Liberty Insurance Limited (“Liberty Insurance”), incorporated under the laws of Vietnam, is strongly committed to the protection of your personal data. This Notice sets out why and how we may “process”, in other words, collect, record, analyze, store, update, access, use, disclose, share, copy, transfer, erase, retrieve, provide, and/or disclose personal data (defined below), as well as assist you in making an informed decision before providing us your personal data or of other individuals, including personal data from minors.
What Liberty Insurance does with the Personal Data provided to us
The types of personal data we may process depends on the products or services we may provide you
Basic Personal Data such as:
a) Personal information: last name, middle name, first name, date of birth, gender, nationality, employment details
b) Identification information: identity card and/or personal identification number/s, passport number, driver's license, license plate, personal tax, social or insurance card number/s, images/photographs
c) Contact information: mailing address, home address, telephone number, email,
d) Family information: marital status, family relationships, dependents
e) Digital information: information collected automatically when using our websites and/or mobile applications such as IP information, cookies, logins
f) Communication information: phone call recordings to our hotlines, customer service lines, complaints, surveys, experiences, your communication preferences, and related information.
Sensitive Personal Data such as:
a) Financial & Transaction information: bank account, credit card, debit card, credit bureau records, payment/transaction records,
b) Insurance & Private information: claim history, medical and health records/diagnosis, police/law enforcement and/or court decisions/reports/investigations, genetic/pre or hereditary conditions, race/ethnicity, sexual orientation
The reasons we may process Personal Data depends on the products or services we may provide you
The Personal Data is primarily to assist in serving your interests and assists us to operate efficiently so we can continue to best serve your interests.
Hence, we may process your Personal Data for the below “Purposes”:
a) To perform our rights, obligations and maintain high level of services to you by:
b) To comply with applicable laws, regulations & maintain our standards by:
c) To continuously improve our products/services for you:
d) Other purposes:
How we collect or obtain Personal Data depends on the products or services we may provide you
We only process Personal Data i) when you provide us voluntary express consent, ii) to protect life/health of data subjects or others in emergencies, iii) per applicable laws or iv) fulfill obligations under contracts with data subjects.
As such, we may collect Personal Data through our websites, mobile applications, when you communicate with us, submit applications, claims, complaints, make requests, purchases, payments, subscribe, follow our social media or create customer accounts. Additionally, we may obtain Personal Data from one of our Liberty Mutual Group of Companies, business partners, service providers, insurance intermediaries, your representatives, employers, or other related third parties such as but not limited to police, hospitals, regulators, government, or public authorities.
Your consent may be withdrawn at any time (see “Your Rights” below). Withdrawal of your consent does not affect the lawfulness of our Personal Data processing prior to your withdrawal. Please note, if you refuse i) to provide us all or some of your Personal Data, ii) whom we may obtain or provide Personal Data, iii) to process Personal Data for all or some of the Purposes, or, iv) for if you provide us incomplete or inaccurate information, it may have undesirable consequences for you such as we may not be able to provide you all or some of our products/services, or at standards we promised or which you may have requested, including meeting obligations under the insurance contract.
Who we provide Personal Data depends on the products or services we may provide you
Subject to applicable laws, we may provide Personal Data to others for one or more of the above Purposes. Your Personal Data may be available to:
Retention & Security
We have reasonable policies and procedures in place to protect Personal Data provided to us and take all practicable steps to ensure the security of the Personal Data, to avoid unauthorised, accidental access, erasure, misuse, alternation, destruction, or other undesirable consequences. Despite our best efforts, protection cannot be absolutely guaranteed against all threats. To the best of our ability, access is limited to those Recipients stated above for any of the above Purposes and those who have access to Personal Data are required to uphold confidentiality and adhere to standards as dictated in this Privacy Notice.
We also make best efforts to retain Personal Data only for so long as necessary for any of the above Purposes or until we are asked by you for your Personal Data to be deleted (see “Your Rights & Obligations” below).
We may use your Personal Data for direct marketing purposes such as sending you, from time to time, by post and/or electronically:
that we consider may be of your interests related to your current insurance policy or certain products/services that may be offered by us, one of the Liberty Mutual Group of Companies or our business partners.
Persons under the age of 16 (“Minors”) shall not transmit Personal Data to us without consent of their parents/guardians. We do not knowingly solicit or collect Personal Data from Minors.
How to protect your Personal Data
Your Rights & Obligations
Subject to applicable laws, you have the below rights in respect of your Personal Data:
Additionally, you have the below obligations in respect of your Personal Data:
If you need to exercise your above rights, you may contact:
Liberty Insurance Limited, 18th Floor, Vincom Office Building, 45A Ly Tu Trong Street, District 1, Ho Chi Minh City, Vietnam
This Privacy Notice may be modified from time to time. We encourage you to periodically review this Notice to remained informed about how we are protecting your Personal Data.
In the event of any discrepancy or inconsistencies between the English and Vietnamese versions of this Notice, the Vietnamese version shall prevail.
Last update: 23 June 2023