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Policy on Personal Data
| 1. |
Dao Heng Insurance Co., Limited (“the Company”) is a subsidiary of Hong Leong Assurance Berhad which is a member of the Guoco Group and accordingly adheres to the Guoco Group policy on personal data set out below. The Guoco Group includes Guoco Group Limited together with its direct or indirect subsidiaries, associated companies, holding companies and any of the holding companies’ direct and indirect subsidiaries and associated companies, including but not limited to the Company, Dao Heng Securities Limited, Dao Heng Commodities Limited, Hong Leong Bank Berhad and Hong Leong Assurance Berhad, operating in the asset management, stock and commodity broking, investment advisory, banking, insurance, property development and investment and financial and related services, continued expansion of which is anticipated in Hong Kong, Malaysia, Singapore and elsewhere.
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| 2.
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Hong Kong legislation controls the collection, use and storage of personal information in respect of individuals (“data”). This policy is being provided to existing and prospective individual customers of the Guoco Group in Hong Kong (“customers”) from whom data have been and/or may in the future be collected.
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| 3.
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Customers have in the past and will in the future be required to provide data to the Guoco Group in connection with the establishment, provision and operation of financial and related services and products and all other services and products provided by the Guoco Group, both now and in the future. Also, in the ordinary course of continuing relationships with their customers, Guoco Group companies will collect further data, for example, when customers make payments or issue instructions.
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| 4.
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If a customer does not supply such data, this may result in the Guoco Group being unable to provide or operate services and products for the benefit of that customer.
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| 5. |
A customer’s data may be used by the Guoco Group for the following purposes and the customer hereby expressly invites the Guoco Group to use his/her data for the following purposes:-
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| (a) |
carrying out customer’s instructions, responding to enquiries by that customer or made on his/her behalf and providing customers with an effective and efficient service;
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(b) |
providing the customer with financial and related services, banking, investment management, asset management, advisory or other services, credit, trust, insurance, estate development, nominee or related services (whether provided by a Guoco Group company or a selected third party supplier);
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(c) |
purposes specifically provided for in any particular service or facility offered by the Guoco Group. Such procedures include matching procedures (as defined in The Personal Data (Privacy) Ordinance, but broadly includes comparison of two or more sets of the customer’s data, such as declining an application);
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(d) |
researching, designing, launching, promoting and marketing financial and other facilities, services and products of the Guoco Group and third parties (including but not limited to the exchange of non-financial information with selected business partners and developing marketing lists for exchange with selected business partners) and monitoring the provision, operation and use of such services or products;
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(e) |
provision of reference (status enquiries);
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(f) |
carrying out credit and other status checks and debt collection and assisting other institutions to do so;
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(g) |
ensuring ongoing credit-worthiness of customers;
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(h) |
operating internal controls including determining amounts owed to or by customers, payment to or collection of such amounts from customers and from any persons providing security for customers’ obligations and enforcing any charge or other security granted by or for customers;
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(i) |
performing treasury functions;
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(j) |
provision of services under the terms and conditions of the accounts a customer holds with the Guoco Group;
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(k) |
for operational purposes, credit assessment or statistical analysis;
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(l) |
the enforcement of customers’ obligations, including without limitation the collection of amounts outstanding from customers and those providing security for customers’ obligations;
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(m) |
(where the customer seeks or holds insurance from a Guoco Group company) assessing and analysing any insurance claim and assisting other insurance companies to conduct claims checks;
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(n) |
forwarding publicity materials or other information to customers from charitable organizations selected by the Guoco Group from time to time;
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(o) |
the performance of procedures for comparing the customer’s data with other information supplied by the customers (for whatever purpose), including, without limitation, procedures undertaken for the purpose of taking adverse action against the customer (whether or not such comparison is by manual or automated means);
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(p) |
meeting any legal, governmental or regulatory requirements in Hong Kong or any other applicable jurisdiction, including disclosure or notification requirements; and
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(q) |
assisting any person who is acquiring or participating in any contractual arrangements between the Company and the customer to evaluate the transaction for such acquisition or participation;
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and any other incidental and associated purposes relating to any of the above.
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| 6. |
Data held relating to a customer will be kept confidential but it may be provided to:- |
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(a) |
any person under a duty of confidentiality to the Company or to the Guoco Group, including but not limited to any company or division within Guoco Group (whether or not such company or division operates in Hong Kong, Malaysia, Singapore or elsewhere);
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(b) |
any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, securities clearing, insurance, professional or other services to the Guoco Group;
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(c) |
any banking, financial or other institution with which the customer has or proposes to have dealings;
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(d) |
any credit reference agency and in default debt collection agencies or similar provider of debt collection or credit information services to the Guoco Group;
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(e) |
(where the customer seeks or holds insurance from a Guoco Group company) any insurance company and any association or federation of insurance companies (whether or not based in Hong Kong);
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(f) |
any person or corporation to whom a Guoco Group company transfers or proposes to transfer its interests and/or obligations in respect of that customer or any product or service provided to that customer;
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(g) |
any nominee, trustee, co-trustee, centralised securities depository or registrar, custodian, insurance company, estate agent, solicitor or other person who is involved with the provision of Guoco Group services or products to that customer; or
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(h) |
any person by whom the Guoco Group is required by applicable legal, governmental or regulatory requirements to make disclosure;
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or to any other person reasonably requiring the same in order for the Company to carry out the purposes permitted in paragraph 5 above.
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The Company or the Guoco Group may disclose data to any or all of the parties stated above and may do so notwithstanding the recipient’s place of business is outside Hong Kong including but not limited to Malaysia and Singapore, or that such information following disclosure will be collected, held, processed or used by such recipient (including but not limited to the Company) in whole or in part outside Hong Kong.
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Without limiting the generality of clause 5 and this clause, the Company or the Guoco Group will disclose data to the Guoco Group and/or to any other party who, in each case, may from time to time be duly appointed to carry out data processing, analysis, outsourcing or other services, provided that, in each case, the applicable legal and regulatory requirements have been complied with.
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7. |
Any individual is entitled:
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(a) |
to ask whether a user of data holds data on them and to request access to and the correction of any such data held;
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(b) |
to ascertain the Company’s policies and practices in relation to data and to be informed of the kind of personal data held by the Company; and
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(c) |
in relation to customer credit:
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| (i)
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to request to be informed which items of data are routinely disclosed to credit reference agencies or debt collection agencies;
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| (ii)
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to be provided with further information to enable an access and correction request to be made to the relevant credit reference agency or debt collection agency; and
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| (iii)
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to ask the Company to request the relevant credit reference agencies to delete his consumer credit data once the credit has been fully repaid, if there is no payment default in excess of 60 days in the past 5 years. If an individual has any such payment default, the individual is liable to have his consumer credit data retained by the relevant credit reference agencies until 5 years from the final settlement date of the default amount.
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A reasonable fee will be charged for processing each data access request.
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8.
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Requests for access to or correction of data or for information regarding policies and practices and kinds of data held by the Company, should be addressed to The Data Protection Officer, Guoco Group Limited, 50th Floor, The Center, 99 Queen’s Road Central, Hong Kong.
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9.
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To help us to provide a better service to you, please ensure that your contact details including your home and office addresses, your telephone numbers (including your mobile telephone number), e-mail address and other details registered with us are up to date.
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10.
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If you do not want to receive any direct marketing or follow up regarding products and special promotions from the Guoco Group, please notify us in writing. No fee will be charged.
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11.
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The provisions of this policy may form part of the account terms and conditions and/or the agreement or arrangements that you have or may enter into with the Guoco Group. If any inconsistency is found, the provision of this policy shall prevail.
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12.
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In this policy, “subsidiary” and “holding company” shall bear the same meanings given to them under the Companies Ordinance of Hong Kong and “associated company” shall in relation to a company mean any company in the equity capital of which not less than twenty percent but not more than fifty percent of its shareholdings is held by the foregoing company.
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For more details about Data Privacy Ordinance, please refer to
Personal Data Privacy and the Internet - A Guide for Data Users and
Preparing On-line Personal Information Collection (PIC) Statements and Privacy Policy Statements (PPS) posted on Office of the Commissioner of Insurance.
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June 2006
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