Privacy

Personal Statement

Among the most important assets of the CONVOY Group of companies is the trust and confidence placed to properly handle information. Customers expect us to maintain their information accurately, protected against manipulation and errors, secure from theft and free from unwarranted disclosure.

This statement provides you with notice as to why your personal data is collected, how it is intended to be used, to whom your personal data may be provided to and how to access, review and amend your personal data.

The CONVOY Group of companies recognizes its responsibilities in relation to the collection, holding, processing or use of personal data. The provision of your personal data is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to do business with you.

 

DEFINITIONS

  1. “Data access request”, “data correction request”, “data subject”, “data user”, “direct marketing”, “matching procedures” and “personal data” used throughout this Notice shall have the meaning as defined in the Personal Data (Privacy) Ordinance.

For the purpose of this Statement:

“Customers” shall mean data subjects and the existing and prospective customers of CONVOY, including but not limited to:

  1. insurance policy owners, insured, beneficiaries and other persons designated or entitled to receive moneys and/or other benefits under an insurance policy; and
  2. members under an occupational retirement scheme; 
  3. scheme members under a mandatory provident fund scheme;  
  4. share/unit holders of investment funds; 
  5. borrowers and/or guarantors of money lending services; 
  6. members of remittance services; 
  7. members of property consulting services; and
  8. members of reward, loyalty or privilege programmes and related products and services.

“Hong Kong” shall mean the Hong Kong Special Administrative Region.

“CONVOY” shall mean Convoy Global Holdings Limited and/or its (wholly owned and/or partially owned) subsidiaries (as the case may be) in respect of its respective customers.

“CONVOY Fund (s)” shall mean any investment fund sponsored or managed from time to time by a member of the CONVOY Group and “CONVOY Fund(s)” shall mean all such investment funds.

“CONVOY Group” shall mean Convoy Global Holdings Limited and its (wholly owned and/or partially owned) subsidiaries and affiliates. The rights and obligations of each member of CONVOY Group under this Notice are several and not joint. No member of CONVOY Group shall be liable for an act or omission by another member of CONVOY Group.

“Ordinance” shall mean Personal Data (Privacy) Ordinance.

 

COLLECTION

  1. From time to time, it is necessary for customers to supply CONVOY with personal data in connection with the establishment or continuation of business relationship, or provision of products or services. Failure to supply such data may result in CONVOY being unable to establish or continue the business relationship, or provide products or services.

 

  1. It is also the case that personal data are collected or received by CONVOY from and/or in respect of customers in the ordinary course of the continuation of the business relationship, for example, when an application is made for a change of beneficiary/insured member under the insurance policy; or when notification is made by the employer of a change of employment/address of an employee member of an occupational retirement scheme/mandatory provident fund scheme; or when a joint share holder of an investment fund applies for investment fund switching.

 

PURPOSES

  1. The purposes for which personal data of a customer may be used will vary depending on the nature of the customer’s relationship with CONVOY. Such purposes may include the following:
  1. processing, assessing and determining applications or requests made by customers for products and/or services;
  2. administering, maintaining, managing and operating products and/or services provided to customers;
  3. confirming customer’s identity and uniquely identifying customer;
  4. confirming the accuracy of the information collected;
  5. understanding customer’s financial situation better, evaluating customer application, assessing the risks CONVOY is assuming and reviewing claims submitted to CONVOY;
  6. any purposes in connection with any claims made by or against or otherwise involving customers in respect of any products and/or services including but not limited to making, defending, analysing, investigating, processing, assessing, determining or responding to such claims;
  7. providing investment management services, dealing and advisory services, custody services and other services under the terms and conditions of the accounts a customer holds with CONVOY;
  8. performing any functions and activities related to products and/or services including but not limited to marketing, audit, reporting, research, analysis, reinsurance, and general servicing and maintenance of online and other services;
  9. researching and/or designing products and/or services for customers, and promoting, improving and furthering the provision of products and/or services;
  10. conducting matching procedures (as defined in the Ordinance, but broadly includes comparison of two or more sets of the data subject’s data, for purposes of taking actions adverse to the interests of the data subject, such as declining an application);
  11. making disclosure under and/or complying with the requirements of any law, rules, regulations, codes of practice, guidelines or guidances binding on or applicable to CONVOY or any member of CONVOY Group (whether within or outside Hong Kong) including but not limited to making disclosure to local or foreign regulators, governmental bodies, industry recognised bodies (whether within or outside Hong Kong) such as federations or associations of insurers, credit reference agencies or auditors;
  12. complying with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognised bodies (whether within or outside Hong Kong) that is assumed by or imposed on CONVOY or any member of CONVOY Group by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognised bodies;
  13. for operational purposes, credit assessment, credit scoring models or statistical analysis (including in each case, behaviour analysis and evaluation on the overall relationship with CONVOY Group which includes using such data to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within CONVOY Group and/or other use of data and information in accordance with any CONVOY Group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities), whether on the data subjects or otherwise;
  14. exercising any rights CONVOY may have in connection with the provision to customers of products and/or services;
  15. conducting identity and/or credit checks;
  16. determining any amount of indebtedness owing to or from customers, and collecting and recovering any amount owing from customers or any person who has provided any security or undertaking for customers’ liabilities;
  17. enabling an actual or proposed assignee, transferee, participant or sub-participant of the rights or business of CONVOY or any member of CONVOY Group to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;
  18. purposes specifically provided for in any particular service or product offered by CONVOY;
  19. any purposes relating to the above (including seeking professional advices) or any other purposes in accordance with the general policies of CONVOY or any member of CONVOY Group in relation to insurance, occupational retirement schemes, mandatory provident fund schemes, investment funds, wealth management services and other financial products and services as set out in notices, circulars, or other terms and conditions made available by CONVOY or any member of CONVOY Group to customers from time to time.

 

TRANSFEREES

  1. Personal data of a customer held by CONVOY will be kept confidential but CONVOY may transfer such data to the following persons and/or entities (whether within or outside Hong Kong) for any of the purposes set out in paragraph 4 above:
  1. any person in connection with any claims made by or against or otherwise involving customers in respect of any products and/or services;
  2. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, information technology, payment, data processing or storage, marketing, mailing, printing, telemarketing, customer satisfaction analysis, or other services to CONVOY or any member of CONVOY Group in connection with the operation of business, including any custodian, administrator, investment manager, investment advisor or distributor;
  3. any credit reference agencies or, in the event of default, any debt collection agencies;
  4. any advisor (including his or her employees) or other intermediary (including their employees);
  5. reinsurers and medical service providers;
  6. employers of the customers;
  7. any person which has undertaken to CONVOY or any member of CONVOY Group to keep such data confidential;
  8. any actual or proposed assignee, transferee, participant or sub-participant of the rights or business of CONVOY or CONVOY Group;
  9. any member of CONVOY Group;
  10. any person to whom CONVOY or any member of CONVOY Group is under an obligation or otherwise required to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to CONVOY or any member of CONVOY Group including but not limited to any local or foreign regulators, governmental bodies, or industry recognised bodies;
  11. any person to whom CONVOY or any member of CONVOY Group is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognised bodies (whether within or outside Hong Kong) that is assumed by or imposed on CONVOY or any member of CONVOY Group by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, industry recognised bodies.

 

USE OF PERSONAL DATA IN DIRECT MARKETING

  1. CONVOY intends to use, from time to time, customer’s personal data in direct marketing of the following products and services:
  1. insurance, provident funds and/or schemes, investment funds, wealth management services, or other financial products and services;
  2. reward, loyalty or privilege programmes and related products and services;
  3. products and services of co-branding partners of any member of CONVOY Group (the names of such co-branding partners can be found in the application form(s) for the relevant products and services as the case may be).
  4. Only the following kinds of personal data of the customer may be used in such direct marketing:
  1. name;
  2. gender;
  3. date of birth;
  4. part of identity card or passport number;
  5. contact information (including but not limited to phone number, fax number, email address, correspondence address and residential address);
  6. information about the products and/or services the customer has purchased or applied, including the distribution channels (including their individual advisors or intermediaries) through which the products and/or services were purchased or applied for;
  1. CONVOY may not so use the data unless it has received the customer’s consent to the intended use.

 

PROVISION OF PERSONAL DATA FOR USE IN DIRECT MARKETING

  1. CONVOY intends to provide, from time to time and for money and other property, customer’s personal data to CONVOY Group (other than CONVOY itself) for use by CONVOY Group in direct marketing of the following products and services:
  1. insurance, provident funds and/or schemes, investment funds, wealth management services, or other financial products and services;
  2. reward, loyalty or privilege programmes and related products and services;
  3. products and services of co-branding partners of any member of CONVOY Group (the names of such co-branding partners can be found in the application form(s) for the relevant products and services as the case may be).
  4. Only the following kinds of personal data of the customer may be provided to CONVOY Group (other than CONVOY itself) for use by CONVOY Group in such direct marketing:
  1. name;
  2. gender;
  3. date of birth;
  4. part of identity card or passport number;
  5. contact information (including but not limited to phone number, fax number, email address, correspondence address and residential address);
  6. information about the products and/or services the customer has purchased or applied, including the distribution channels (including their individual advisors or intermediaries) through which the products and/or services were purchased or applied for.
  1. CONVOY may not so provide the data unless it has received the customer’s written consent to the intended provision.

 

  1. Under the Ordinance, a data subject has the right to:
  1. request access to his or her personal data;
  2. request correction of any of his or her personal data which is inaccurate;
  3. ascertain a data user’s policies and practices in relation to personal data;
  4. be informed of the kind of personal data held by the data user;
  5. be informed of the main purposes for which personal data held by the data user are or are to be used;
  6. make data access request and data correction request through the channel set out in paragraph 9 below.

 

ACCESS RIGHTS TO PERSONAL DATA

  1. In accordance with the provisions of the Ordinance, CONVOY has the right to charge a reasonable fee for processing any data access request. Requests may be made in writing to the Data Protection Officer at:

39/F, @CONVOY, 169 Electric Road, North Point, Hong Kong

Attention: Customer Marketing Department

 

AMENDMENTS TO THIS PRIVACY STATEMENT

  1. CONVOY reserves the right, at any time and without notice, to add to, change, update or modify this privacy statement, simply by notifying you of such change, update or modification. If we decide to change our personal data policy, those changes will be notified on our website so that you are always aware of what information we collect, how we use the information and under what circumstances the information is disclosed. Any such change, update or modification will be effective immediately upon posting.

 

In the event of any discrepancy between the English and Chinese versions, the English version shall apply and prevail.