Privacy Statement – Personal Information Collection Statement (PICS)
The purpose of the Privacy Statement is to explain how we collect, hold, process, use, protect, store, share and transfer (collectively referred to as “processing”) the data and/or information you provide to us when you use this platform, including but not limited to your personal data and information (“Data”).The Privacy Statement covers both “online” and “offline” (eg. collection of information by telephone or in person) activities that we hold, operate, provide and/or cause to exist. The Privacy Statement specifically discusses our obligations under relevant laws with respect to the privacy of personal data. Where practicable, we are committed to operating in accordance with the principles and procedures stated in relevant laws in our global business. If our business is governed by privacy legislation other than that of that jurisdiction, the Privacy Statement applies to the extent it is practicable and consistent with that legislation.
The provision of Data is voluntary. You may choose not to provide us with the requested Data, but failure to do so may inhibit our ability to provide information and services to you or to respond to your enquiries. GoGoX Insurance will not collect any information that identifies you personally through this website unless and until you use and browse the website, buy our products or services, register as a member, interact with us, sign-up to receive news about our products and services, or otherwise communicate with us (including where requesting technical support).
Please read the Privacy Statement carefully to understand our privacy policies and practices. The terms ‘we’, ‘our’, and ‘us’ used in this Privacy Statement refer to GoGoX Insurance.
GoGoX Insurance’s stance on data collection, processing, and protection
In all things related to data collection and protection, we strive to implement and follow modern best practices. Where possible we have adopted practices that ensure we are compliant across borders. The information contained within this Privacy Statement meet or exceed the following generally accepted data principles:
Personal data is processed fairly and legally – We do not collect or process any Data unless it is contractually required or it is necessary by our partners;
Personal data shall be obtained only for one or more specified and lawful purposes – As noted above and explained through the document, GoGoX Insurance only collects and processes Data when we need to;
Personal data shall be relevant – Data collected by GoGoX Insurance is only what is needed, and nothing more. Any requests made by clients or otherwise are followed through immediately, or within the next business day;
Personal data shall be accurate – All Data collected by GoGoX Insurance is deemed to be accurate and any changes are updated as soon as reasonably possible;
Personal data shall be kept only for as long as it serves a purpose – All Data stored by GoGoX Insurance is kept only as long as needed or legally required;
Personal data shall be processed only in accordance with local and international law – All Data collection, processing, and storage is done in a way that it is compliant with all relevant data protection laws and regulations, and ensure compliance by our staff with strict standards of security and confidentiality; and
Appropriate technical and security measures must be taken to secure personal data – GoGoX Insurance employs robust IT solutions and standard operating procedures that ensure all personal data is secure and only available to those who use it.
How do we collect data?
As an insurance broker, GoGoX Insurance is contractually obligated to collect and retain certain personal data of both potential and existing clients. The Data collected reflects what is required by insurers in order for the insurance broker to offer quotes, fulfill applications, and enable coverage.
We will usually identify any information which is mandatory (i.e. information required for creating an account, and enable you to access the features of the website and receive any services and information required for application forms from the insurer, or ones created by GoGoX Insurance on behalf of an insurer, and other written documents. Data that is not necessary will not be requested.) when we collect the information from you. At any time, you will maintain the right to request to view, change or delete the Data we have collected.You may also choose not to provide us with the requested Data, but failure to do so may inhibit our ability to do business with you or to respond to your enquiries. Data collected via telephone and emails may be recorded for training purposes, quality assurance and fraud prevention. By committing to these communication methods you consent to the recordings.
We will collect and store your Data either:
– Directly when you provide such information to us (for example, through your enquires and communications via telephone, email, text messaging or in person with us);
– Indirectly through your use of our websites, apps, or social media platforms; or Where you have provided it to us through any other means.
What data is being collected?
The personal data collected can include some or all of the following:
– Identity information – Name, address, personal contact details (including email address and telephone numbers, age, gender, nationality, job title and family structure of all persons to be covered by an insurance plan);
– Medical history – medical history of the primary policyholder and all persons to be covered by the plan;
– Insurance – insurance purchases, coverage and claims history of the primary policyholder;
– Lifestyle information – of all persons covered by the plan; and
– Method of payment – details related to method of payment (including credit card and bank account information) of the primary policyholder as well as any spouses.
Collection of Data from businesses
The above list also applies to businesses that GoGoX Insurance sells to. For businesses, additional Data may also be requested by the insurer. This could include:
– Employee data of all types listed above;
– Business registration, tax registration records, and ownership information;
– Employee salary record – for life/disability plans only;
– Collection of Data from children.
GoGoX Insurance sells insurance coverage to families. This means that a child’s data may need to be collected, as is contractually required by an insurer. With all Data collected for children under 18, GoGoX Insurance will contact the parents or guardian of the children to first gain consent and to explain what Data is being collected and why.
In situations where we are dealing with a minor (any person under the age of 18) as the primarypolicy holder (e.g., a student going overseas contacts us looking for insurance) we will contact the parent or guardian of the minor and ensure that consent for requested Data is provided. Parents or guardians will be involved in ALL communications and any decisions made.
Why we collect your Data and what do we use the Data for?
Data is collected for the following purposes:
– To verify your identity;
– To provide you with the services, access to the content on the website, apps or social media platforms;
– To provide you with promotional information related to insurance or wealth management products of GoGoX Insurance;
– To provide information as required by a particular insurance company’s application requirements;
– To administer and process of insurance policies, insurance claims and medical and security underwriting checks;
– To operate, protect, improve and optimize all the features of the services; to improve and customize the user experiences and usage trends of the platform, and to develop new services, features and functionalities;
– To notify you about changes to the platform or respond to any communication and/or request from you;
– To monitor the use of the platform and to investigate any reported incidents, complaints or potential breaches of the services; Where applicable and subject to compliance of the relevant laws, to match the Data with other Data collected for other purposes and from other sources including third parties in relation to the provision of services to you;
– To facilitate our processing of the Data for purposes relating to the provision of services offered by us such as marketing services, special events and/or promotions; and
– To disclose to and/or assist relevant authorities where we suspect you have committed an offense, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant public and law enforcement authorities and to comply with our obligations under the applicable laws and regulations from time to time.
Unless permitted by applicable laws and regulations, we will obtain consent from you if we wish to use your personal data for purposes other than those stated in this Privacy Statement.
We will seek your express consent to change how we process the Data if required by the relevant laws, but otherwise use of the services following such change constitutes your acceptance of the revised statement then in effect.
Who may be provided with your Data?
Personal data will be kept confidential but may, where permitted by law or where such disclosure is necessary to satisfy the purpose or a directly related purpose for which the personal data was collected, provide such Data to the following parties:
– Any person authorized to act as sales agent for GoGoX Insurance in relation to the distribution of products and services offered by GoGoX Insurance;
– Any other affiliates or personnel of GoGoX Insurance, on a need to basis, in relation to the handling of claims, renewals, accounting, marketing, administrative and client support duties;
– Any contractor or third-party service provider who provides administration, data processing, telecommunications, computer, payment, debt collection, technology outsourcing, legal advisors, call center services, mailing and printing services in connection with the operation of GoGoX Insurance’s business and GoGoX Insurance’s provision of services to you;
– Any government or regulatory bodies in any jurisdiction or any person to whom GoGoX Insurance must disclose Data.
We also reserve the right to disclose your information that we believe, in good faith, is appropriate and necessary to (i) take precautions against liability, (ii) protect ourselves from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect the security or integrity of of the service and any facilities or equipment used to make the service available, or (v) protect our property or other legal rights, or the rights, property or safety of others.
How long does GoGoX Insurance store data?
GoGoX Insurance stores data for as long as a user is a client or can reasonably be considered a potential customer without having notified us of their intention to opt out of any marketing communications. Beyond this, users that purchase products or services through GoGoX Insurance will have their Data stored for up to seven years following the end of their business with us, as such Data may be needed for reasons related to taxation, governmental, and financial compliance.
What control do I have over data and how do I change my consent?
Under applicable laws and regulations, you may have the right to:
– Verify whether GoGoX Insurance holds any personal data about you and to access any such Data;
– Require GoGoX Insurance to correct or delete any personal data relating to you which is inaccurate;
– Withdraw your consent or ‘opt out’ for use of personal data for direct marketing;
– Make a complaint about GoGoX Insurance’s data handling; and
– Enquire about GoGoX Insurance’s policies and practices in relation to personal data.
Requests for access, correction, complaints or other queries relating to your personal data should be addressed to:
GoGoX Insurance Data Protection Officer
10/F, Yau Lee Centre,Kwun Tong, Kowloon, Hong Kong
Under applicable laws and regulations, GoGoX Insurance has the right to charge costs which are directly related to and necessary for the processing of any personal data request..
Use of Data for direct marketing purposes
For the purposes of direct marketing, we may, where permitted by law, use your personal data information collected by us in marketing and promotion of other insurance services and products and must be within your consent. This Data includes your address, phone number, email and name, and may be transferred to companies affiliated to GoGoX Insurance. Please tick the box at the bottom of this PICS if you do not consent to receive such marketing communications.
Without an “opt-out” request from you, GoGoX Insurance may continue to use personal data for voluntary marketing purposes. If you wish to withdraw your consent or to stop receiving information or direct marketing please contact [email protected]
GoGoX Insurance has a strict policy against spamming and forbids the sending of mass emails or unsolicited emails of any kind. We only send emails to those who have requested to receive it to follow accepted permission-based email guidelines. If you suspect that GoGoX Insurance has been used by someone to send spam, report the activity to [email protected] and the issue will be investigated.
Is GoGoX Insurance’s data collection policy compliant?
All of GoGoX Insurance’s data collection, protection, and usage policies are fully in line with international regulations, including the European Union’s General Data Protection Regulation and Hong Kong’s Personal Data (Privacy) Ordinance. Furthermore, all users have the ability to view and alter any submitted user data. Thus, the GoGoX Insurance Privacy Statement is unlikely to cause objections or complaints.
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Amendments to this Privacy Statement
GoGoX Insurance 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. Where required by applicable law, we may also notify you in the event of material changes to this Privacy Statement and, where required, seek your consent to those changes.