Prior Insurance Consultants Limited
(“Company”) pledges to meet fully with the requirements of the Personal Data
(Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the
Company will ensure compliance by its staff to the strictest standards of
security and confidentiality in respect of all personal information and data
submitted by its customer(s) and prospect(s) (collectively “Customer(s)”) to
the Company and the Company will not release such information to anyone without
the prior consent of the relevant Customer(s) of the Company except to the
authorized persons listed under the section entitled “Disclosure or Transfer of
Data”.
Customers are strongly recommended to read
this privacy statement (“Privacy Statement”) carefully to have an understanding
of the Company’s policy and practices with regard to the treatment of personal
information and data provided by the Customers.
If Customers have questions or concerns
regarding this Privacy Statement, they should first contact the customer
service representative of the Company at (852) 25411599 or email to info@priorinsurance.com.hk
I. Collection of Personal Data
1. Means of Collection of Personal Data
The Company collects the personal
information and/or data of Customers by various means including but not limited
to the following:
(a) via the Websites;
(b) member registration forms (whether
completed via the Websites or otherwise);
(c) activities enrolment forms (whether
completed via the Websites or otherwise);
(d) order forms, warranty activation forms,
warranty registration and activation sheets (whether completed via the Websites
or otherwise);
(e) enquiry forms (whether completed via
the Websites or otherwise);
(f) forms for contests, surveys, or special
offers (whether completed via the Websites or otherwise);
(g) collection and/or exchange of name
cards and other personal information, either verbal or written, for and during
activities and events either organised by or involving the Company;
(h) via online social networking service
platforms (such as Facebook, Twitter, Weibo, WeChat);
(i) written communications between
Customers and the staff and personnel;
(j) verbal communications between Customers
and the staff and personnel with the Customers being aware of such collection;
and
(k) through the above means by the
Company’s affiliates, third party service providers and corporate clients of
the Company for the Company with the Company’s authorization.
The Company may collect personal
information and/or data of a Customer such as his/her name, address, email
address, phone number, age, sex, date of birth, country of residence,
nationality, education level, work experience, boat model, boat license number
and other related information, and log-in ID and password for getting access to
the Websites (if applicable) that is/are not otherwise publicly available.
Only duly authorized staff of the Company
will be permitted to access the Customers’ personal information and data, and
the Company shall not release such personal information and data to any third
parties save and except for the circumstances listed out under the section
entitled “Disclosure or Transfer of Data”.
2. Purpose of Collection of Personal Data
In the course of using the Services,
Customers may disclose or be asked to provide personal information and/or data.
In order to have the benefit of and enjoy various Services offered by the
Company and/or its affiliates, it may be necessary for Customers to provide the
Company with their personal information and/or data. Although Customers are not
obliged to provide the information and/or data as requested, the Company may
not be able to render certain Services to such Customers in the event that they
fail to do so.
The Company’s purposes for collection of
information and data include but not limited to the following:
(a) for the daily operation of the Services
provided to Customers;
(b) to identify Customers who have enjoyed
and used the Services provided;
(c) to provide Customers with marketing and
promotional materials for their enjoyment of benefits provided by the Company
to its Customers (for further details, please refer to section headed
“Subscription of Newsletter/Promotional Materials/Marketing Materials” below);
(d) to identify Customers who have enjoyed
their benefits as Customers by receiving and using marketing and promotional
materials;
(e) to allow Customers to enjoy their
benefits by enrolling for special events hosted by the Company and/or its
affiliates;
(f) to design and provide products and
services to Customers in relation to the above purposes; and
(g) to facilitate the Company and/or its
affiliates to use the Customers’ personal data for purposes relating to the
provision of services offered by the Company and marketing services, special
events and/or promotions of the Company, its affiliates and/or their respective
clients.
If the Customer is under the age of 13, the
Company would strongly recommend him/her to seek prior consent from a person
with parental responsibility for him/her, e.g. parent or guardian, who may
contact the responsible personnel of the Company at info@priorinsurance.com.hk for
providing relevant and appropriate personal information and/or data to the
Company.
II. Disclosure or Transfer of Data
The Company agrees to take all practicable
steps to keep all personal information and data of Customers confidential
and/or undisclosed, subject to the following.
Generally speaking, the Company will only
disclose and/or transfer Customers’ personal information and/or data to the
Company’s personnel and staff for the purpose of providing the Services to
Customers. However, the Company may disclose and/or transfer such information
and/or data to third parties under the following circumstances:
(a) where the information and/or data
is disclosed and/or transferred to any third party suppliers or external
service providers who have been duly authorized by the Company to use such
information and/or data and who will facilitate the Services provided by the
Company and/or its affiliates, under a duty of confidentiality;
(b) where the information and/or data
is disclosed and/or transferred to any agents, affiliates or associates of the
Company who have been duly authorized by the Company to use such information
and/or data;
(c) where the Company needs to
protect and defend its rights and property;
(d) where the Company considers
necessary to do so in order to comply with the applicable laws and regulations,
including without limitation compliance with a judicial proceeding, court
order, or legal process served on the Company and/or its affiliates; and
(e) where the Company deems necessary
in order to maintain and improve the Services.
Personal data collected by the Company may
be transferred, stored and processed in any country in which the Company or its
affiliates operate. By using the Services, Customers are deemed to have agreed
to, consented to and authorized the Company to disclose and/or transfer their
personal information and data under the circumstances stated above, as well as
to any transfer, disclosure and use of information and data outside of the
Customers’ country.
III. Subscription of Newsletter/Promotional
Materials/Marketing Materials
The Company and its affiliates may from
time to time communicate to Customers newsletters, promotional and marketing
materials and information, either verbally or in writing, based on the personal
information and data that they have provided to the Company. In this
connection, please note that:
(a) the name, contact details, age, sex,
date of birth, country of residence, nationality, education level, work
experience, and other related information, and log-in ID and password for
getting access to the Websites (if applicable) of Customers held by the Company
from time to time may be used by the Company and/or its authorised personnel or
staff in direct marketing;
(b) the products, services and subjects may
be provided or (in the case of donations and contributions) solicited by the
Company and/or:
i. the Company’s affiliates;
ii. third party service providers providing
the products, services and subjects listed in paragraph (b) above; and
iii. charitable or non-profit marking
organizations;
(c) in addition to marketing the above
services, products and subject itself, the Company also intends to provide the
data described in paragraph (a) above to all or any of the persons described in
paragraph (c) above for use by them in marketing those services, products and
subjects, and the Company requires the Customers’ written consent (which
includes an indication of no objection) for that purpose;
(d) the Company may receive money or other
property in return for providing the data to the other persons in paragraph (b)
above and, when requesting the Customers’ written consent as described in
paragraph (d) above, the Company will inform the Customers if the Company
receives any money or other property in return for providing the data to the
other persons.
Suitable measures are implemented to make
available to such Customers the options to “opt out” of receiving such
materials. In this regard, Customers may choose to unsubscribe for such
materials by, as the case may be, clicking on the automatic link appearing in
each e-newsletter/message and follow the instructions and procedures contained
thereunder, filling out and returning the hard copy of the instruction for
“opt-out” or contact the customer service representative of the Company at +852
25413456 or email info@priorinsurance.com.hk
IV. Access
Any Customer is entitled to request access
to or make amendments to his/her own personal information and data kept with
the Company by contacting the customer service representative of the Company at
+852 25411599 or email to info@priorinsurance.com.hk.
In the event that a Customer wishes to
access or amend his/her personal information and data, the Company may request
him/her to provide personal details in order to verify and confirm his/her
identity. HKID card number or passport number or business registration
certificate number cannot be amended unless such data is proved to be
inaccurate. The Company is required to respond to a Customer’s requests within
40 days of his/her request and will endeavor to do so wherever possible.
V. Use of Websites of the Company
1. Cookies and Log Files
The Company does not collect any personally
identifiable information from any Customers whilst they visit and browse the
Websites, save and except where such information of the Customers is expressly
requested. When Customers access the Websites, the Company records their visits
only and do not collect their personal information or data. The Websites’
server software will also record the domain name server address and track the
pages the Customers visit and store such information in “cookies”, and gather
and store information like internet protocol (IP) addresses, browser type,
referring/exit pages, operating system, date/time stamp, and clickstream data
in log files. All these are done without the Customers being aware that they
are occurring. The Company does not link the information and data
automatically collected in the above manner to any personally identifiable
information. The Company generally uses such automatically collected
information and data to estimate the audience size of the Websites, gauge the popularity
of various parts of the Websites, track movements of Customers on the Websites
and number of entries in the Company’s promotional activities and special
events, measure traffic patterns of the Customers using the Websites and
administer the Websites. Such automatically collected information and data will
not be disclosed save and except in accordance with the section entitled
“Disclosure or Transfer of Data”.
2. Links to Other Sites
The Websites may provide links to other
websites which are not owned or controlled by the Company. Personal information
and data from Customers using the Websites may be collected on these other
websites when Customers visit such websites and make use of the services
provided therein. Where and when Customers decide to click on any advertisement
or hyperlink on the Websites which grants Customers access to another website,
the protection of Customers’ personal information and data which are deemed to
be private and confidential may be exposed in these other websites.
All Customers using the Websites are deemed
to have consented to the terms of this Privacy Statement. Customers not
registered to the Websites who gain access to the Websites, including those
Customers who gain access to those Websites via their accounts in online social
networking tools (including but not limited to Facebook), are deemed to have
consented to the terms of this Privacy Statement, and such Customers’ personal
data which they have provided to those networking tools may be obtained by the
Company and be used by the Company and its authorized persons in and outside of
the Customers’ country for the purpose of providing services and marketing
materials to the Customers. The Company and its authorized personnel may gain
access to and use the personal data of such Customers so obtained, subject to
the other provisions of this Privacy Statement.
This Privacy Statement is only applicable
to the Customers utilising the Services provided by the Company and/or its
affiliates. Customers are reminded that this Privacy Statement grants no
protection to Customers’ personal information and data that may be exposed on
websites other than the Websites, and the Company is not responsible for the
privacy practices of such other websites. Customers are strongly recommended to
refer to the privacy policy of such other websites.
VI. Security
The security of Customers’ personal
information and data is important to the Company. The Company will always
strive to ensure that Customers’ personal information and data will be
protected against unauthorized access. The Company has implemented appropriate
electronic and managerial measures in order to safeguard, protect and secure
Customers’ personal information and data.
All personal information and data provided
by Customers are only accessible by the authorized personnel of the Company or
its authorized third parties, and such personnel shall be instructed to observe
the terms of this Privacy Statement when accessing such personal information
and data. Customers may rest assured that their personal information and data
will only be kept for as long as is necessary to fulfill the purpose for which
it is collected. Customers registered to the Websites should safeguard
his/her unique Username and Password by keeping it secret and confidential and
never share these details with anyone (where applicable).
The Company follows generally accepted
industry standards to protect the personal information and data submitted by
Customers, both during transmission and once the Company receives it. However,
no method of transmission or storage of data, including without limitation
transmission over the Internet and storage by electronic means, is 100% secure.
Therefore, while the Company strives to protect Customers’ personal information
and data against unauthorized access, the Company cannot guarantee its absolute
security.
Retention of Personal Data
Once the Company has obtained a Customer’s
personal information and/or data, it will be maintained securely in designated
premises and computer systems of the Company and/or its engaged service
provider(s). Subject to legal requirements, the personal information and/or
data of Customers will be retained by the Company after deactivation of the
relevant service until the Customer requests the Company in writing to erase
his/her own personal information and/or data from the Company’s database or to
terminate his/her membership of the Websites (if applicable).
Changes in this Privacy Statement
The Company reserves the right to update,
revise, modify or amend this Privacy Statement in the following manner at any
time as the Company deems necessary and Customers are strongly recommended to
review this Privacy Statement frequently. If the Company decides to update,
revise, modify or amend this Privacy Statement, the Company will post those
changes to this webpage and/or other places the Company deems appropriate so
that Customers would be aware of what information the Company collects, how the
Company uses it, and under what circumstances, if any, the Company discloses
it.
If the Company makes material changes to
this Privacy Statement, the Company will notify Customers by email or by means
of a notice on the home page of the Company.
For any query, please contact the Company’s
customer service representative at (852) 25411599 or email to info@priorinsurance.com.hk.
