Our mobile software applications and/or web-based application platforms (Apps) are or are made available through our Site. We take the privacy of our Apps users very seriously. We ask that you read this Apps policy (Apps Policy) carefully as it contains important information about how we will use your personal data.
Our Apps are intended for use by those who can access it from within the Hong Kong Special Administrative Region (HKSAR). If you choose to access and/or use our Apps from locations outside HKSAR, you are responsible for compliance with local laws where they are applicable.
Personal Data We May Collect About You
Information that you provide
We will obtain personal information about you (such as your name, email address, phone number, personal description, payment details) whenever you complete forms and/or register user details on the App.
We will also obtain personal information you provide when you, for example, download to use the App, send us feedback, post material, contact us for any reason and by any medium, sign up to a service, make in-App purchases, share information via the App’s social media functions, complete a survey, report a problem with the App.
We may ask you to provide sensitive personal data, such as information about your health or your assets, when you submit information through our Apps to apply for and/or renew insurance policies. If we request such data, we will give you additional information as to why we are requesting sensitive personal data and how we will use it. We may retain a record of any contact you make with us.
Information that we will collect automatically
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the App. For further information about cookies and how to disable them please go to www.aboutcookies.org or www.allaboutcookies.org.
Device Information: We may also collect information about your device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface), the type of mobile browser that you are using, the mobile operating system that you are using, mobile network information, the time zone setting.
Information on Your Device: We may also collect information that is stored on your device each time you use the App. For example, we may collect contact information, login information, friends lists, photos, videos, and other digital content.
Location Data: We may also collect information to determine your location using GPS technology. Some of the features of the App may require access to such location data to work. If you would like to use any such feature, you will be asked to consent to provide such location information.
Information from Third-Parties: Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us improve and personalise the Apps for a better experience and service.
How We Use Your Personal Data through the Apps
We use your personal data for the following purposes:
- to help us identify you and any accounts you hold with us
- research, statistical analysis, and behavioural analysis
- customer profiling and analysing your purchasing preferences
- marketing - see 'Marketing and opting out', below
- fraud prevention and detection
- billing and order fulfillment (including in-App purchase fulfillment)
- credit scoring and credit checking - see 'Credit checking', below
- customising the App and its content to your particular preferences
- to notify you of any changes to the App or to our services that may affect you
- security vetting
- improving our services, and
- general purposes under our PICS
Marketing and Opting Out
Certain personal data of customers collected or held by us, in particular, names and contact information such as telephone number, email address and postal address may be used by Liberty and/or the Liberty Mutual Group of Companies to provide marketing materials and conduct direct marketing activities (including but not limited to promoting, marketing or selling of us, Liberty Mutual Group of Companies or co-branded insurance or financial or investment-related products or services by electronic or other means) in relation to insurance and/or financial products and services of us, the Liberty Mutual Group of Companies and/or other financial services providers. You may download the Opt-Out Form from here https://www.libertyinsurance.com.hk/sites/libertyhk/files/documents/Opt_Out_Form/Opt_Out_Form.pdf.
In the absence of any “opt-out” request from you, we shall treat the application and continuation of policy(ies) held with us as an indication of no objection to our use of such personal data for this voluntary marketing purpose.
Keeping Your Data Secure
We will use technical and organisational measures to safeguard your personal data, for example:
- access to your account is controlled by a password and username that is unique
- we store your personal data on secure servers; and
- payment details are encrypted using SSL technology
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet and/or through our Apps.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention, and compliance.
To enable us to make insurance policy decisions about you and members of your household and for fraud prevention and money laundering purposes, we may search the files of credit reference and fraud prevention agencies (who will record the search). We may disclose information about how you conduct your account to such agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit providers may use this information to make credit decisions about you and the people with whom you are financially associated, as well as for fraud prevention, debtor tracing, and money laundering purposes. If you provide false or inaccurate information and we suspect fraud, we will record this. We may be obligated to report our suspicions to the appropriate enforcement and regulatory agencies under applicable Laws.
Information About Other Individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data
- receive on his/her behalf any data protection notices; and
- give consent to the transfer of his/her personal data abroad
According to the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to of access to, correct and/or change any of your personal data held by us by contacting our Personal Data Privacy Officer at:
Telephone: (852) 2892 3888
Address: 13/F, Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong
In accordance with the Ordinance, a reasonable fee may be charged by us for the processing of any data access request.
Changes to this Apps Policy
We may change this Apps Policy from time to time. You should check this Apps Policy frequently to ensure you are aware of the most recent version that will apply each time you use the App.
In the event of any discrepancy or inconsistencies between the English and Chinese versions of this notice, the English version shall prevail.