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Privacy Statement

FWD Wellness Pass Privacy Statement

Protecting Your Privacy

"FWD Wellness Pass" Membership Program (the "Program") is a program operated and managed by FWD Life Insurance Company (Bermuda) Limited (incorporated in Bermuda with limited liability) ("FWD"). In order for you and your registered affiliated member(s) (if any) (the “Members”) to enjoy the benefits and services provided through the Program, FWD will collect personal data from you. FWD is committed to implementation and compliance with the provisions of the Personal Data (Privacy) Ordinance, and has implemented procedures to ensure that the Members's personal data is handled in a safe, secure, and responsible manner.

Personal Information Collection Statement ("PICS")

Collection, Use and Transfer of Personal Data

1. FWD will collect, process, generate and compile personal data about the Members and the purposes for which your personal data may be used are as follows:

  • Processing the Members' registration for or request of termination of membership of the Program;
  • Managing and maintaining the Members' membership account held with the Program;
  • Verifying your identity and eligibility to register as a member of the Program;
  • Processing the Members' request for registration of promotion campaigns and redemption of welcome gifts under the Program and sending you confirmation SMS or email upon the registration or redemption ;
  • Processing payment instructions;
  • Determining any indebtedness owing to or from the Members, and collecting and recovering any amount owing from the Members or any person who has provided any security or other undertakings for your liabilities;
  • Providing the Members with the services under the Program;
  • Handling and responding to the Members' enquiries in relation to the Program;
  • Designing new or enhancing existing services to be provided under the Program;
  • Performing marketing, statistical or actuarial research and analysis;
  • Meeting disclosure obligations and other requirements imposed by or for the purposes of any laws, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong) binding on FWD;
  • Sending the Members promotional materials and conducting direct marketing campaigns, including but not limited to FWD’s insurance and finance related products and offers; and
  • Fulfilling any other purposes directly related to any of the above.

2. The Members must provide FWD with personal data as required in the registration pages of the Program, otherwise FWD will not be able to process the registration and provide the services under the Program.

3. The Members' personal data will be kept confidential, but to facilitate the purposes set out in paragraph 1 above, FWD may transfer, disclose, grant access to or share the Members' personal data with the following parties (which may be located in or outside Hong Kong):

  • subsidiaries, holding companies, associated or affiliated companies of FWD;
  • any authorized FWD financial advisor, telemarketer, agent, contractor or service provider providing direct marketing, administrative, distribution, telecommunications, computer, data processing, payment processing, debt collection, printing, redemption or other services to the Program; and
  • business partners providing the offers, rewards or privileges under the Program; and
  • any official, regulator, ministry, law enforcement agent or other person (whether within or outside Hong Kong) to whom FWD is under an obligation or otherwise required or expected to make disclosures under the requirements of any law, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong).

4. In addition to the purposes set out in paragraph 1 above, FWD intends to use the main member’s name and contact details to send the main member updates or promotional materials (“Updates”) relating to the products and/or services offered by FWD. The Updates will be sent or communicated to the main member by way of e-mail, SMS, telephone calls or other appropriate means of communication.

5. FWD will only use the main member’s personal data for the purpose set out in paragraph 4 above if the main member provide the consent or do not object. If the main member do NOT wish to receive the Updates from FWD, the main member may exercise your right to opt-out anytime. For the avoidance of doubt, the opt-out from the Updates in the Program will not affect the main member’s consent for direct marketing previously provided to FWD under other circumstances.

Access to and Correction of Personal Data

6. Under the Personal Data (Privacy) Ordinance, you have the right to request access to the Member’s personal data, and request correction of any of your personal data which is incorrect. FWD has the right to charge the Member a reasonable fee for processing and complying with your data access request. For any requests for access to, or correction of the Member’s personal data in the Program, please email us or make your request in writing to our Data Protection Officer:

36/F, Hopewell Centre 183 Queen’s Road East, Wanchai Hong Kong

FWD Life Insurance Company (Bermuda) Limited

Should you have any queries, please do not hesitate to call our Customer Service Hotline on 3123 3320.

Retention of Personal Data

7. FWD will take practicable means to ensure that no personal data is kept for longer than necessary and that FWD will comply with all statutory and regulatory requirements in the Hong Kong concerning the retention of personally identifiable information. FWD will keep the Members' personal data as long as necessary to fulfil the purpose(s) for which the data was collected. We may also retain archived personal data for statistical purposes.

Personal data which is no longer required will be destroyed.

8. FWD will eliminate or delete any personally identifiable information that is unable to help in optimizing the Program as applicable laws permit.

9. Depersonalised data will be maintained by FWD to better serve current members and future members. Such data will be used for relevant processing in terms of service recovery, audit, security, etc.

Data Security

10. With its best endeavours, FWD will ensure that the Members' personal data will be stored and managed in a manner to protect it from potential inappropriate usage, unauthorized access, modification or disclosure. It is the practice of FWD to achieve appropriate levels of security by restricting physical access to data, providing secure storage facilities and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data and personal data is only transmitted by secure means.

11. To facilitate the purposes set out in paragraph 1 above, FWD may transfer, disclose, grant access to or share your personal data with the parties set out in paragraph 3 above (which may be located in or outside of Hong Kong). The Members' personal data may be transferred to places where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Personal Data (Privacy) Ordinance.

Accuracy of Personal Data

12. FWD will take practicable means to ensure the accuracy of all personal data collected and processed in the Program, and if such personal data is transferred to third parties, it will notify that third party of any correction to be made. Appropriate procedures are implemented so that all personal data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used.

Use of Cookies and Third Party Links

13. The Program’s website (“Website”) may include hyperlinks to third party websites. FWD has no control over the content, accuracy, opinion expressed, and other links provided at these third party websites or how these third party websites deal with your personal data. You should visit these third party websites for details of their privacy policies in relation to their handling of your personal data.

14. FWD may use “cookies” to improve its internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by the Website. Cookies enable the Website to remember you and your preferences when you visit the Website and enable FWD to tailor the Website to your needs. The information collected by cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser.

Changes to Privacy Statement

15. FWD reserves the right, at any time and without notice, to add to, change, update or modify this Privacy Statement. Such addition, change, update or modification will be posted on our Website and will be effective immediately upon posting. FWD will treat your use as acceptance of the updated Privacy Statement if you continue to use the service provided by the Program after the date on which the Privacy Statement has changed, updated or modified.

Enquiries or Complaint Handling

16. For any enquiries or complaint relating to the Members' personal data handling, please email us. FWD’s corresponding personnel will consider and process your enquiries or complaint within seven working days. FWD pledges to use its best endeavours to resolve any complaint to your satisfaction.