This Privacy Notice sets out the terms upon which Lombard International Brokers Limited (“we” or “us”) will collect, use, store, maintain, transfer and disclose your personal data. This Privacy Notice will apply to you if you engage us in connection with services provided to you. This Privacy Notice will supplement any notices which we may have previously provided you with and any other consent (to the extent required under the law) which you may have previously provided to us and is in addition to any rights which we may have under applicable law to handle your personal data.
To the extent necessary to provide you with our services, we will collect personal data which includes the following information:
- Your name, national identification number and/or passport number
- Contact information such as telephone number and mailing address
- Bio-data (e.g. height and weight) and health information
- Employment information
- Financial information
- Investment portfolios
- Personal data of any other individuals (e.g. family members or beneficiaries where you have the consent of the owner of the personal data to provide such information)
- Any information you have provided in any forms you may have submitted to us
- Any information about you provided by third party sources
We will collect such personal data directly from you and also from third party sources including:
- your insurers
- your medical practitioners
- your financial institution or financial adviser where you have been referred to us by an introducer
- your professional advisers where you have authorized us to contact your banker and your professional advisers to discuss and/or release information regarding the assets held in your account by the bank/financial Institution
We will inform you of whether it is mandatory or voluntary for you to provide certain types of personal data. If you do not provide complete and accurate personal data to us as and when it is required which are mandatory, we may not be able to provide you with the requested services.
HOW WE HANDLE YOUR PERSONAL DATA
We will handle your personal data for purposes reasonably related to the services required of an insurance broker including:
- identifying you
- communicating with you (including but not limited to sending you information about insurers’ policies and services)
- communicating with the insurers about your insurance applications and policy services
- conducting a review of your insurance
- providing you with ongoing services and respond to your inquiries or instructions
- complying with legal and regulatory requirements, including reporting to regulatory and industry entities
- resolving complaints and handling disputes
- any merger, purchase, sale, amalgamation or any other acquisition, disposal or financing of Lombard International Brokers Limited, or affiliates or subsidiaries or any part of thereof
- other purpose reasonably related to any of the above
We will only collect and use personal data that is necessary for the purposes identified by us above. We will treat your personal data as private and confidential at all times. We will NOT disclose your personal data to others except:
- at your request or with your consent;
- to regulators, law enforcement and government agencies in any applicable jurisdiction where we are required to disclose by court order, law or regulations;
- any actual or potential purchaser of Lombard International Brokers Limited, or affiliates or subsidiaries or any part of thereof; or
- where we engage third parties to facilitate the purposes identified by us above and your personal data is reasonably required for and limited to information necessary for these third parties to do the work, including the following third parties:
- service providers to provide us with services such as translation of documents, IT support, mail distribution, data storage, disaster recovery or emergency assistance services, operational services including processing product applications for carriers and handling all underwriting and administrative services required to have policies issued and paid by such carriers
- medical professionals and institutions
- financial institutions and premium finance providers
- introducers who have referred you to us
- your professional advisers
- dispute resolution parties
We may transfer personal data to service providers outside of Hong Kong for processing, storage, analysis, disaster recovery or emergency assistance services and this data may be required to be disclosed to those authorized under the applicable laws of that foreign country. These service providers with whom we have contractual relationships are required to provide a standard of protection to the transferred personal data that is comparable to the protection under the Hong Kong Personal Data (Privacy) Ordinance and consistent with our personal data protection policies and practices. However, please note that we may need to transfer personal data overseas in the course of providing services to a destination where the law governing the protection of personal data may not be comparable to the protection under the Hong Kong Personal Data (Privacy) Ordinance.
WITHDRAWAL OF CONSENT
- Where you have given us your consent to collect, use, disclose or process your personal data, you may at any time withdraw that consent
- You must give us reasonable notice for withdrawal of such consent by writing to your insurance broker representative serving you
- On receipt of notice, we will inform you of consequences of withdrawal
- While you may withdraw your consent for the collection, use or disclosure of personal data, any withdrawal of consent by you for any purpose(s) that is reasonably required to provide the service you have engaged may result in the termination of your contract with us
- After you withdraw consent, we will cease to collect, use or disclose your personal data, as the case may be. However, please note that we are not required to delete your personal data upon receipt of your withdrawal of consent and we may still retain your personal data as long as necessary for legal or business purposes
ACCESS AND CORRECTION OF PERSONAL DATA
You are entitled to access your personal data and to make changes. If you wish to do so, please contact your insurance broker representative serving you or our Compliance Officer (see “How Can You Contact Us” below).
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as necessary for the purposes for which we collect and use your personal data or directly related purposes, or for such longer period as is permitted or required by applicable law. However, we will cease to retain personal data as soon as it is reasonable to assume that the purpose for which the personal data had been collected is no longer served by retaining the personal data; and such retention is no longer necessary for the aforesaid purposes.
We will automatically collect information about your use of our site through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we may combine this information with other information we collect about you, The types of data we collect include:
- your browser type and operating system;
- web pages you view on the site;
- links you click on the site;
- your device’s IP address;
- the length of time you visit our site; and
- the referring URL, or the webpage that led you to our site.
For more information on how we deploy cookies, web beacons and similar technologies, please refer to our Cookies Policy, available here: https://asia.lombardinternational.com/en-ASIA/Disclaimers/Cookies-policy.
DATA SECURITY POLICY
We will adopt reasonable technical, organizational and administrative measures to protect your personal data from accidental or unauthorized access, use, disclosure, erasure, transfer and processing. While we will take all reasonable steps to protect your Personal Data, we cannot guarantee that transmissions over the Internet will be secure all the time.
HOW CAN YOU CONTACT US
You can contact the Compliance Officer for any question, concern or complaint you may have at AsiaDPO@LombardInternational.com or by post at Two International Finance Centre, 10th Floor, No. 8 Finance Street, Hong Kong.
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice was last modified on 30 Sep 2020.
We may modify this Privacy Notice from time to time. We recommend that you check our Privacy Notice regularly. Where required by applicable law, we will seek your consent to changes to this Privacy Notice.