DATA PROTECTION POLICY
Lioner International Group Ltd and its subsidiaries and affiliates (collectively “Lioner”) have to ensure full compliance with the applicable legal and regulatory requirements relating to personal data protection.
This Data Protection Policy sets out the basis upon which Lioner Group (“we”,”us” or “our”) may collect, use, disclose or otherwise process personal data of employees, clients and referrers (collectively referred to as “you” or “your”).
This Policy will apply to you if you engage Lioner Group in connection with services provided by Lioner Group, if you indirectly benefit from such services or if you visit our website. By transferring personal data or visiting our website, you explicitly agree to the terms and conditions of this Policy.
Lioner Group shall revise this Policy from time to time to reflect changes in law or changes in its business operation. You can find the latest version of the Data Protection Policy on our website (https://www.lioner.com/dpo/). You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. We encourage you to periodically review our Data Protection Policy for the latest information on our privacy practices.
1. General Information
As used in this Policy, “personal data” means data, whether true or not, about the natural person who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
All information, materials and / or data received, collected or created during the course of employment belongs to Lioner Group, including but not limited to the following:
a) Company’s information
b) Client’s personal information
c) Bank partner information
d) Quotation
e) Presentation materials
f) Client’s materials
g) In-house templates
h) Research and data analysis
(collectively known as “Company Property”).
This Policy applies to Company Property in our possession or under our control. Any willful disclosure of the Company Property by an employee to any unauthorised party during the course of employment may result in immediate dismissal.
Additionally, Client’s Materials are strictly for distribution to clients and MUST not be circulated to any referrers, regardless of softcopy or hardcopy.
We reserve the right to take legal action against anyone who is in unauthorized possession of and / or has disclosed Company Property without authorization to any party. We also reserve the right to report such acts to the relevant authorities.
2. Confidentiality and Security of Information
Any information provided to us by you will only be used for purposes set out at Clause 3.1 below and will not be intentionally disclosed by us for any other purpose unless:
a) Lioner Group has obtained all necessary consents, whether from you or otherwise; or
b) Lioner Group is required to disclose the information by a court of competent jurisdiction or any government or regulatory body having requisite authority over any Lioner Group entity; or
c) The information is already in the public domain or has been received by Lioner Group from a third party not under any duty of confidentiality.
We will take appropriate steps to maintain the security of your confidential documents and information which are in our possession and will comply with any applicable law or regulations.
3. Collection, use and disclosure of Personal Data
3.1 Purpose of Collection
During the normal course of business, we may collect personal information and / or personal data about natural persons which you have provided to us in Hong Kong SAR or Singapore for the following purposes:
a) to process an application;
b) to administer and process insurance policies, insurance claims and medical claims, security and underwriting checks;
c) to process payment instructions;
d) to verify your eligibility for insurance, financial or wealth management products and services;
e) to evaluate your financial needs;
f) to design and provide you with insurance, financial and related services and products;
g) to conduct identity and / or credit checks;
h) to communicate with you;
i) to provide you with promotional materials relating to insurance or financial services or related wealth management products arranged by us or partnering insurance companies or financial institutions;
j) to perform a policy review or needs analysis;
k) to conduct research and statistical analysis;
l) to comply with the laws of any applicable jurisdiction or to meet disclosure requirements imposed by law or regulatory authorities;
m) to match any information / data held which relates to you from time to time for any of the purposes listed herein;
n) to carry out other services in connection with the operation of our business; and
o) for other purposes directly related to any of the above.
We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
You are entitled at any time to furnish us with, and we may periodically request for, further information to ensure that your personal data is kept up to date.
3.2 Classes of Transferees
We may disclose your information to third parties (within or outside Hong Kong SAR and/or Singapore) for the purposes outlined in Clause 3.1, including, without limitation, the following third parties:
a) insurance and re-insurance companies;
b) insurance brokers and agents;
c) companies within Lioner Group, if applicable;
d) claims investigation companies;
e) third party administrators;
f) third party service providers (including, without limitation, bankers, lawyers, healthcare providers, accountants, and other third party service providers who provide administrative, telecommunications, computer, payment, printing, redemption or other services to us to enable us to operate its business;
g) industry associations and federations;
h) medical bill review companies;
i) professional advisers;
j) researchers;
k) credit reference agencies,
l) partner financial institutions;
m) regulators and government agencies;
n) law enforcement agencies; and
o) the courts.
Each time we submit your personal information to external recipients who process that information on our behalf, we will contractually ensure that your information is transmitted, protected and processed in accordance with all applicable privacy laws.
4. Protection of Information
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosure of personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
4.1 Accuracy of Information
We generally rely on the information provided by you (or your authorised representative). In order to ensure that your information is current, complete and accurate, please update us if there are changes to your personal data.
4.2 Retention of Information
We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
5. Right of Access, Correction and Deletion
If you have any question, concern, or complaint about the way in which your personal information is handled by us, or you want to request for access to and/or correction/ deletion of your personal information handled by us, you may write to our Data Protection Officer at 17/F, 152 Queen’s Road Central, Central, Hong Kong or send an email to dpo@lioner.com.
Last updated: December 2022
