Personal Data Protection Policy and Practices (“the Policy”)
FWD Life (Hong Kong) Limited or FWD Life Assurance Company (Hong Kong) Limited (“the Company”) is committed to implementation and compliance with the provisions of the Personal Data (Privacy) Ordinance (“the Ordinance”). In this context the Corporate Data Protection Officer is responsible for coordinating and overseeing compliance with the Ordinance and the upholding of the Data Protection Principles set out in the Ordinance.
This Policy applies to all products and services provided by the Company and sets out how the Company may collect, use and disclose your personal information.
Personal Information Collection Statement (“PICS”)
From time to time, it is necessary for you to supply FWD Life Assurance Company (Hong Kong) Limited / FWD Life (Hong Kong) Limited (“the Company”) or agents and representatives acting on its behalf with personal information and particulars in connection with our services and products. Failure to provide the necessary information and particulars may result in the Company being unable to provide or continue to provide these services and products to you.
The Company may also generate and compile additional personal data using the information and particulars provided by you. All personal data collected, generated and compiled by the Company about you from time to time is collectively referred to in this PICS as “Your Personal Data”.
“Your Personal Data” will also include personal data relating to your dependents, beneficiaries, authorised representatives and other individuals in relation to which you have provided information. If you provide personal data on behalf of any person you confirm that you are either their parent or guardian or you have obtained that person’s consent to provide that personal data for use by the Company for the purposes set out in this PICS.
As detailed in this PICS, Your Personal Data may also be processed by the Company’s subsidiaries, holding companies, associated or affiliated companies and companies controlled by or under common control with the Company (collectively, “the Group”).
The purposes for which Your Personal Data may be used are as follows:
providing our services and products to you, including administering, maintaining, managing and operating such services and products;
processing, assessing and determining any applications or requests made by you in connection with our services or products and maintaining your account with the Company;
developing insurance and other financial services and products;
developing and maintaining credit and risk related models;
processing payment instructions;
determining any indebtedness owing to or from you, and collecting and recovering any amount owing from you or any person who has provided any security or other undertakings for your liabilities;
exercising any rights that the Company may have in connection with our services and/or products;
carrying out and/or verifying any eligibility, credit, physical, medical, security, underwriting and/or identity checks in connection with our services and products;
any purposes in connection with any claims made by or against or otherwise involving you in respect of any of our services or products, including, making, defending, analysing, investigating, processing, assessing, determining, responding to, resolving or settling such claims, detecting and preventing fraud (whether or not relating to the policy issued in respect of this application);
performing policy reviews and needs analysis (whether or not on a regular basis);
meeting disclosure obligations and other requirements imposed by or for the purposes of any laws, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong) binding on the Company or any other member of the Group, including making disclosure to any legal, regulatory, governmental, tax, law enforcement or other authorities (including for compliance with sanctions laws, the prevention or detection of money laundering, terrorist financing or other unlawful activities) or to any self-regulatory or industry bodies such as federations or associations of insurers;
for marketing, customer services research, statistical or actuarial research undertaken by the Company or any member of the Group; and
fulfilling any other purposes directly related to (i) to (xii) above.
Your Personal Data will be kept confidential, but to facilitate the purposes set out in paragraph 5 above, the Company may transfer, disclose, grant access to or share Your Personal Data with the following:
other members of the Group;
any person or company carrying on insurance-related and/or reinsurance-related business which is engaged by the Company in connection with the Company’s business;
any physicians, hospitals, clinics, medical practitioners, laboratories, technicians, loss adjustors, risk intelligence providers, claims investigators, organizations that consolidate claims and underwriting information for the insurance industry, fraud prevention organizations, other insurance companies (whether directly or through fraud prevention organizations or other persons named in this paragraphs), the police and databases or registers (and their operators) used by the insurance industry to analyze and check information provided against existing information, legal advisors and/or other professional advisors engaged in connection with the Company’s business;
any agent, contractor or service provider providing administrative, distribution, credit reference, debt collection, telecommunications, computer, call centre, data processing, payment processing, printing, redemption or other services in connection with the Company’s business; and/or
any official, regulator, ministry, law enforcement agent or other person (whether within or outside Hong Kong) to whom the Company or another member of the Group is under an obligation or otherwise required or expected to make disclosures under the requirements of any law, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong).
Your Personal Data may be transferred or disclosed to any assignee, transferee, participant or sub-participant of all or any substantial part of the Company’s business.
The Company is only allowed to (i) use Your Personal Data in direct marketing; or (ii) provide Your Personal Data to another person or company for its use in direct marketing, if you provide your consent or do not object in writing.
In connection with direct marketing, the Company intends:
to use your name, contact details, services and products portfolio information, financial background and demographic data held by the Company from time to time in direct marketing to market the following classes of services and products offered by the Company, other members of the Group and/or Our Business Partners (being providers of the product and services described below) from time to time:
insurance services and products;
wealth management services and products;
pensions, investments, brokering, financial advisory, credit and other financial services and products;
health-check and wellness services and products;
media, entertainment and telecommunications services;
reward, loyalty or privileges programmes and related services and products; and
donations and contributions for charitable and/or non-profit making purposes; and
to provide your name and contact details to any members of the Group and/or Our Business Partners for their use in direct marketing the classes of services and products described in paragraph 9(i) above (including, in the case of Our Business Partners, for money or other commercial benefit).
You may write to the Company at the address below to opt out from direct marketing at any time.
To facilitate the purposes set out in paragraphs 5 and 9 above, as well as to ensure that Your Personal Data is stored safely, the Company may transfer, disclose, grant access to or share Your Personal Data with the parties set out in paragraphs 6 and 9(ii) and you acknowledge that those parties may be based outside Hong Kong and that Your Personal Data may be transferred to places where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Personal Data (Privacy) Ordinance.
Under the Personal Data (Privacy) Ordinance you have the right to request access to Your Personal Data held by the Company and request correction of any of Your Personal Data which is incorrect and the Company has the right to charge you a reasonable fee for processing and complying with your data access request.
Requests for access to or correction of Your Personal Data should be made in writing to:
Corporate Data Protection Officer
FWD Life Assurance Company (Hong Kong) Limited /
FWD Life (Hong Kong) Limited
11/F, FWD Tower, 979 King’s Road, Quarry Bay, Hong KongShould you have any queries, please do not hesitate to call our Customer Service Hotline on 3123 3123.
In case of discrepancies between the English and Chinese versions of this PICS, the English version shall apply and prevail.
A Privacy Addendum under the Personal Information Protection Law of the People’s Republic of China supplements this PICS and is available at https://www.fwdlife.hk/en/personal-data-protection-policy-and-practices/. The Privacy Addendum applies to you if you are within mainland China.
Addendum to Personal Information Collection Statement for Mainland China (the “Privacy Addendum”) (applicable to individuals in Mainland China)
Last updated date: January 2026
This Privacy Addendum forms part of our Personal Information Collection Statement (“PICS”) and only applies to individuals who are located in Mainland China and who receive the products and services provided by FWD Life Insurance Company (Bermuda) Limited / FWD Life Assurance Company (Hong Kong) Limited / FWD Life (Hong Kong) Limited (“the Company” or “We”) from Hong Kong. For the purposes of this Privacy Addendum:
“Mainland China” refers to the People’s Republic of China, excluding Hong Kong, Macau, and Taiwan.
“Hong Kong” refers to the Hong Kong Special Administrative Region of the People’s Republic of China.
The Company is committed to implementation and compliance with the relevant laws and regulations on the protection of personal data applicable in Mainland China.
This Privacy Addendum applies to all products and services provided by the Company and sets out how the Company may collect, use and disclose your personal information, as well as your rights.
The Company or agents and representatives acting on its behalf may collect from you some personal data relating to yourself, your dependents, beneficiaries, authorised representatives and other individuals during its daily business operation (including through offline, the Company’s website, App or other methods). If you refuse to provide the personal data or do not consent to our collection and use of the personal data, we may not be able to provide you with the relevant products and services.
In order to provide you with the Company’s relevant products and services, we will collect the following personal data:
Identity and Contact Information: such as full name, title, contact details (e.g., phone number, email address), and historical contact records;
Travel document information: such as information from passports or other travel-related documents;
Financial and payment information: such as credit card numbers, bank account details, and other payment-related information;
Demographic information: such as date of birth, age and gender;
Citizenship information: such as nationality, identity document copies and details, where relevant to the product or service;
Policy-related information: such as information about policy holders, joint policy holders, insureds, beneficiaries (including minor beneficiaries), assignees, trustees and claimants of the products or services;
Family information: such as information of family members (if relevant to the product or service);
Communication records: such as records of your interaction with us such as via the phone number of our customer service centre and, if you interact with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address;
Product and services usage: such as records of usage of our products and services, claims submission and claims results (and details related to this);
Health information: such as medical history and health-related records;
Tax information: such as tax residency and tax identification number;
Residency and Citizenship: such as residency and citizenship status; and
Family and social information: such as marital status, family, lifestyle or social circumstances (if relevant to the product or service). For example, the number of dependents or widowhood.
Certain personal data which we collect from you is defined as sensitive personal data according to the laws of Mainland China, including but not limited to biometric data, health data, financial account information, and information relating to minors. We collect such sensitive personal data for specific purposes such as assessing your insurance policy application, processing your insurance claims and managing your insurance account. We will take strict protection measures to protect such sensitive personal data.
The Company’s products, services and website are primarily intended for adults. Minors under the age of 14 (the “Minors”) should not create their own accounts on the Company’s website without the consent of their parents or guardians. If we need to collect and use the personal data of Minors, we will obtain the consent of the Minors’ parents or guardians when necessary to provide relevant products and/or services.
We will process Your Personal Data based on your consent. In case of any change to the purpose or method of processing Your Personal Data, or any change to the type of Your Personal Data to be processed, we will re-obtain your consent.
However, please be kindly aware that according to the relevant laws and regulations in Mainland China, we do not need to obtain your consent for collecting and processing Your Personal Data under the following circumstances:
- where it is necessary for the conclusion or performance of a contract to which you are a party;
- where it is necessary for the performance of our statutory duties or statutory obligations;
- where it is necessary for the response to a public health emergency or for the protection of life, health and property safety of a natural person in an emergency;
- where such acts as news reporting, media supervision, and other activities conducted in the public interest;
- where it is necessary to handle the personal data disclosed by the individual concerned or other personal data that has been legally disclosed within a reasonable scope in accordance with the laws.
The Company may transfer, disclose, grant access to or share Your Personal Data to third parties or affiliate companies for the purpose stated under the PICS and this Privacy Addendum. Your personal data will be collected, accessed, processed, used, stored, and/or transferred outside of, Mainland China.
If we intend to provide Your Personal Data to other parties other than the abovementioned parties, we will re-obtain your consent.
In order to centrally, properly and securely store your personal data, we may store or transfer your personal data to servers located in other regions or countries outside Hong Kong and the Mainland China.
We will only keep your personal data for the shortest period necessary to achieve the purposes outlined in our PICS and this Privacy Addendum, unless we are required to retain certain personal data in view of contractual, legal and regulatory obligations. Upon the expiry of the above retention period, we will delete or anonymize your personal data.
In accordance with the relevant laws and regulations in Mainland China, you may exercise the following rights:
- Access to your personal data;
- Correct and supplement your personal data. When you find that any personal data we are processing is inaccurate or incomplete, you may request us to correct or supplement it.
- Delete your personal data You may request us to delete your personal data in the following circumstances:
- the purposes for which we process your personal data have been achieved, cannot be achieved, or such personal data is no longer necessary for achieving the purposes for which they are processed;
- we cease to provide our products or services, or the retention period has expired;
- you have withdrew your consent to us;
- our processing of your personal data has violated the laws, regulations or our agreements.
- Change your consent to the Company You may change or withdraw your consent to the Company at any time. However, please be kindly aware that if you change or withdraw your consent, we may not be able to provide or continue providing certain products or services of the Company. After you have withdrew your consent, we will no longer process the corresponding personal data, but such withdrawal shall not affect the processing of your personal data which we have carried out based on your consent before you withdraw your consent.
- Obtain a copy of your personal data
You may exercise your above rights by writing to our Data Protection Officer at:
Corporate Data Protection Officer
FWD Life Insurance Company (Bermuda) Limited /
FWD Life Assurance Company (Hong Kong) Limited /
FWD Life (Hong Kong) Limited
11/F, FWD Tower, 979 King’s Road, Quarry Bay, Hong Kong
Regarding the personal data of your dependents, beneficiaries, authorised representatives and other persons , you may exercise the above rights on their behalf.
In case of discrepancies between the English and Chinese versions of the PICS and this Privacy Addendum, the English version shall apply and prevail.
The updated versions of the PICS and this Privacy Addendum will be published via our website.
Accuracy of Personal Information
The Company will ensure the accuracy of all personal data collected and processed by the Company. Appropriate procedures are implemented so that all personal data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. In so far as personal data held by the Company consists of statements of opinion, all reasonably practicable steps are taken to ensure that any facts cited in support of such statements of opinion are correct.
The Company will at all times endeavour to ensure the accuracy of personal data held by the Company, and if such personal data is transferred to third parties, it will notify that third party of any correction to be made.
Retention of Personal Information
No personal data is kept for longer than is necessary and that the Company will comply with all statutory and regulatory requirements in the Hong Kong Special Administrative Region concerning the retention of personally identifiable information.
Data Security
The Company will ensure an appropriate level of protection for personal data in order to prevent unauthorized access, processing or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by unauthorized access to that data. It is the practice of the Company to achieve appropriate levels of security by restricting physical access to data, providing secure storage facilities and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data and personal data is only transmitted by secure means.
Use of Cookies and Third Party Links
The Company’s website may include hyperlinks to third party websites. The Company has no control over the content, accuracy, opinion expressed, and other links provided at these third party websites or how these third party websites deal with your personal data. You should visit these third party websites for details of their privacy policies in relation to their handling of your personal data.
The Company may use “cookies” to improve our internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by the Company’s website. Cookies enable the Company’s website to remember you and your preferences when you visit the website and enable us to tailor the website to your needs. The information collected by cookies is anonymous visitor’s personalised settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser.
