PERSONAL INFORMATION COLLECTION
The Company recognizes its responsibilities in relation to the collection, holding, processing, use and/or transfer of Personal Information under the Civil Code and other relevant laws and regulations of Vietnam (the “Laws of Vietnam”).
- relating directly or indirectly to a living individual;
- which directly or indirectly identifies an identifiable person;
- from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
- in a form in which access to or processing of the data is practicable.
The Personal Information of customers (including, but not limited to, policyholders, insureds and beneficiaries) (the “Customer”) collected or held by the Company may be used, stored, processed, transferred or disclosed or shared for the following obligatory purposes (the “Purposes”):
- Processing and determining insurance applications, insurance claims and providing ongoing insurance services;
- Processing requests for payment and for direct debit authorization, if applicable;
- Managing, investigating and analyzing any claim, action and/or proceedings brought against the Customers, and to exercise the Company’s rights as more particularly defined in applicable policy wording, including, but not limited to, subrogation rights;
- Compiling statistics or using for accounting purposes;
- Meeting disclosure requirements of the Laws of Vietnam or any foreign law, regulations, codes or guidelines binding on the Company, its parent and affiliated companies (“Liberty Mutual Group of Companies”)
- Complying with the legitimate requests or orders of the competent People’s Court in Vietnam, the Insurance Supervisor Agency under the Ministry of Finance of Vietnam, auditors, governmental bodies and governmental-related establishments binding the Liberty Mutual Group of Companies;
- Conducting medical or health reference checks for relevant insurance products, if applicable;
- For management of IT environment and business operation;
- Ensuring security of the Company’s IT environment;
- Detecting and investigating illegal activity, including fraud, money laundering or terrorism financing;
- Complying with legal, regulatory and other good governance obligations, including respond to requests from public and governmental authorities (including those outside your country of residence);
- Monitoring and assessing compliance with the Company and the Liberty Mutual Group of Companies policies and standards;
- Achieving other legitimate business purposes, for example, to carry out insurance surveys, research and analysis, including analysis of the Company’s customer base and other individuals whose Personal Information the Company to analyze behavior, preferences and interests, develop new products, improve the Company’s services, identify usage trends, understand the interests of the Company’s users, to plan and execute business transactions (including joint ventures and business sales) and for other legitimate business purposes,
- Complying with any legal or regulatory obligations in Vietnam or overseas, if applicable;
- Establishing, exercising or defending legal rights of any member of the Liberty Mutual Group of Companies;
- Providing third party administration services;
- Direct marketing of the Company's services and products to the Customer via call, text message to the Customer's telephone number or by electronic or other means;
- Facilitating the Company’s authorized service providers to provide services to the Company and/or Customers for the above Purposes;
- Other purposes directly relating to any of the above; and
- Any other purposes the Company notify you at the time of obtaining your consent.
Please note that if you do not provide us with your Personal Information, the Company may not be able to issue your policy, process claims or provide insurance products or services to you or process your request.
Please ensure that you provide complete and accurate Personal Information to the Company and keep the Company updated on any changes to your Personal Information. Kindly note that if you do not provide complete and accurate Personal Information to the Company as and when it is required, it may have adverse consequences for you.
B. DIRECT MARKETING
Certain Personal Information collected or held by the Company, in particular, names and contact information such as telephone number, email address and postal address may be used by the Company 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 the Company, the Liberty Mutual Group of Companies or co-branded insurance by electronic or via call, text message to the Customer's telephone number or other means) in relation to insurance products and services of the Company, the Liberty Mutual Group of Companies and/or other financial services providers.
The Company shall use such Personal Information for marketing purpose stipulated in Section B.
C. TRANSFER OF PERSONAL INFORMATION
Your Personal Information will be kept confidential and may be held or stored locally, regionally or globally, whether in Vietnam or out of Vietnam.
Subject to the provisions of any applicable law, the Company may need to disclose your Personal Information to third parties, whether located within or outside Vietnam for one or more of the above Purposes. Your Personal Information may be made available to:
- Other Liberty Mutual Group of Companies and any other companies carrying on insurance or reinsurance related business, or an intermediary may have access to and use of Personal Information in connection with the conduct of the Company’s business where appropriate in order to fulfill one or more of the above Purposes.
- Any of Liberty Mutual Group of Companies in a service provider role, such as accountants, auditors, lawyers and other outside professional advisors; call center service providers; IT systems and management, IT support and security service providers; cloud providers, research and analytics service providers; claim investigators and adjusters; and similar third-party service providers that assist the Company in carrying out business activities;
- External third-party service providers such as, but not limited to, agents, contractors, bankers, legal advisors, investigators, loss adjusters, reinsurers, medical and rehabilitation consultants, emergency assistance companies, medical doctor panel groups, medical advisory consultants, surveyors, specialists, repairers, accountants and data processors or third party service providers who provide administrative, telecommunications, computer, payment, banking or other services to the Company in connection with the operation of its business;
- Other third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company’s business, assets or stock (including in connection with any bankruptcy or similar proceedings); to reinsurance companies;
- Any person to whom the Company is under an obligation to make disclosure under the requirements of any law binding on the Company or any other Liberty Mutual Group of Companies for the purposes of any regulations, codes or guidelines issued by governmental, regulatory or other authorities with which the Company or any other Liberty Mutual Group of Companies are expected to comply;
- Any person pursuant to any order of a court of competent jurisdiction;
- Any actual or proposed assignee of the Liberty Mutual Group of Companies or transferee of the Liberty Mutual Group of Companies’ rights in respect of the policyholders;
- The data center of the Liberty Mutual Group of Companies, or the Liberty Mutual Group of Companies in the United States of America may host such respective servers or may utilize third party servers which the Liberty Mutual Group of Companies would be the controller for processing, storage, and/or backup of Personal Information. Such data centers and/or servers are/may be located in Singapore, elsewhere in Asia, the United States of America, Europe and Latin America or such other countries/territories as determined by the Liberty Mutual Group of Companies from time to time;
- Providers of risk intelligence for the purpose of Customer due diligence or anti-money laundering screening;
- Other banking/financial institutions, commercial or charitable organizations with whom the Company maintains business referral or other arrangements for marketing communication if “no objection” is provided;
- Third party marketing service providers and insurance intermediaries for marketing communication if “no objection” is provided;
- Any actual or proposed purchaser of Company business or, in the case of a merger, acquisition or other public offering, the purchaser or subscriber for shares in the Liberty Mutual Group of Companies;
- An organization involved in maintaining, reviewing and developing the Company’s business systems, procedures and infrastructure including testing or upgrading the Company’s computer systems;
- Your duly authorized representatives, including your legal advisers;
- Anyone to whom you have given your consent;
- Other Company’s authorized service providers to provide services to you for the above Purposes for which the Personal Information are to be used; and
- As we believe to be necessary or appropriate, to comply with legal process, to respond to requests from public and government authorities including public and government authorities outside Vietnam, to enforce the Company’s terms and conditions, to protect the Company’s operations, to protect the Company’s rights, privacy, safety or property, and/or that of you or others, to detect and prevent fraud, and to allow the Company to pursue available remedies or limit the damages that the Company may sustain.
D. DATA PROCESSING OUTSIDE VIETNAM
The Company may share Personal Information with one or more of the Liberty Mutual Group of Companies, service providers or with third parties for the purposes described herein.
Some of these Liberty Mutual Group of Companies, service providers and third parties may be based in other countries and may not be subject to the Laws of Vietnam. By sharing Personal Information with the Company, you consent to the collection, use, processing and transfer of such information in accordance with this statement to the United States (where the Company’s headquarter is located) or other countries.
The Company will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this statement. However, you should note that where your Personal Information is disclosed to or accessed by parties located outside of Vietnam as provided above, your Personal Information may not be afforded the same protections as it is under the Laws of Vietnam.
E. ACCESS AND CORRECTION OF PERSONAL INFORMATION
According to the Laws of Vietnam, all policyholders have the right to of access to, correct and/or change any of their own Personal Information held by the Company by contacting the Company at: Liberty Insurance Limited, 18th Floor, Vincom Office Building, 45A Ly Tu Trong Street, District 1, Ho Chi Minh City, Vietnam.
PROTECTING INFORMATION GATHERED AND SECURITY
Personal Information you have provided is limited to employees and agents of the Company who need to know that information in order to service your request. The Company maintains physical, electronic, and procedural safeguards that comply with Laws of Vietnam to guard your Personal Information. The Company retains the information collected for as long as required or permitted by law or regulation.
NOTIFICATION OF CHANGES