Privacy policy

This policy provides information on the obligations and policies of Chartis Insurance Hong Kong Limited (“Chartis HK”) and member companies of American International Group, Inc. (“ AIG ”) (collectively called “Chartis affiliates”) in relation to the personal data collected from customers in Hong Kong and Macau (including via its websites at www.chartisinsurance.com.hk, www.chartisdirect.com.hk, www.chartisinsurance.com.hk/travelwise, www.chartisinsurance.com.hk/hkptu, www.chartisinsurance.com.hk/travelcompass, www.chartisinsurance.com.hk/macau and www.chartisinsurance.com.hk/anh/csd ). The policy is designed to assist you in understanding why and how Chartis HK collects and uses your personal data and to whom data access or “opt-out” requests can be addressed. Chartis HK reserves the right to amend this policy at any time and will place any such amendments on this website. Any change, will be effective immediately upon being posted on this website. In case of discrepancies between the English and Chinese versions of this policy, the English version shall prevail.

1. How do we collect personal data?

   The principal ways Chartis HK collects personal data is through its application forms for its insurance products, by phone through telephone applications, or through registration made via its websites. Our websites use "cookies" to gather statistical information concerning web traffic and usage patterns. Cookies do not track your name, e-mail address, or similar personal information.

2. What types of personal data do we collect?

   Depending on your relationship with Chartis HK (for example, as a consumer policyholder; non-policyholder insured or claimant; witness; commercial broker or appointed representative; or other person relating to our business), personal data collected about you and your dependants may include:

   1. General identification and contact information

      Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.

   2. Identification numbers

      Identity Card number; passport number; or driver’s or other license number.

   3. Financial information and account details

      Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.

   4. Medical condition and health status

      Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.

   5. Other sensitive information

      In certain cases, Chartis HK may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).

   6. Telephone recordings

      Recordings of telephone calls to the representatives and call centers of Chartis HK.

   7. Information to investigate crime, including fraud and money laundering

      For example, insurers may share information about their previous dealings with policyholders and claimants for this purpose.

   8. Information enabling us to provide products and services

      Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; and other insurance you hold.

3. Purposes for which customer’s personal data may be collected and used

   Our overriding principle is only to collect any of the above personal data which we believe to be relevant and required to understand our customer’s insurance needs, to conduct our business and to provide better customer services and products. In this respect, the particular purposes for which personal data may be collected and used by Chartis HK and Chartis affiliates are as follows:-

   1. Providing insurance, financial services or related products and services to customers and administering, maintaining, managing and operating such products and/or services;
   2. Sending customers important information regarding changes to the policies of Chartis HK and/or Chartis affiliates, other terms and conditions, the websites and other administrative information;
   3. Processing, assessing and determining any applications or requests made by customers for insurance products or services;
   4. Any purposes in connection with any claims made under any insurance products or in respect of any services provided by Chartis HK or Chartis affiliates including, without limitation, making, defending, analysing, investigating, processing, assessing, determining or responding to such claims;
   5. Performing any functions and activities related to the insurance products and/or services provided by Chartis HK or Chartis affiliates including, without limitation, obtaining reinsurance, auditing, reporting, performing market research, and general servicing and maintenance of online and other services;
   6. Managing the infrastructure and business operations of Chartis HK and/or Chartis affiliates, and complying with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
   7. complying with applicable laws and regulatory obligations (including laws outside Hong Kong and Macau), such as those relating to anti-money laundering and anti-terrorism and legal processes; and responding to requests from public and governmental authorities (including those outside Hong Kong and Macau);
   8. Matching any data held by Chartis HK or Chartis affiliates relating to customers from time to time for any of the purposes listed in this statement;
   9. Meeting the requirements to make disclosure pursuant any law binding on Chartis HK or any of the Chartis affiliates or for the purposes of complying with any regulations or guidelines issued by any regulatory or other authorities which has jurisdiction over Chartis HK or any Chartis affiliates;
   10. Exercising any rights Chartis HK or Chartis affiliates may have in connection with the provision of insurance products and services to its customers;
   11. Conducting identity checks, such as for the purposes of verifying a customer’s identity in order to respond to that customer’s request to be provided with a duplicate policy or other documentation, any request made by a customer to change his/her address in our records, or any request by a customer to change his/her bank account or payment or other details in our records;
   12. Conducting credit checks on customers - such as analyzing, verifying and/or checking a customer’s credit, payment and/or status in relation to his/her ability to use the services;
   13. Determining any amount of indebtedness owing to or from a customer, and collecting and recovering any amount owing from a customer or any person who has provided any security or undertaking for such customer’s liabilities;
   14. providing improved quality, training and security (for example, with respect to recorded or monitored phone calls to Chartis HK’s contact numbers);
   15. resolving complaints, and handling requests for data access or correction;
   16. preventing, detecting and investigating crime, including fraud and money laundering, and analyse and manage other commercial risks;
   17. Enabling an actual or proposed purchaser, assignee, transferee, participant or sub-participant of Chartis HK’s or any Chartis affiliate’s rights or business to evaluate the transaction intended to be the subject of the reorganization, merger, sale , joint venture, assignment, transfer, participation or sub-participation;
   18. Marketing to customers the following services and products :
       1. insurance, financial and related services and products;
       2. reward, loyalty or privileges programmes and related services and products; and
       3. services and products offered by Chartis HK's business partners in joint promotion arrangements (being mainly financial related products). The categories of business partners with whom we currently have joint promotion arrangements are financial institutions and professional members associations;

       These services or products may be provided and/or marketed by Chartis HK and/or any member of the Chartis or AIG groups of companies , third party reward, loyalty or privileges programme providers and business partners of Chartis HK and/or Chartis affiliates which engage in joint promotion activities; and

   19. Any purposes relating to the above or any other purposes in accordance with Chartis HK’s general policies or those of Chartis affiliates in relation to insurance and financial services as set out in statements, circulars, notices or other terms and conditions made available by Chartis HK and/or Chartis affiliates to customers from time to time.
4. Classes of persons to whom personal data may be disclosed

   Personal data held by Chartis HK will be kept confidential but Chartis HK may disclose or transfer such data to any of the following classes of persons in fulfilment of any of the purposes listed in the above section.

   1. Any Chartis affiliates.
   2. Any companies carrying on insurance and/or reinsurance related business.
   3. Any insurance intermediaries.
   4. Any insurance claims investigators.
   5. Any associations and federations of insurance companies that exist from time to time.
   6. Any insurance agents and professional advisers.
   7. Any other service providers providing insurance and/or reinsurance related business.
   8. Any companies with whom Chartis HK may embark on joint promotion activities (for the purposes of such activities only and in this respect only the name, telephone number and e-mail address of the customers will be transferred) – see 18(c) in the above section for further details.
   9. Any person in connection with any claims made by or under or otherwise involving any products or services provided by Chartis HK or Chartis affiliates.
   10. Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, data processing or storage, or other services to Chartis HK or Chartis affiliates in connection with the operation of the business of Chartis HK and any of Chartis affiliates.
   11. Any credit reference agencies or, in the event of default, any debt collection agencies.
   12. Any person under a duty of confidentiality to Chartis HK or Chartis affiliates which has undertaken to keep such data confidential.
   13. Any actual or proposed purchaser, assignee, transferee, participant or sub-participant of Chartis HK’s (or any Chartis affiliate’s) rights or business.
   14. Any person to whom Chartis HK or Chartis affiliates are under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice or guidelines binding on Chartis HK or Chartis affiliates including, without limitation, any applicable regulators, governmental bodies, or industry recognised bodies, and where otherwise required by law.
   15. Any registers of claims which are shared with other insurers for the purpose of detecting, preventing or investigating fraudulent claims (and for these purposes, Chartis HK may search such registers).
5. Data Security

   Chartis HK and Chartis affiliates takes appropriate technical, physical, legal and organization measures to handle personal data in a secure manner which are consistent with the Personal Data (Privacy) Ordinance (Cap. 486). Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with Chartis HK is no longer secure (for example, if you feel that the security of any personal data you might have with Chartis HK has been compromised), please immediately notify Chartis HK by writing to Chartis HK at GPO Box 456 or cs.hk@chartisinsurance.com or telephone us at the appropriate number shown in the ‘Contact Us’ section of this website.

   Access to Chartis HK’s web site's servers is limited to employees, agents, and contractors of Chartis HK. Standard practices require these personnel to preserve the confidentiality of user information they receive while performing their jobs and conducting the business of Chartis HK.

   Chartis HK’s staff are trained on how to handle personal data in a secure, confidential and appropriate manner.

6. Retention of personal data

   Chartis HK will destroy any personal data it may hold in accordance with its internal policy which accord with the following principles:

   1. personal data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which such data was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
   2. personal data is purged from Chartis HK’s electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and Chartis HK’s internal procedures.
7. Transfer of personal data outside of Macau and Hong Kong

   Personal data collected in Macau , by Chartis HK’s Macau branch is transferred to Chartis HK’s head office in Hong Kong , a jurisdiction which has laws protecting the use and processing of personal data in the form of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”).

   Personal data collected in Hong Kong by Chartis HK (including data collected by its Macau branch) is likely to be transferred to places outside of Hong Kong (such as to AIG or Chartis secure data centres, Chartis affiliates, service providers, business partners and governmental or regulatory authorities) in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.

8. Access and correction of personal data

   Each customer of Chartis HK has the following rights in respect of the personal data he/she has provided to Chartis HK:

   1. to check whether Chartis HK holds data relating to him/her and to access such data;
   2. to require Chartis HK to correct any data relating to him/her which is inaccurate; and
   3. to ascertain Chartis HK’s policies and practices in relation to personal data and to be informed of the kind of personal data held by Chartis HK.

   To exercise any right of access and correction of personal data above you may write to Chartis HK at GPO Box 456 or cs.hk@chartisinsurance.com. Chartis HK will, upon satisfying itself of the authenticity and validity of the access request, make every endeavour to comply with and respond to the request within the period set by the Ordinance.

9. Marketing Preferences and opt-out of personal data for direct marketing

   You may at any time inform Chartis HK whether you object to the intended use by Chartis HK and/or provision of your personal data to Chartis HK’s business partners for direct marketing by writing to Chartis HK at GPO Box 456 or cs.hk@chartisinsurance.com.

   You may opt-out of receiving all direct marketing channels from Chartis HK, or simply state your preferences as to the channels of communication from which you wish to opt-out. For example:

   1. Receiving e-mails from Chartis HK: If you no longer want to receive marketing-related e-mails from Chartis HK, you may opt-out by clicking on the link to “unsubscribe” provided in each e-mail or by contacting Chartis HK at the above addresses.
   2. Receiving mobile messages (for example SMS text messages) / telephone communications / postal mail from Chartis HK: If you no longer want to receive mobile messages / telephone communications / postal mail from Chartis HK, you may opt-out by contacting Chartis HK at the above addresses.
   3. Transfer of your personal data with Chartis affiliates for their marketing purposes: If you would prefer that Chartis HK does not share your personal data for marketing purposes with any of its affiliates, you may opt-out of this sharing by contacting Chartis HK at the above addresses.
   4. Provision of your personal data with selected third-party business partners for their marketing purposes: If you would prefer that Chartis HK does not provide your personal data with any of its business partners (as stated in paragraph 18(c) in the above section III) for marketing purposes, you may opt-out by contacting Chartis HK at the above addresses. Such request may specify i) which categories of Chartis HK’s business partner(s) you do not wish your personal data to share with; and/or ii) which types of services in respect of which you prefer not to receive direct marketing.

   Upon receipt of any opt-out request from you, Chartis HK will, at no cost to you, act on your request and ensure that your personal data will not be used as indicated in your request and, if applicable, notify the third party business partners to cease to use your personal data for direct marketing purposes in accordance with your written opt-out request(s) within a reasonable time period.

10. Other information Chartis HK collects through this website

    In addition to personal data, Chartis HK may collect other data through its websites. The types of information and how they are collected through the websites are set out in the attached link.

11. Third Party Websites

    This Privacy Policy does not address, and Chartis HK is not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this website contains a link. The inclusion of a link on this website does not imply endorsement of the linked site by us or by any of Chartis affiliates.

12. Use of website by Minors

    This website is not directed to individuals under the age of eighteen (18), and Chartis HK requests that these individuals do not provide personal data through this website.