[NEW] *Personal Information collection Statement relating to the Personal Data (Privacy) Ordinance (“the Ordinance”) (Effective 1 January 2018)
*Note: You may be subject to paragraph 6 of the previous version of this statement that was effective from 1 December 2015 if you have not indicated your marketing communication preferences in relation to the current statement.
We may from time to time update or amend this Policy and all information will be governed by our most recent Policy. Our most recent Policy will be available on our website at www.bupa.com.hk .
Collection of your information
We do not collect information about individuals, except where this is specifically stated and provided with your knowledge. We collect various types of personal information to enable us to provide you with health insurance and related products and services. We may ask you to supply personal information about you including without limitation:
- your name, date of birth, address, telephone number, gender and email address;
- information about your health;
- your billing information, credit card number, credit card expiry date, credit card security code, or other payment information; and
- information about your computer and devices used by you to access our services.
We may also collect aggregate data that does not allow you to be identified. This data helps us understand your needs so that we can better adapt our services and products. We may share aggregate data about you with third parties, including for advertising or marketing purposes.
We may collect personal information from you in a range of ways including:
- when you complete an application form or another type of form in relation to our products and services;
- when you contact us in person, by phone, via mail, email or online;
- when you lodge a claim;
- when you participate in a chronic disease management program;
- when you participate in our wellbeing program;
- when you enroll in marketing activities/customer communications;
- when you register to access our web apps/mobile applications/health tools; and
- when you opt for new services in relation to your policy.
We will always try to collect your personal information directly from you. However, there may be instances where we will need to collect your information from other persons or entities, including in the following circumstances:
- If you are covered by a family or couples health insurance policy, we may collect information from another person on the policy;
- When we underwrite your policy or when you make a claim for benefits, we may collect information from medical providers or hospitals in order to provide you with a policy and assess a claim;
- If you are a corporate customer, we may collect information from your employer; and
- If you have authorized an insurance broker or agent to act on behalf of you, we may collect your information from your insurance broker or agent.
- If you do not provide us with the necessary information, we may not be able to pay you benefits, or provide you with health insurance or related products or services.
Use and disclosure of your personal information
We use your personal information primarily:
- to provide, manage and administer our products and services to you;
- to register you as a member and manage your membership;
- to provide you with customer service and respond to your requests;
- to enable us operate our business efficiently and sustainably;
- to improve marketing and promotional efforts and product and service offerings; and
- to provide you with: (i) information, materials and newsletters relating to our health and insurance related products, services or benefits, and third party health services and medical products, which we consider of potential benefit to you and your family; and (ii) personalised medical information; and
- to enable you to utilise our health forums, online health assessment programs and mobile applications.
In providing you with our products and services, we may disclose personal information to other organizations or agencies that are bound to handle your information in the same way we do. The circumstances where we may disclose your personal information to such third parties include:
- When another organization helps us process transactions, store data, access data or provide services to you in order for them to perform their role. Our business terms ensure that these contractors only use your personal data in connection with the purposes outlined above, and prohibit our contractors from using your personal information for their own purposes (including direct marketing).
- Where laws require or allow us to provide information to a government agency, regulatory body or authorized authority;
- When a hospital or provider helps administer a claim that has been made for hospital or ancillary items or services (eg hospitals, doctors and other ancillary providers);
- When you are not the policy holder and membership details and benefit payments need to be confirmed with the policy holder;
- In connection with a merger, acquisition or sale of all or a substantial part of our business with or to another company; and
- where you have given your express consent.
Bupa will not sell your personal information to anyone. Only with your consent, or with your indication of no objection, from time to time, Bupa may use your personal information including your name, contact details, gender, health and family status to provide you with marketing communications about our and our group companies’, a co-branded partner’s or business partner’s insurance, medical, healthcare, financial and related products and services, and donations and contributions for charitable and/or non-profit making purposes.
If you do not wish to receive marketing material from us, please write to us at any time at: 18/F, Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong, or at firstname.lastname@example.org .
Security of your information
We take reasonable steps to ensure your personal information is kept secure from unauthorized access or disclosure, including steps to ensure that it is stored correctly and is protected from misuse and loss from unauthorized access, modification or disclosure. This includes a range of systems and communication security measures, as well as the secure storage of hard copy documents. In addition, access to your personal information will be restricted to those properly authorized to have access.
Even though we take steps to secure your personal information, you should be aware that no system is impenetrable and no information provided over the Internet is totally secure. Accordingly, we cannot guarantee the security of information that you transmit or receive over the Internet. Users are requested not to send confidential details or credit card numbers, for example, by email, unless specifically requested by Bupa.
Retention of personal information
We keep your personal information for as long as it is required to provide you with the products and services you requested from us and to comply with legal requirements. If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely delete or destroy your personal information.
Your privacy online
The information handling processes outlined in this section relate to any personal information collected online via our website located at www.bupa.com.hk ("our website"). www.bupa.com.hk
We do collect information on a visitor’s activity on the website. This is commonly referred to as ‘web analytics’ information, which may include (but is not limited to) information such as where the visitor has come from (eg referring domains, search engines, marketing campaigns), the type of browser or operating system used to access our website, pages viewed, date and time of access, the site path of the visitor, which content visitors are clicking on, which products visitors are interested in and purchase.
We do not collect any personal information (eg name, address, email address) using the web analytics but we do collect IP addresses. Bupa does not link any ‘web analytics’ information to an individual. Bupa uses this information to ensure that Bupa websites are providing the best possible customer experience and providing relevant products.
We also use "cookies" which are alphanumeric identifiers that are stored by your web browser on your hard-drive relating to your preferences, which enable our system to recognize you when you visit the site. This helps us track basic visitor information so that we can better tailor our website to your needs. Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you so wish. However, if you do so you may not be able to take full advantage of our website.
We may share overall visitor trends and other generic information collected on our website with third parties but we will not disclose any personal details or personally identifiable information without your specific consent.
We do collect non-specific visitor information by third-party web beacons and cookies from vendors, including Oracle, Google & Yahoo, via the means of web analytics tools such as Omniture and Yahoo Web Analytics, Google Analytics and Yahoo Web Analytics on most parts of the website, in order to provide advertisements about goods and services of interest to an individual. This information is related to your browser and operating system and does not include any personal details. You can find out more about Omniture and Google Analytics , Yahoo Web Analytics on their respective websites.
Our website contains links to websites operated by third parties. We have no control over the content of the linked websites or the way in which the operators of those websites deal with your personal information. We encourage you to review the privacy policies applicable to these third party websites to understand the ways in which your personal data may be used by those third parties.
Access and correction of personal information
You have the right under the Ordinance to request access to and correction of any personal information that you provide to Bupa. You may make such a request by writing to the Privacy Officer at: 18/F, Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong, or at email@example.com . In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any data access or correction request.
Terms and Conditions of Use
Use of the website
3. You must not do (or attempt to do) any of the following acts, nor assist others to do any of the following acts:
- use the website for any activities which breach any applicable laws or infringe the rights of any third party.
- use the website to post or transmit information or material: that is defamatory, abusive, offensive or vulgar; or that is of a commercial nature or intended to solicit business.
- knowingly transmit any viruses or other computer programs that may damage or interfere with the website.
- tamper with or modify the website.
- use the website to send unsolicited electronic messages.
Notice and Disclaimer
4. Unless otherwise specified, the materials on this website are directed solely at those who access this website from Hong Kong. Bupa makes no representation that any information, product or service referred to in the materials on this website is appropriate for use, or available, in other locations. Those who choose to access this website from other locations are responsible for compliance with local laws if and to the extent local laws are applicable.
5. Unless otherwise stated, this website is for information only. Bupa has used all reasonable care and skill in compiling the content of this website but to the extent permitted by law, makes no warranty as to the suitability or accuracy, completeness or reliability of any information on this website for any purpose. Bupa shall not be liable for any errors or omissions in any material on the website.
Bupa disclaims all warranties and conditions with regard to information or material contained on the website, including any implied warranty of merchantability or fitness for a specific purpose. Bupa makes no warranty or representation regarding your access to the website or any content accessed via the website, including without limitation: (i) that your access to the website will be uninterrupted and error-free; (ii) that the website and/or server is free from viruses or harmful components; and (iii) that any defects will be corrected.
6. Sometimes we include content featuring or graphically representing medical or surgical procedures, which are only ever provided for educational or informative purposes. If you find or are likely to find such images offensive please do not view them or if necessary click on the "Back" button at the top left hand corner of your screen or click on the "Home" link which appears as the first tab on the row of tabs towards the top of the screen.
Given that there is such content on this site, the website should not be accessed by anyone under the age of 18, and parents are advised not to allow their children to browse this site.
7. Bupa shall not be liable to any person for any loss or damage which may arise from the use of any of the information contained in any of the materials on this website. The information contained in any such materials is not intended nor implied to be a substitute for professional medical advice nor is it intended to be for medical diagnosis or treatment.
8. Under no circumstances shall Bupa be liable for any loss, cost or expense (whether direct, indirect, special or consequential) arising from your use or inability to use the website and any information or materials posted on the website.
9. Bupa does not exclude liability for damage arising from death or personal injury caused by the negligence of Bupa or any of its employees or agents.
10. You agree to indemnify and hold Bupa harmless from and against any and all claims, actions, demands, damages, liabilities, costs or expenses (whether in tort or contract, including without limitation negligence) arising out of or in connection with your use of the website.
Third Party Content and Links
11. Material appearing on this website will include advertising and other material submitted by parties other than Bupa and this website will provide links to other websites operated by advertisers and third parties. It is the responsibility of these third parties to ensure that such material and such websites comply with all relevant laws and regulations. To the full extent permissible by law, Bupa disclaims all responsibility for any error, omission or inaccuracy in such material or its failure to comply with the relevant laws or regulations.
Linking to the Bupa website
12. If you would like to link to the Bupa (Asia) Limited website, please email us at firstname.lastname@example.org .
Governing Law and Jurisdiction
15. If any part of this notice and disclaimer is deemed unlawful, void or for any reason unenforceable then that part will be deemed severable and will not affect the validity and enforceability of the remaining parts.
17. All rights not expressly granted herein are reserved by Bupa.
19. The health insurance schemes detailed on this website are insured by Bupa (Asia) Limited. Bupa (Asia) Limited is authorised and regulated by the Hong Kong Insurance Authority to carry out general insurance business in the HKSAR. The registered office of Bupa (Asia) Ltd. is 18/F Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong. Telephone number: 2517 5175.