AXA WEALTH MANAGEMENT(HK) LIMITED

SWISS PRIVILEGE

PERSONAL DATA PRIVACY POLICY STATEMENT

AXA Wealth Management (HK) Limited is an insurance company providing insurance and other financial products and services in Hong Kong ("our Business") and is an authorized insurer under the Insurance Companies Ordinance (Cap 41). Swiss Privilege is one of AXA Wealth Management (HK) Limited's authorised insurance agents in Hong Kong. References in this Statement to "we" or "us" include both AXA Wealth Management (HK) Limited and Swiss Privilege.

In order to carry on our Business we need to collect, hold, use, transfer and disclose certain information concerning our customers and other individuals such as persons covered by, or the beneficiaries of, the insurance policies we issue ("Relevant Persons"). Some of this information constitutes personal data for the purposes of the Personal Data (Privacy) Ordinance (the "PDPO").

We respect the privacy of our customers and other Relevant Persons and are committed to protecting the personal data we have collected on each customer or the Relevant Persons connected with such customer or which arises during our relationship with such customer (hereinafter referred to as "Customer Personal Data").

This Statement sets out our policies and practices with regard to Customer Personal Data and explains what Customer Personal Data we collect and why. By using our Web Site you agree, on behalf of yourself and all Relevant Persons connected with you, to our use of Customer Personal Data in accordance with the terms set out in this Statement.

This Statement is a statement of our policies and practices only and is not intended to, nor shall it, create any legal obligations binding on us provided always that nothing in this Statement shall exclude or limit the rights of any data subject under the PDPO.

Our Privacy Policy

We undertake to comply with the PDPO, and in particular the data protection principles set out in the PDPO, to the extent the PDPO and such data protection principles apply to Customer Personal Data. In practice this means:

• We take reasonable steps to protect the privacy of Customer Personal Data and to prevent use by unauthorised persons or for unauthorised purposes although customers recognize that they are primarily responsible for the security and maintaining the confidentiality of their Customer Login and Password
• We use reasonable endeavours to keep the Customer Personal Data we hold accurate and up-to-date although customers acknowledge that they are primarily responsible for informing us of any changes in the Customer Personal Data they have provided to us
• We only retain Customer Personal Data for such period as may be reasonably necessary in connection with the provision of the products or services we provide or to comply with our regulatory, legal or accounting obligations

The following sections of this Statement set out what sort of Customer Personal Data we collect, why we collect it, the purposes for which we may use or disclose it and finally who data subjects can contact if they require access to or the correction of any of their Customer Personal Data we may hold.

What sort of Customer Personal Data do we collect?

When you apply for products or services we offer we may ask you to provide certain information concerning yourself or Relevant Persons connected with you. Such information includes, but is not limited to, the following:

(i) name, Hong Kong identity card number, marital status and other personal details;

(ii) contact details including personal, home and business address, telephone and fax numbers;

(iii) salary details and other personal and business financial information;

(iv) details of other insurance, financial and investment products held and claims history; and

(v) financial, medical, health and occupational history.

When you visit our Web Site we may collect information through the use of "cookies" - small data files sent to your web browser and stored on your hard drive. These data files contain information we can use to track such things as passwords, pages you've visited and the date when you last looked at a certain page. We use this information for internal purposes only. You can disable this feature by changing the setting on your browser. However, if you do you may lose certain functionality on our Web Site.

Additional Customer Personal Data, such as details of the policies or investments you hold with us and financial and claims information, will also be generated during the course of our business relationship with you.

Where we tell you that you must provide particular information to us and you choose not to do so this may impact on our ability to provide you with products or services or to administer our business relationship with you or Relevant Persons efficiently and effectively.

Why do we collect Customer Personal Data?

The purposes for which we collect Customer Personal Data vary depending upon the nature of our business relationship with particular customers but broadly speaking we collect Customer Personal Data for the following purposes:

(i) to evaluate potential insurance and financial needs;

(ii) to process applications for and administer the products and services offered by AXA Wealth Management (HK) Limited (including, without limitation, to carry out or assist with medical and clinical assessments and status checks) and for promotional and marketing purposes;

(iii) to communicate with Relevant Persons and to approve, underwrite, service, administer and reinsure insurance policies and financial products or services purchased from AXA Wealth Management (HK) Limited.

(iv) to process claims;

(v) to enforce the obligations and liabilities you owe to us and to protect our commercial and business interests including, without limitation, the collection of debts;

(vi) to promote and offer products or services offered by AXA Wealth Management (HK) Limited or by third parties if we consider such products or services may be of interest to you;

(vii) to improve the type, nature and extent of the products and services we offer;

(viii) to comply with all laws, statutes, rules, regulations and codes of conduct and practice binding on us in relation to our Business or Customer Personal Data or binding on AXA Wealth Management (HK) Limited;

(ix) for the purposes of statistical or actuarial research carried out by AXA Wealth Management (HK) Limited or in which we participate; and

(x) for other purposes connected with, or necessary to carry out any of, the activities set out above.

Disclosure

Generally speaking we do/will not disclose your Customer Personal Data to anyone outside AXA Wealth Management (HK) Limited or Swiss Privilege. You agree to us disclosing your Customer Personal Data to persons within AXA Wealth Management (HK) Limited or Swiss Privilege, even if they are outside Hong Kong.

However, we may disclose and/or transfer Customer Personal Data to the following persons outside AXA Wealth Management (HK) Limited or Swiss Privilege (and you hereby agree to us doing so):

(i) our auditors, accountants, lawyers and other professional advisers;

(ii) our insurers and reinsurers;

(iii) regulatory or other authorities; and

(iv) third party providers of products or services we consider may be of interest to you;

(v) our agents, employees, sub-contractors or third parties providing services to us in connection with our Business who need to know such information for that purpose; and

(vi) persons outside AXA Wealth Management (HK) Limited or Swiss Privilege, provided they have first undertaken to us to keep such information confidential.

You also agree that we shall be entitled to transfer your Customer Personal Data to a purchaser of substantially all of our assets or our Business who intends to carry on a similar business offering similar products and services.

Who you can contact in relation to Customer Personal Data matters?

We may from time to time contact you directly via post, e-mail or telephone offering you products and services that may be of interest to you. You can tell us that you do not want to receive direct marketing or promotional material and if you do we will remove your contact details from our database.

In accordance with the PDPO this Statement notifies you that you have the right to contact us to find out whether we hold any of your Customer Personal Data, to access such data and if such Customer Personal Data is inaccurate or misleading a right to have it corrected.

Data access and correction requests and any other queries or questions regarding Customer Personal Data should be addressed to:

head of the Policyowners' Service Department
20/Floor, AXA Centre,
151 Gloucester Road, Wanchai, Hong Kong

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