1. Policy background
Liberty Specialty Markets provides a wide range of commercial and specialist general insurance services in Hong Kong. We are committed to protecting the privacy of your personal data.
Liberty Specialty Markets Hong Kong Limited (UBI 66395065) (Liberty) is a company incorporated in Hong Kong. Liberty is authorised by the Office of the Commissioner of Insurance (HK) to conduct general insurance business in Hong Kong. Liberty is a member of the US-based Liberty Mutual Group.
This Privacy Policy explains the main ways Liberty protects your privacy and how Liberty complies with the Data Protection Principles, which form part of the Personal Data (Privacy) Ordinance.
This Privacy Policy applies to any personal data you provide to Liberty directly and any personal data Liberty collects about you from other sources such as intermediaries or brokers.
Key terms
Personal data is information or opinion that allows others to identity you. It includes your name, date of birth, gender, contact details, health information and financial information.
2. Why Liberty collects personal data
Liberty collects your personal data:
- to administer our client relationship with you (as an insured, broker, or intermediary) including assisting you with any information or queries you may have about a Liberty product or service;
- if you are a prospective employee of Liberty; or
- to provide you the products and services Liberty offers. This may include offering policies of insurance, risk management and claims handling. Liberty may use your personal data to check whether you are eligible for a product or service, provide you with a product or service or help manage the product or service. This can occur in the context of issuing insurance quotes and policies of insurance, underwriting policies of insurance and managing claims and complaints.
Liberty also collects your personal data to:
- develop and identify products and services that may interest you, by conducting product and service research and sharing your information with Liberty’s related entities for them to be able to offer you products and services;
- establish and administer alliances and other arrangements with third parties (discussed below) in relation to the promotion, administration and use of Liberty’s respective products and services;
- track your use of our website, products and services to enhance user experience; and
- facilitate events, meetings and activities when you visit any of our office locations in Australia.
We may also use your information in the course of performing business activities including reporting and analytics. This may include the use (either in an identified or de-identified form via aggregation) of your personal data for product and service data analysis, data trend analysis and the development of business strategy.
3. What type of personal data Liberty collects
The personal data Liberty collects about you will depend on the nature of our relationship with you and can include:
- your name, date of birth, gender, mailing address, telephone number and e-mail address;
- identification information such as your passport details or driver licence;
- bank and payment details; and
- if relevant, information about your job such as job title, employment history and professional accreditations.
Applying for a specific product or service, or making a claim, may also require us to collect additional personal data about you (where relevant to that product or service), including:
- your insurance history; and
- your financial information such as bank account details, billing information or insurance payment arrangements to collect premiums or to pay claims.
When you make a claim with Liberty, we may collect personal data that is more sensitive in nature. For example, in relation to the purchase of, or making a claim under a casualty insurance policy, this may include any information about your membership of professional associations, health information, religious beliefs, criminal record, financial details and identification documents, where this is relevant. More specifically, when you take out a policy or make a claim with Liberty, we may collect the following information to the extent it is relevant to that policy or claim:
- details about your criminal convictions and any related information;
- details about your physical and mental health, including medical reports, x-rays and blood tests; and
- information which may reveal personal data that is sensitive, such as when you take out a policy or where you specify certain medical treatments.
If you do not provide us with the personal data we request (or our third parties request on our behalf) we may not be able to provide you with the appropriate type or level of products or services.
4. How Liberty collects personal data
Liberty mostly collects personal data directly from you in the course of providing our products or services and undertaking business operations (for example, underwriting, claims processing, etc) in relation to you or those you represent (for example, if a broker is acting as your agent).
In some cases, we may collect your personal data indirectly from a third party. For example, an insured's representative (such as a broker) may tell us about other persons wanting the benefit of Liberty’s services or the relevant product. Another example might be the personal data of a director, officer, professional or other staff member being provided to us by an insured company. In limited circumstances, we might also collect information about you for a claim made by you from a private investigator or through publicly available sources.
Liberty may also collect your personal data through our own representatives or third parties such as loss adjusters, lawyers, insurers, health care workers, or witnesses to a claim.
If you are a third party making a claim against one of our insureds (for example, an individual or entity holding an insurance policy with us), we may collect your personal data directly from you when making a claim or complaint, or when you contact us by email, telephone or any other written and verbal communications. We may also collect your personal data from our insured, and any third parties involved in the insurance policy or the claim you are making.
5. Disclosing your personal data
Within Hong Kong
Liberty will disclose your personal data to third parties within Hong Kong in the normal business of conducting insurance operations, such as providing you with an insurance quote, processing, servicing, administering your insurance policy and claims, our business administration and when permitted or required by law.
For example, in providing our services to you we may provide information to:
- other insurers;
- reinsurers (which provide insurance to Liberty itself or to other insurance providers);
- insurance intermediaries (e.g. insurance and reinsurance brokers, agents, appointed representatives and distributors);
- governmental authorities, industry bodies or as required by a statutory or regulatory authority;
- providers of analytics and fraud detection services;
- Liberty’s own advisers or external third party service providers including loss adjusters, lawyers, private investigators, auditors, accountants and similar third party service providers that facilitate the handling of a claim.
Liberty limits our use and disclosure of your personal data to the purposes for which you have been notified (or consented to, as the case may be) including in the Privacy Policy. However, there may be circumstances in which Liberty uses or discloses your personal data for a secondary purpose if:
- it is reasonably necessary to do so. For example, Liberty may disclose your personal data to an outsourced service provider in carrying out our business activities such as auditing; or
- the secondary purpose is ‘related’ to the primary purpose of collection. This situation may arise if an external third party is engaged for the purposes of acting on our behalf in respect of a claim or complaint filed against us.
The limitations to the use or disclosure of your personal data do not apply to direct marketing (refer to Section 9 below).
Outside of Hong Kong (i.e. transborder disclosure)
For the purposes noted above, Liberty may also transfer your personal data overseas (i.e. outside Hong Kong) if it is reasonably necessary in order to provide you with our products or services or to process claims or otherwise conduct our business.
For example, depending on the product or service you have, we may transfer your personal data to overseas insurers, reinsurers, Liberty Mutual Group entities and other third party providers (or provide them access to it). Liberty may also store your information with overseas third party cloud or other types of networked or electronic storage providers. The overseas Liberty Mutual Group entities and third parties referred to above may be located in countries outside of Hong Kong, including:
- the United States;
- Canada;
- United Kingdom;
- European Union;
- India;
- Australia;
- Malaysia; and
- Singapore.
By engaging Liberty for the purposes of taking out a policy, accessing any of Liberty’s products or services, making a claim and/or providing your personal data to us, absent any written indication to the contrary (by you to us), you consent to all reasonably necessary cross-border transfers of and access to your personal data as noted in this Privacy Policy.
6. What Liberty expects of you (when providing another's personal data to us)
When you provide Liberty with personal data about other individuals, we rely on you to undertake certain actions and confirm that you have performed those actions. We expect you to:
- have made them aware that you will be providing their information to Liberty (and confirmed that they agree to this);
- provide them with a copy of (or details of where they can find) this Privacy Policy;
- explain the purposes for which Liberty will use their personal data and that the types of third parties Liberty may disclose it to is set out in the Privacy Policy; and
- explain how they can access or correct their information and that how they may make a complaint by reference to this Privacy Policy.
When obtaining another individual’s agreement to share their personal data with Liberty, this can be given to you expressly or impliedly but must be clearly intended to be given. If you have not done any of the above actions, you must tell us before you provide us with the relevant personal data.
If Liberty gives you any personal data about another person (including if you are acting as a representative) you must only use it for the agreed express purposes and in accordance with this Privacy Policy.
7. Security of your personal data
Liberty holds personal data in both electronic and hard copy formats and takes reasonable steps to protect your personal data from misuse, interference, loss, unauthorised access, modification and disclosure. We take reasonable steps to maintain up to date computer and network security and impose clear privacy restrictions on all third parties who will handle your personal data.
Liberty will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy. Where your personal data held by us is no longer needed for any purpose then, subject to any legal requirements to hold it, we will take steps to securely destroy your personal data.
8. Accuracy of an access to your personal data
You may access or seek correction of the personal data Liberty holds about you. Liberty will, on your request, provide you with access to your personal data that we hold unless there is a legal exception preventing us from providing you with access to that data. For example, where giving access would have an unreasonable impact on the privacy of another individual, Liberty will not provide you with access to that personal data.
If Liberty does not provide you with access, we will provide you with reasons for the refusal and inform you of any legal exceptions relied upon where we are not able to provide this information to you. Liberty may recover from you its reasonable costs for retrieving and supplying your personal data to you that you have requested access to.
If you would like to access or correct your personal data, please contact Liberty’s Privacy Officer (details at section 12).
Your request to access, correct or update your personal data will be dealt with as soon as reasonably practicable, and we will respond to you no later than 21 days from your original request.
9. Opting out of receiving marketing information
As noted in Section 2 ‘Why Liberty collects your personal data’, we may use your personal data to offer you products or services we believe may be of interest to you and we may provide your personal data to our related companies for that purpose.
However, if at any time you no longer wish to receive marketing information about Liberty or our related companies' branded products and services, please let us know by contacting Liberty’s Privacy Officer. We will act promptly on your request.
10. Making a complaint
If you wish to make a complaint about how we are handling your personal data or you have any query regarding how your personal data is collected, used or disclosed or any other query relating to the Privacy Policy, please contact Liberty’s Privacy Officer:
Mail: Privacy Officer
Suites 2401-04 24/F Cityplaza One, 1111 King’s Road Tai Koo Shing, Hong Kong
By email: Privacy.Officer.AP@libertyglobalgroup.com
Liberty will respond to your query or complaint as soon as possible and will try to resolve any complaint within 21 business days. If this is not possible, we will contact you within that time to inform you that further time is required to assess the resolution of your complaint.
11. Liberty's websites
You can browse Liberty’s website (the Site) without having to tell us who you are or revealing any personal data. We may use various technologies to passively collect information from you while you are visiting the Site. We do log non-personal data and general statistical information such as domain name, Internet Protocol (IP) address and browser type. For example, we may use "cookies" (sets of information assigned to you by our web server when you visit the Site) only for maintaining information between pages. They are not used for storing or tracking your personal data as a visitor on the Site. If you wish, you can set your computer to decline cookies. However, if you do, you are fully responsible for altering your browser software to do this.
12. Contacting Liberty Hong Kong
If you wish to gain access to or correct your personal data held by Liberty Hong Kong, opt out of receiving marketing information, make a complaint in relation to your personal data or if you have any query relating to this Privacy Policy, please contact Liberty’s Privacy Officer on:
Email: Privacy.Officer.AP@libertyglobalgroup.com
Mail: Suites 2401-04 24/F Cityplaza One, 1111 King’s Road Tai Koo Shing, Hong Kong
Website: www.libertyspecialtymarkets.com.hk
13. Updating this Privacy Policy
Liberty may update this Privacy Policy from time to time, and in any event at least annually, to reflect our current practices and changes in law, regulation and/or industry standards. The updated Privacy Policy will replace the version on our Site.
This Privacy Policy was last updated on 8 March 2024.
14. Publication
This Privacy Policy is to be published on the Liberty Hong Kong website.