Data Privacy Policy

PRIVACY POLICY STATEMENT
STATEMENT OF POLICY

The protection of privacy in relation to personal data is the concern of every person in AXA Wealth Management (HK) Limited (referred to hereinafter as the “Swiss Privilege”). Swiss Privilege respects personal data privacy and is committed to fully implementing and complying with the requirements under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by Swiss Privilege is accurate. Swiss Privilege will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.

STATEMENT OF PRACTICES
Information collected when you visit our websites

When you browse this website, cookies will be stored in your computer’s hard drive. The purpose of using cookies is to 1) facilitate the content display and successful redirection to the correct page upon your clicking on the changing banner; and 2) remember that you have visited our website as well as what interested you on our website, such as the pages you viewed.

We do not collect or store any personal data from you under this circumstance. You have a choice not to accept the cookies, but if you do, certain functionality, i.e. banner redirection and certain content display may not be available.

Statistics on visitors to our website

When you use this website, Swiss Privilege will record anonymous statistics about your visit and do not collect any information which identifies your personal identity until you in fact decide to buy any of our products. Our service providers make a record of your visit that includes but not limited to IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited, and time/duration and the pages visited.

Your visit to our website may be recorded for general analysis for website enhancement and optimisation. Anonymous information may be gathered through the use of cookies. These cookies include retargeting cookies and are placed by Swiss Privilege or by advertising networks that Swiss Privilege work with. We use these cookies to ensure that the advertising and website content that we serve you, on our site or other websites, is aligned to your browsing habits. For example, to remind you of the products or services you have shown an interest in. These cookies are also used to limit the number of times you may see an advert/content and to tailor the messaging we serve you. They may also be used for market research and to help measure the effectiveness of an advertising campaign.

If you would prefer, you can set your browser to disable cookies or inform you when they are set.

Third parties

We may engage with third parties to provide us with certain analytical services to better understand our visitors, who may use various third party technologies to collect and store anonymous information when you visit our website, and this may include using cookies, web beacons and similar mechanisms to collect information when you click on or move your cursor over their buttons. We may have access to this information to permit us to identify other websites that you have visited that are also associated with that third party. In doing so, however, these third parties do not collect personal information (unless you explicitly provide it to them), and we do not give any personally identifiable information to them. These third parties may collect certain non-personally identifiable information such as what web site a visitor came from, your IP address, and what type of browser you are using. These companies may also use non-personally identifiable information during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you, and we do not control the dissemination of these third party cookies, web beacons and similar mechanisms.

Links to third party

This Website may contain links to third party websites. Swiss Privilege does not provide your personal data to these third party websites. However, Swiss Privilege has no control over these third party websites. You should review the privacy policies applicable to these third party websites to understand the ways in which these third parties may collect and deal with your personal information.

Retention

Swiss Privilege ensures personal data is not kept longer than is necessary for the fulfillment of the purpose for which the data is or is to be used.

Security

Swiss Privilege applies strict measures to safeguard the confidentiality of personal data. We limit access to your personal data to people working for us on a business need to know basis who shall ensure that your personal data are protected against unauthorized or accidental access, processing, erasure, loss or use.

We store information under a secure site with 128-bit encryption. Personal data to and from Swiss Privilege is encrypted through the Secure Socket Layer (SSL) protocol.

Collection of Personal Data

From time to time it is necessary for Swiss Privilege to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by us for purposes (“Purposes”), including:

  1. offering, providing and marketing to you the products/services of Swiss Privilege , other companies of the AXA Group (“our affiliates”) or our business partners (see “Use and provision of personal data in direct marketing” below), and administering, maintaining, managing and operating such products/services;
  2. processing and evaluating any applications or requests made by you for products/services offered by Swiss Privilege and our affiliates;
  3. providing subsequent services to you, including but not limited to administering the policies issued;
  4. any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by Swiss Privilege and/or our affiliates, including investigation of claims;
  5. detecting and preventing fraud (whether or not relating to the products/services provided by Swiss Privilege and/or our affiliates);
  6. evaluating your financial needs;
  7. designing products/services for customers;
  8. conducting market research for statistical or other purposes;
  9. matching any data held which relates to you from time to time for any of the purposes listed herein;
  10. making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;
  11. conducting identity and/or credit checks and/or debt collection;
  12. complying with the laws of any applicable jurisdiction;
  13. carrying out other services in connection with the operation of Swiss Privilege’s business;
  14. other purposes directly relating to any of the above.

Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.

Transfer of personal data

Personal data will be kept confidential but, subject to the provisions of any applicable law, may be provided to:

  1. any of our affiliates, any person associated with Swiss Privilege, any reinsurance company, claims investigation company, your broker, industry association or federation, fund management company or financial institution in Hong Kong or elsewhere and in this regard you consent to the transfer of your data outside of Hong Kong;
  2. any person (including private investigators) in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by Swiss Privilege and/or our affiliates;
  3. any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to Swiss Privilege and/or our affiliates in Hong Kong or elsewhere and who has a duty of confidentiality to the same;
  4. credit reference agencies or, in the event of default, debt collection agencies;
  5. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
  6. any government department or other appropriate governmental or regulatory authority in Hong Kong or elsewhere.
  7. the following persons who may collect and use the data only as reasonably necessary to carry out any of the purposes described in paragraphs nos. 2, 3, 4 and 5 of the Purposes specified above: insurance adjusters, agents and brokers, employers, health care professionals, hospitals, accountants, financial advisors, solicitors, organisations that consolidate claims and underwriting information for the insurance industry, fraud prevention organisations, other insurance companies (whether directly or through fraud prevention organisation or other persons named in this paragraph), the police and databases or registers (and their operators) used by the insurance industry to analyse and check data provided against existing data.

For our policy on using your personal data for marketing purposes, please see the section below “Use and provision of personal data in direct marketing”.

Transfer of your personal data will only be made for one or more of the Purposes specified above.

Use and provision of personal data in direct marketing

Swiss Privilege intends to:

  1. use your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by Swiss Privilege from time to time for direct marketing;
  2. conduct direct marketing (including but not limited to providing reward, loyalty or privileges programmes) in relation to the following classes of products and services that Swiss Privilege, our affiliates, our co-branding partners and our business partners may offer:
    a.     insurance, banking, provident fund or scheme, financial services, securities and related products and services;
    b.     products and services on health, wellness and medical, food and beverage, sporting activities and membership, entertainment, spa and similar relaxation activities, travel and transportation, household, apparel, education, social networking, media and high-end consumer products;
  3. the above products and services may be provided by the Swiss Privilege and/or:
    a.     any of our affiliates;
    b.     third party financial institutions;
    c.     the business partners or co-branding partners of the Swiss Privilege and/or affiliates providing the products and services set out in (2) above;
    d.     third party reward, loyalty or privileges programme providers supporting Swiss Privilege or any of the above listed entities;
  4. in addition to marketing the above products and services, Swiss Privilege also intends to provide the data described in (1) above to all or any of the persons described in (3) above for use by them in marketing those products and services, and Swiss Privilege requires your written consent (which includes an indication of no objection) for that purpose.

Before using your personal data for the purposes and providing to the transferees set out above, Swiss Privilege must obtain your written consent, and only after having obtained such written consent, may use and provide your personal data for any promotional or marketing purpose.

You may in future withdraw your consent to the use and provision of your personal data for direct marketing.

If you wish to withdraw your consent, please inform us in writing to the address in the section on “Data Access and Correction”. Swiss Privilege shall, without charge to you, ensure that you are not included in future direct marketing activities.

Data Access ad Correction

Under the PDPO, you have the right to ascertain whether Swiss Privilege holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request  Swiss Privilege to inform you of the type of personal data held by it.

Requests for access and correction or for information regarding policies and practices and kinds of data held by Swiss Privilege should be addressed in writing to:

Data Privacy Officer

AXA Wealth Management (HK) Limited Customer Service Center:
Suite 2001, 20/F, Tower Two, Times Square, 1
Matheson Street, Causeway Bay, Hong Kong.

A reasonable fee may be charged to offset Swiss Privilege’s administrative and actual costs incurred in complying with your data access requests.

Enquiries

If you have any queries about our Privacy Policy and Practices, please address to the Data Privacy Officer.