PRIVACY POLICY

(Effective from January 1, 2015) Personal Information Collection Statement relating to the Personal Data (Privacy) Ordinance (the “Ordinance”)

Your privacy and maintaining the confidentiality of your personal information is important to Bupa (Asia) Limited ("Bupa", "we", "our", "us"). This privacy policy ("Policy") applies to all health insurance and related products and services provided by us and sets out how we may collect, use, disclose and protect your personal information. This Policy is governed by and observes the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance").

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, nationality, 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
    • information about your computer and devices used by you to access our services
    • details of queries you have made
    • information from customer surveys, competitions and marketing activities
    • quotes you have requested
    • policy applications made by you
    • policy applications where you are included as a dependant
    • your Bupa policies; and
    • Bupa policies where you are included as a dependant, including corporate policies

We may add your information to a database in order that we can identify you as an individual, to manage our relationship with you as a Bupa customer or prospective customer.  If you have had a Bupa policy (or been included as a dependant on a policy) or have made or been included in an application for a Bupa policy, our customer database may also record information relating to:

  • credit and anti-fraud checks

  • payment details

  • your medical history and medical reports

  • your claims history

  • complaints

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 request a quote and/or complete an application form or another type of form in relation to our products and services, online, by telephone or using an intermediary
  • 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 access our web apps/mobile applications/health tools (please see our cookie policy for more details)
  • when you opt for new services in relation to your policy; and
  • you submit any query to us, for example, by email, telephone, blog replies, or social media

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

  • when processing an application or claim, we may do credit or fraud checks, obtain medical reports or obtain information from other Bupa group insurers you have previously had insurance with

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

  • 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

  • to enable you to utilise our health forums, online health assessment programs and mobile applications
  • to make suggestions about clinically appropriate treatment
  • for research and analytics
  • to detect and prevent fraud or improper claims

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).

Subject to our obligations of confidentiality and data protection, we may share your personal data with:

  • other Bupa group companies for the purposes set out above, and access is restricted to those individuals who have a need to access the information for those purposes
  • other Bupa group insurers or our insurance partners If you transfer to another Bupa plan or a plan offered by one of our partners, we will share your medical and claims history with the new insurer
  • our service providers

Often we will need to share your personal data with professional advisors such as claim investigators, emergency assistance providers, medical professionals, lawyers and other experts.

We also engage third party service providers to provide our IT systems; printing and marketing services; research and analytics and similar outsourced services. In each case, we require these third parties only use the personal data as is necessary to carry out their services.

Sometimes these third parties are located outside your jurisdiction, in countries which do not provide the same protection as your own. We ensure they are subject to contractual restrictions with regard to confidentiality and security obligations.

We may also share your data:

  • 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
  • with your intermediary, with your authority
  • with Bupa group companies and administrators, to assist us in providing our services to you, including sales agents to follow up with prospective customers queries in relation to our products
  • with Bupa group companies or one of our insurance partners, where you would like to move to one of their insurance products
  • with credit reference agencies for the purpose of assessing your credit score
  • with other insurers and third parties for the purpose of fraud detection
  • where you have given your express consent

Direct marketing

Bupa will not sell your personal information to anyone. From time to time, Bupa may use your name, address, email address, telephone number and fax number to contact you about 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. When we contact you it may be via mail, phone, email, SMS or fax.

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 customercare@bupa.com.hk.

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 and www.bupaglobal.com ("our website"). Please see our cookie policy on the respective website for more details.

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.

PRIVACY POLICY

(Effective from January 1, 2015) Personal Information Collection Statement relating to the Personal Data (Privacy) Ordinance (the “Ordinance”)

Your privacy and maintaining the confidentiality of your personal information is important to Bupa (Asia) Limited ("Bupa", "we", "our", "us"). This privacy policy ("Policy") applies to all health insurance and related products and services provided by us and sets out how we may collect, use, disclose and protect your personal information. This Policy is governed by and observes the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance").

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, nationality, 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
    • information about your computer and devices used by you to access our services
    • details of queries you have made
    • information from customer surveys, competitions and marketing activities
    • quotes you have requested
    • policy applications made by you
    • policy applications where you are included as a dependant
    • your Bupa policies; and
    • Bupa policies where you are included as a dependant, including corporate policies

We may add your information to a database in order that we can identify you as an individual, to manage our relationship with you as a Bupa customer or prospective customer.  If you have had a Bupa policy (or been included as a dependant on a policy) or have made or been included in an application for a Bupa policy, our customer database may also record information relating to:

  • credit and anti-fraud checks

  • payment details

  • your medical history and medical reports

  • your claims history

  • complaints

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 request a quote and/or complete an application form or another type of form in relation to our products and services, online, by telephone or using an intermediary
  • 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 access our web apps/mobile applications/health tools (please see our cookie policy for more details)
  • when you opt for new services in relation to your policy; and
  • you submit any query to us, for example, by email, telephone, blog replies, or social media

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

  • when processing an application or claim, we may do credit or fraud checks, obtain medical reports or obtain information from other Bupa group insurers you have previously had insurance with

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

  • 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

  • to enable you to utilise our health forums, online health assessment programs and mobile applications
  • to make suggestions about clinically appropriate treatment
  • for research and analytics
  • to detect and prevent fraud or improper claims

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).

Subject to our obligations of confidentiality and data protection, we may share your personal data with:

  • other Bupa group companies for the purposes set out above, and access is restricted to those individuals who have a need to access the information for those purposes
  • other Bupa group insurers or our insurance partners If you transfer to another Bupa plan or a plan offered by one of our partners, we will share your medical and claims history with the new insurer
  • our service providers

Often we will need to share your personal data with professional advisors such as claim investigators, emergency assistance providers, medical professionals, lawyers and other experts.

We also engage third party service providers to provide our IT systems; printing and marketing services; research and analytics and similar outsourced services. In each case, we require these third parties only use the personal data as is necessary to carry out their services.

Sometimes these third parties are located outside your jurisdiction, in countries which do not provide the same protection as your own. We ensure they are subject to contractual restrictions with regard to confidentiality and security obligations.

We may also share your data:

  • 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
  • with your intermediary, with your authority
  • with Bupa group companies and administrators, to assist us in providing our services to you, including sales agents to follow up with prospective customers queries in relation to our products
  • with Bupa group companies or one of our insurance partners, where you would like to move to one of their insurance products
  • with credit reference agencies for the purpose of assessing your credit score
  • with other insurers and third parties for the purpose of fraud detection
  • where you have given your express consent

Direct marketing

Bupa will not sell your personal information to anyone. From time to time, Bupa may use your name, address, email address, telephone number and fax number to contact you about 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. When we contact you it may be via mail, phone, email, SMS or fax.

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 customercare@bupa.com.hk.

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 and www.bupaglobal.com ("our website"). Please see our cookie policy on the respective website for more details.

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.