve the Purposes for which the personal data is collected, in accordance with applicable data protection laws. 

Use and provision of personal data in direct marketing: 

1.    The Company intends to 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 purposes, and under the PDPO, the Company requires your consent (which includes an indication of no objection) for that purpose.

2.    The classes of services, products and subjects that may be marketed are: [insurance products/services, additional insurance advisory activities].

3.    The above services, products and subjects may be provided by [the Company and/or its affiliates, or third party local or offshore insurance companies, or other insurance service providers].

4.    In addition to marketing the above services, products and subjects itself, the Company also intends to provide the data described in paragraph (1) above to [its affiliates] for use by them in marketing those services, products and subjects, and under the PDPO, the Company requires your written consent (which includes an indication of no objection) for that purpose.

You may in the future withdraw your consent at any time to the use and provision of your personal data for direct marketing purposes.  If you wish to withdraw your consent, please inform us in writing to the address in the section on “Your Rights”.   The Company shall, without charge to you, ensure that you are not included in future direct marketing activities.

Your Rights:  Under the PDPO and other applicable data protection laws, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate.  You may also request the Company to inform you of the type of personal data held by it. 

In addition, [if you are located in the European Economic Area or the UK,] under applicable data protection laws you may also have the following rights: 

•    You may have the right to ask us to erase your personal data in certain circumstances;

•    In limited circumstances, you may have the right to request that we restrict processing of your personal data.

•    Under certain circumstances you may have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity;
•    Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. If applicable, this may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision;

•    Where we rely on your consent, you have the right to withdraw your consent at any time; 

•    You have the right to lodge a complaint with your local data protection authority.  

Requests to exercise your rights under applicable data protection laws or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:

Data Privacy Officer
International Planning Group Insurance Brokers, Ltd.
24/F Henley Building, 5 Queen’s Road Central, Central, Hong Kong

Where permitted under applicable data protection laws, a reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests.