Personal Data Protection Statement
Personal Data Protection Statement
Village Insurance Hong Kong Limited and its group companies (“Village Insurance Hong Kong”) take your privacy seriously and understand that you care about how your personal information is used and shared. We will only collect and use your personal information in accordance with the terms of this notice and in a manner that is consistent with our obligations and your rights under the applicable law.
This Privacy Notice explains the types of personal information we collect and how we use, disclose, and protect that information.
- PERSONAL DATA
As used in this Notice:
“Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“Personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, date of birth, and financial information. Other terms used in this Notice shall have the meanings given to them in the PDPO (where the context so permits).
- COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPO or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
Village Insurance Hong Kong may collect and use your personal data for any or all of the following purposes:
Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you.
Verifying your identity.
Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
Managing your relationship with us.
Processing payment or credit transactions.
Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
Any other purposes for which you have provided the information.
Transmitting to any unaffiliated third parties, including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Hong Kong or abroad, for the aforementioned purposes.
Any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you, such as to our technology partners and/or insurance underwriters.
To third-party service providers, agents, and other organizations we have engaged to perform any of the functions in connection with the above-mentioned purposes.
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
- WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of complying with your request. This may include any legal implications which may affect your rights and liabilities towards us. In general, we aim to process your request within ten (10) business days of receiving it.
While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you. In such circumstances, we will notify you before completing the processing of your request. If you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws, including the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong).
- ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for a copy of the personal data we hold about you or information regarding the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that a reasonable fee may be charged for an access request, in accordance with the Personal Data (Privacy) Ordinance. If a fee is applicable, we will inform you before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within twenty (20) business days. If we are unable to respond to your request within thirty (30) days of receiving it, we will inform you in writing within those thirty (30) days of the time by which we expect to be able to respond. If we are unable to provide you with any personal data or make a correction requested by you, we will generally inform you of the reasons, unless we are not required to do so under the Personal Data (Privacy) Ordinance.
- PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative, physical, and technical measures. These measures include, but are not limited to:
Minimizing the collection of personal data to what is necessary for our purposes.
Implementing authentication and access controls, such as strong password practices and limiting data disclosure on a need-to-know basis.
Encrypting data where appropriate and anonymizing personal data when possible.
Conducting regular security reviews and testing to ensure the effectiveness of our data protection measures.
These measures are designed to comply with the requirements of the Personal Data (Privacy) Ordinance and ensure the ongoing protection of your personal data.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
- RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
- TRANSFERS OF PERSONAL DATA OUTSIDE OF HONG KONG
While it may be necessary to transfer your personal data to countries outside Hong Kong, we will ensure that either (a) the standard of data protection in the recipient country is comparable to that of the Hong Kong Personal Data (Privacy) Ordinance (PDPO); or (b) that we will have a contractual agreement in place with the receiving party to ensure that your personal data is protected to the same standard as that prescribed by the PDPO.
- DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address:
Address: Room 1701,
17F Wanchai Commercial Centre,
194 Johnston Road, Wanchai, Hong Kong