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Chubb Life Assurance Public Company Limited  (collectively “the Company”, “we”, “us” or “our”) recognize the importance of your personal data and therefore issue this Privacy Policy in order to help you understand our guidelines on protecting your personal data, to describe our grounds for and means of collection, use, disclosure including the rights described in the Data Protection Law and channel to contact to the Company for accessing, correcting, and/or deleting the personal data or requesting for any right incompliance with the Personal Data Protection Act 2019 (“PDPA”) and all relevant laws and regulations.

Chubb reserves the right, at any time, to correct, add, change, improve or modify this Privacy Policy to the extent permitted by law, simply by notifying you of such change, improve, or modification.

1. Definition

“Personal Data” means any identified or identifiable information about you both direct or indirect such as name-surname, date of birth or any other information that may identify you; except information about the deceased.

“Sensitive Personal Data” means any personal data which may affect the data subject such as racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, biometric data etc.

2. Collection of Personal Data

We will collect, use and/or disclose (“Processing”) your Personal Data to the extent necessary to fulfill any of purposes of business operation related to the life insurance products and/or services of the Company (“Products and/or Services”) offered to you. In case you do not allow the Company to process your Personal Data, the Company may not be able to provide the Products and/or Services to you.

Your consent given to the Company (including but not limited to agent, broker, third party or service provider, partner, and other relevant persons) for processing your personal data related to the Product or Services of the Company is important. 

3. Personal Data the Company collects

To offer the Products and/or Services, the Company may collect the following information whether directly or indirectly receiving from you or from the third person: 

  1. The personal information such as name-surname, gender, date of birth, age, weight, height, blood group, nationality, marital status, ID number or passport number, address, phone number, email or any other information that may be used to identify you.
  2. Contact information such as contact details, social media information, IP address, records for offering products or receiving the services in form of image and voicemail, voice record, image records, including but not limited to contact details of person for emergency case.
  3. Health information such as medical history, consultation, medical examination, medical investigation, nurse notes, prescription, medical treatment record, medical services rendered, medical report, autopsy reports, and medical billing including but not limited to health questionnaire, and any information in form of document, folder, report, plan, map, drawing, photo, film, picture and voice recorded by electronic devices.
  4. Information of family members or relevant persons such as beneficiary, premium payor, policy holder, insured members.
  5. Financial information such as revenue, source of income, bank account number, credit/debit card number, credit/debit card statement, tax information, bank account statement, loan information, investment information, and any financial information that may be declared in application form or Financial Need Analysis form.
  6. Sensitive Personal Data under the PDPA. 
  7. Products and/or Services details that you have purchased or received from the Company or other insurance companies such as policy number, sum assured, amendment or transaction related to the insurance policy, payment method, payment history, loan history, claim record, and exercising rights under the insurance policy or any other services, American citizen status under the Foreign Account Tax Compliance Act (FATCA), including products and service that you purchased from our partners such as car leasing, motorcycle leasing, home leasing, credit card etc.
  8. Any information the Company has received from the third person such as financial or marketing information, or other information that the Company can use to develop the Products and/or Services.
  9. Technical data and personal activities/preference collected when you use our websites, application and online social network platforms of the third-party provider, such as customer’s unique identification on social media platforms, IP address, browser type and version, time zone settings, browser plugin types, operating systems and platform, user profile, device information (including with respect to mobile devices the IMEI number, wireless networks and general network information), computer traffic information (Log).
  10. Data relating to fraud, offence both prosecuted and non-prosecuted such as criminal record, civil and criminal litigation record, other litigations including but not limited to record and/or documents of the officer and court orders, history of bankruptcy, money laundering, terrorist support provided or designated by the Competent Regulators.
  11. Education and employment information such as transcript from school or university, certificate, employment history which are occupation, position, employer details, workplace, and/or employment history, salary, remuneration.
  12. Data relating to the work performance, award received, history of complaints, license revocation, license suspension, termination of agency/broke agreement, discipline penalties, including audit and risk assessment, etc.
  13. Data of transactions or request for services due to the execution of covenants or agreements, or an acceptance of condition between you and the Company including but not limited to the data you provided when engaged in activities, competition, campaign, or any survey with the Company etc.
  14. Other data such as photo, video or record by CCTV or other electronic device, data for applying to use the website or application, data from using the Company’s website or application operated by the Company, social media information.

You may choose not to allow the Company to collect some of your Personal Data requested by the Company. However, this may lead to an obstacle to the Company’s ability to enter into the transaction with you or to provide you the services, or to respond to your requests such as the inability of the Company to enter into the insurance contract with you, or to provide any service related to insurance products including the claim for compensation.

4. Source of receiving your Personal Data

The Company may collect and receive your Personal Data through the following channel:

  1. Directly received from you and/or members of your family including the beneficiary when you purchase the Products and/or Services of the Company;
  2. When you apply and/or register website or application of the Company or any other channel including form regarding the Products and/or Services you already had or interested;
  3. When you or the policy holder exercises the right or receive the benefit arising in connection with the insurance policy or authorizing you to apply the group insurance as representative of insured;
  4. When you enter into any agreement with the Company or give an information for transactions or services;
  5. When you contact with Customer Care Center, Complaint unit, agency, broker, business partner, contractor, service provider or any other related unit (via telephone, letter, social media, interviewing, SMS, email, or other means);
  6. When you attend a marketing activity or any customer relationship activity such as draw lots, contest, survey, exhibition held by the Company, partnership, or any service provider engaged by the Company which may collect your personal data;
  7. Chubb Group when you apply an insurance with Chubb Group or you used to apply such an insurance;
  8. Cookies records, IP address of your computer when you access the website or application of the Company;
  9. Government authorities such as the Anti-Money Laundering Office, the Office of Public Sector Anti-Corruption Commission, the Office of Insurance Commission, the Royal Thai Police, Legal Execution Department or other related authorities;
  10. When you physically come to the Company or attend the Company activity, fair, or Company booth, you may be recorded via CCTV, camera, or video by the Company or agency;
  11. When you attend the activities, meetings, training held by partnership of the Company or the third party that Company engages with for such activities; or
  12. When the Company receives your personal data from the third person including but not limited to the data from the public data source, personal data source or commercial data source, website, application,  social media network, data providers, medical data source, public health center, hospitals, doctors, other public health professional, other insurance companies, association or union of any business related to insurance products which you have purchased, application form for insurance products you have purchased, complaint to insurance Products and/or Services of the Company which you have purchased or used (“Data Source from Third person”);

By providing us with any personal data relating to a third person (including without limitation to the insured persons, family members, premium payors,  or beneficiaries), you certify the accuracy of such personal data and you warrant that you have fully informed and obtained the consent from such third person for the Company to collect, use, disclose and transfer such third party’s personal data for the relevant purposes.

5. Purposes of Personal Data Collection, Use, and/or Disclosure

The Company processes your Personal Data for the purposes as follows:

  1. To offer to sell, sell, provide, manage, operate, comply with the procedures, and administer Products and/or Services of the Company to/for you;
  2. To underwrite, reinsure, calculate the premium, serve any service related to the insurance and/or insurance policies that you have purchased with the Company including to entering into the relevant agreements, delivering the insurance policies and managing the insurance policies;
  3. To conduct and manage the  Products and/or Services incompliance with procedures such as assessment of your financial status in order to introduce Products and/or Services which suitable to you, profiling,  processing an application for insurance products following to the procedures, administration of Products and/or Services which you have purchased, performing the Company’s obligations such as colleting the premium and outstanding debt, managing the provident funds, conducting an investigation, analysis, processing, policy surrendering, and paying compensation/benefit under your insurance policy, and extension, amendment or termination of you insurance policy including monitoring, following the sale offering process to ensure that it is incompliance with rules and regulations required by law and the Company’s policy;
  4. To exercise the rights under your insurance policy that you have purchased with the Company including subrogation of right and right subrogated;
  5. To design the new Products and/or Services of the Company or support the current Products and/or Services of the Company;
  6. To reinsure any insurance Products and/or Services of the Company;
  7. To manage the complaint, comments, questions, including accessing or modifying of data or exercising any right regarding the data, communication, public relation, or contacting you in order to notify the rights and benefit under the policy to you;
  8. To examine and verify the information such as Identification Card verification, and business auditing both internal and external etc.;
  9. For purpose of storing, archiving, back-up of data including data stored on cloud, IT securities monitoring, IT operating relating to the services such as Online payment, Mobile Application, and other online platforms;
  10. For IT infrastructure management and security of the Company, implementation of IT system, managing data on server and website, data analytics, business continuity management;
  11. For processing your behavior of websites, mobile applications or other social network platforms using to analyze and understand the use of such websites, mobile applications or other social network platforms you have accessed in order to enhance the websites, applications or social media platforms to satisfy with your interests, evaluate and improve the websites, application or social media platforms, Products and/or Services of the Company, find solutions, suggestion regarding Products and/or Services, and management of advertisement on websites, application and other channels with targeted customers;
  12. For executing of laws, assisting, and cooperating in investigation conducted by or on behalf of the Company, by police, government authorities or other regulators, reporting according to legal duty or agreement with government authorities or other regulators or performing any action legally ordered by the government agency or authorities;
  13. To perform duties under the laws, rules, disciplines, agreements, or existing policy enforced by regulators, legal authorities, government agency, dispute resolution authorities, or the authorities that regulate the insurance business such as Law of Life Insurance, Law of Anti-Money Laundering, Revenue Code, Law of Data Protection;
  14. For investigation or prevention of fraud, insurance fraud, and other acts whether an offense or a suspicious offense, in particularly for communicating among the insurance industry and financial industry, including the communication with regulator agency related to the Company;
  15. For providing services, assistance and facilitation to you in respect with the communication between you and the Company, including any communication regarding data management and any data related to insurance products or accounts which you have with the Company or communication of any amendment to this Policy in the future;
  16. For administration, control, examination of life insurance agency and/or life insurance broker in order to build quality in insurance including but not limited to resource planning, commission, remuneration, incentive payment, offer, award and performance assessment;
  17. For marketing activities of Products and/or Services provide to you such as communicating the information and advertising the Products and/or Services, sale promotions, customer relation activities held by the Company or partnership or service providers the Company engaged with, benefits which may be done by application, website, email, SMS or post;
  18. For marketing research, data analysis, questionnaire, and training in order to improve the quality of services and develop the products to satisfy your needs including building the good customer experience;
  19. For adjusting the Company’s structure, and Company’s transactions;
  20. For of security of employee and third person including properties and data of the Company;  or
  21. To proceed other necessary matters directly related to the above purposes.

Lawful Basis for processing the Personal Data

Subject to the following lawful basis, the Company may process the Personal Data for the purposes mentioned above:

  • It is necessary for performing the contracts that you are a party or responding your request prior to entering into the contracts.
  • It is necessary for prevention or suppression of a danger to a person’s life, body or health.
  • It is necessary for compliance with a law.
  • It is necessary for legitimate interest of the Company or any other person or juristic persons other than the Company.
  • It is necessary for the performing the duties for public interest of the Company or it is necessary for exercising of official authority vested in the Company.
  • It is for the purpose of the research or statistic, in which the Company shall have the appropriate measures to protect your rights and freedom.
  • Your consent provides to the Company for the event that no lawful basis is available for the Company to use.

Except for otherwise prescribing in Personal Data Protection Law and other laws in force, if the Company would like to use your personal data for any other purpose other than prescribed herein or any other purposes directly relating to this policy, the Company will notify and request for your consent accordingly. 

6. Disclosure of your Personal Data

To comply with the purposes of collecting and storing the Personal Data, the Company may disclose your Personal Data to the following persons both located in Thailand or outside Thailand:

  1. Management, directors, employees, staff, agency, internal person that relevant and necessary to process your personal data, under the purposes written in this policy;
  2. Chubb Group;
  3. Any personnel or vendor of the Company who provides the services that is related to the administration, data processing service, business process service, payment service, debt collection, or security debit service, telecommunication service, IT service, cloud service, personnel outsourcing service, call center service, storage service, documentation service, data collection service, document scanning service, postal service, printing service, parcel delivery service by parcel delivery officer, data analysis service, marketing service, research service, emergency management service, legal service or other services in connection with the business operation of the Company or provide for management, operation, procedure proceeding , or any other management in connection with Products and/or Services of the Company to you;
  4. Any authority who has duty under the law, the Commission established under the law, regulator, dispute resolution authority, government authority, or any person to which the Company or Chubb Group is required to disclose the data according to its obligations permitted by the relevant laws and/or regulations both in Thailand and other countries that Chubb Group is located;
  5. Reinsurance broker or reinsurance companies;
  6. Policy holder for group insurance;
  7. Any person or authority that you consent to disclose your Personal Data to such person or authority;
  8. Any person who do or may do the transaction with the Company whereby your Personal Data may be a part of that transaction or a part of selling or purchasing the ownership of the Company whether in whole or some part;
  9. Partnership or Party of the Company such as agency, broker, other insurance companies, reinsurer, Sub-reinsurer, other companies who sells the Company’s products;
  10. Any person who has been authorized to act as the Company’s personnel or the Company’s Party, or employed by or entered into a contract with the Company in order to invite, introduce, advise, manage, offer, sell, distribute, or provide the services in relation to the Products and/or Services of the Company including delivering the Products and/or Services that the Company offered/ sold to you or providing sale promotion, advertisement such as life insurance agency, life insurance broker, asset management company, bank, financial institution, credit rating institution, company that perform the investigation, or any other vendor; 
  11. Any person who has been employed by or enter into a contract with the Company to invite, introduce, advise, manage, offer, sell, distribute, or provide the Products and/or Services of the Company or Chubb Group to you;
  12. Service Provider that provide services related to the life insurance business to the Company and Chubb Group such as actuary, investment adviser, investment planner, marketing service provider, advertisement service provider, data analysis service provider, translator, any other service provider that the Company has engaged with to develop the Products or Services;
  13. Professional advisers of the Company such as lawyer, auditor, doctor, any other consultant in other field;
  14. Thai Life Assurance Association, any association relevant to the insurance business or other relate business, and other insurance companies; or
  15. Any related person or authority permitted by the relevant laws.

7. Retention period of Personal Data

The Company will retain your Personal Data as long as it deems necessary for collecting and processing your Personal Data under the purposes mentioned above and performing the duties and obligations under the related laws and regulations. However, the Company may retain your Personal Data for longer period if it is required by law.

The Company will retain your Personal Data for necessary and reasonable period under the purposes of collection, use and disclosure of Personal Data mentioned above not exceeding 11 years from the termination date of the transaction between you and the Company. However, the Company may retain the Personal Data for longer period if it is required by law.

If your Personal Data is no longer needed to use, the Company will process to delete or destroy or anonymize your Personal Data without giving a notice in advance.

8. Cross-border Transfer of Personal Data

The Company may disclose or transfer your Personal Data for storing or processing in other ways or submit to any person or authority which located in Thailand or overseas which the destination countries may or may not have the same data protection standards as Thailand for the purposes specified in this policy. In addition, we have taken steps and measures to ensure that your Personal Data is securely transferred, that the data recipients have appropriate data protection standards in place, and that the transfer is lawful by relying on the derogations as permitted under the law. 

9. Processing your Sensitive Personal Data

The Company will process your Sensitive Personal Data as it deems necessary to carry any action under the lawful purposes specified herein. If you do not give the consent to process your Personal Data, the Company will not do the underwriting or provide any service to you. In case you withdraw the given consent or object the collection, use, and/or disclosure or request the Company to delete such Sensitive Personal Data, the Company will not perform its obligations under the insurance contract, other contracts, or services that related to your insurance contract both entire or some part or the Company may not enter into the contract with you. In this case the Company will process your Sensitive Personal Data in compliance with the terms and conditions set in this policy. 

10. Personal Data of Minor, Quasi-Incompetent Person, and Incompetent Person

The Company may collect and process any Personal Data of minor (whose age under 20 years old), quasi-incompetent person and incompetent person from time to time. In such case, the Company shall comply with the Personal Data Protection Law which is related to such processing of the Personal Data. This shall include a request for obtaining consent from a legal representative or parents (in case of minor), a request for obtaining consent from legal guardian (in case of incompetent person) and a request for obtaining consent from legal guardian (in case of quasi-incompetent person) as required by the Personal Data Protection Law.

11. Cookies Policy

We use “cookies” technology to identify and record the data regarding website using in order to deliver the better service and experience for using the Company’s website including developing and improving our website. Cookies consists of a small data file recorded in your electronic device. However, you may check your cookies status or may reject cookies in your browser. For more information, you may study for cookies details at here

12. Your Rights Relating to Your Personal Data

You may exercise the following rights regarding your Personal Data:

  1. Right to access: You may have the right to access and request for obtaining the copy of your Personal Data or right to request the Company to disclose the source of such Personal Data;
  2. Right to data portability:  You may have right to request the Company to send or transfer to you or other Data Controller your Personal Data in case that the Company arranges your Personal Data in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means unless it is impossible to do so because of the technical circumstances.
  3. Right to rectification: You may have right to request the Company to rectify your Personal Data in order for data to be accurate, updated and not misleading.
  4. Right to eraser: You may have right to request the Company to erase, destroy or anonymize your Personal Data.
  5. Right to restriction of processing: You may have right to request the Company to temporarily restrict the collection, use and/or disclosure of your Personal Data when processing of Personal Data is no longer necessary.
  6. Right to objection: You may have right to object the collection, use and/or disclosure of your personal Data.
  7. Right to withdraw consent: You have right to withdraw the given consent except for there is limitation to do so under the law or contract that benefits to you.
  8. Right to submit the complaint.

If you would like to exercise the specified rights, you may contact to the Company directly, details provided in Clause 13. In such case, your right may be subjected to conditions and exclusion permitted by the laws and the Company may reject your request for exercising the right as permitted by law.

If you withdraw your consent to collect, use, or disclose your Personal Data for non-marketing purposes, the Company may be unable to provide the services, and/or manage your products, and/or your account you have with us. This may be disadvantage to you, as you may be losing benefits under your policies or programs, or you may not receive the insurance coverage as same as the previous coverage in the future.  

13. Personal Data Security

The Company shall maintain technical, physical, and administrative security measures designed to provide optimal protection of your Personal data from loss, misuse, unauthorized access, disclosure and modification to ensure that your Personal Data that the Company collects is protected according the standard required by law. 

14. Contact

If you have any question regarding this Privacy Policy or need more information, please contact Data Protection Officer (DPO) via email at dpo.ChubbLifeTH@chubb.com or contact at the following address:

Chubb Life Assurance Pcl.
130-132 Sindhorn Tower Building 1, 11th -12th Floor, Wireless Road, Lumpini, Pathumwan, Bangkok 10330

(updated on May 1, 2021)