Personal Information Collection Statement

PERSONAL INFORMATION COLLECTION STATEMENT

(this "Statement")

AIA Company (Trustee) Limited (the "Company", "we", "us" or "our") is a wholly owned subsidiary of AIA Group Limited. AIA Group Limited, together with its subsidiaries and affiliates are collectively referred to in this Statement as the "AIA Group" and individually referred to as an "AIA Entity".
 
From time to time, it is necessary for you, as (prospective) participating employers ("Participating Employers") and/or members ("Members") (collectively referred to as "you" or "your"), to provide the Company with certain personal data relating to you in connection with the application for and provision of pension schemes as well as the carrying out by the Company of other services relating to the pension schemes. Failure to supply such data may result in the Company being unable to process your application for pension schemes or to provide or continue to provide the pension schemes and/or relevant services to you. During the course of your relationship with the Company, further personal data relating to you, may also be collected in the ordinary course of our business. If you provide personal data to the Company about another individual, you confirm that you are either (i) the parent or legal guardian of the individual, or (ii) you have obtained the individual's consent to provide his or her personal data to the Company, and for such personal data to be used, processed, disclosed and transferred in accordance with this Statement.
(1) PURPOSES FOR COLLECTING PERSONAL DATA
Personal data relating to you held or collected by the Company (including but not limited to credit information and claims history) may be used by the Company for the following purposes ("Purposes"):
 
  1. processing, accepting and/or rejecting applications for Pension Schemes (as defined below);
  2. the administration and/or management of or in connection with the contributions or benefits or accounts in respect of the Participating Employers and/or Members under the pension schemes (the "Pension Schemes") administered by AIA Entities;
  3. providing Pension Schemes and related services to you, and processing requests made by you, from time to time in relation to the Pension Schemes and related services, including but not limited to making contributions, transfer of benefits, switching of pension funds and withdrawal of benefits;
  4. subject to your consent, conducting direct marketing activities of pension products and related services offered by AIA Entities as described in paragraph (3) below;
  5. performing functions and activities incidental to the provision of Pension Schemes and related services, including, without limitation, reporting, maintenance of online and other services, identity verification, data analysis, research and statistical analysis;
  6. improving and furthering the provision of Pension Schemes and related services (including through customer research or surveys) offered by AIA Entities, subject to applicable legislation; 
  7. complying with the obligations, requirements and/or arrangements for disclosing and using data that bind on or apply to the Company and/or the AIA Group or that the Company and/or the AIA Group is expected to comply with according to:
    1. any law binding on or applying to it within or outside the Hong Kong Special Administrative Region ("Hong Kong") existing currently and in the future (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
    2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance or financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines or guidance given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information); or
    3. any present or future contractual or other commitment with local, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of insurance or financial services providers that is assumed by or imposed on the Company or the AIA Group by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations; 
  8. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the AIA Group and/or any other use of data and information in accordance with any group-wide programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
  9. enabling an actual or proposed assignee, transferee, participant or sub-participant of the Company’s rights or business (or portions thereof) to evaluate or carry out the transaction intended to be the subject of the assignment, transfer, participation or sub-participation; and
  10. any other purposes relating to the purposes listed above.
(2) TRANSFER OF PERSONAL DATA
Personal data held by the Company relating to you will be kept confidential but the Company may provide such data to the following parties, whether inside or outside of Hong Kong, to fulfil the Purposes set out above in paragraph (1) of this Statement:
 
  1. any agent, contractor or third party service provider who provides services to the Company in connection with the operation of its pension business including administrative, telecommunications, computer, payment, data processing, storage, customer research or survey or other services in connection with the operation of the Pension Schemes;
  2. relevant Participating Employers (if applicable);
  3. any person or entity to whom the Company or the AIA Group is under an obligation or otherwise required to make disclosure under the requirements of any law or rules, regulations, codes of practice, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations binding on or applying to the Company or the AIA Group or with which the Company or the AIA Group is expected to comply, or to establish, exercise or defend or to protect legal claims, to protect the rights, property or safety of the Company or the AIA Group, or any disclosure pursuant to any contractual or other commitment of the Company or the AIA Group with local, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations, all of which may be within or outside Hong Kong and may be existing currently and in the future;
  4. AIA Entities;
  5. any actual or proposed assignee, transferee, participant or sub-participant of the Company's rights or business; and
  6. any persons who/which you have given instructions, authorization and consent to the Company in order to communicate with and provide information to them. 
From time to time, AIA Group or the Company may purchase a business or sell one or more of the Company's business(es) (or portions thereof). In the event that AIA Group or the Company purchase(s) a business, the personal data received with that business would be treated in accordance with this Statement, if it is practicable and permissible to do so. In the event that AIA Group or the Company sell(s) a business, provisions will be included in the selling contract requiring the purchaser to treat your personal data in the same manner required by this Statement.
(3) USE AND PROVISION OF PERSONAL DATA IN DIRECT MARKETING
Subject to your consent, the Company may use your personal data we collected for direct marketing of Pension Schemes and related services as described below:

  1. your name, your contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of you collected by the Company from time to time may be used by the Company in direct marketing; and
  2. the pension products and related services offered by AIA Entities may be marketed.
If you do not wish the Company to use your personal data we collected for direct marketing of pension products and related services, you may exercise your opt-out right by notifying the Company. To exercise your opt-out right, you may write to the Data Protection Officer of the Company at the address and email address provided in paragraph (4) of this Statement, or provide the Company with your opt-out choice in the relevant application form (if applicable).
(4) DATA ACCESS AND CORRECTION RIGHT
In accordance with the Personal Data (Privacy) Ordinance (the "Ordinance"), you have the right to request access to and the correction of any of your personal data held by the Company, by writing to the Data Protection Officer of the Company at the following address and email: 
 
The Data Protection Officer
AIA Company (Trustee) Limited
c/o AIA International Limited (as administrator)
12/F, AIA Tower, 183 Electric Road,
North Point,
Hong Kong
 
According to the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
 
  1. You also have the right to request for the Company's policies and practices in relation to personal data and to be informed of your personal data that is held by the Company by writing to the Company's Data Protection Officer at the address and email provided in paragraph (4) of this Statement.

  2. Nothing in this Statement shall limit your rights under the Ordinance.

  3. The Company retains the right to change this Statement.

  4. A Privacy Addendum under the Personal Information Protection Law of the People's Republic of China supplements this Statement and is available at https://www.aia.com.hk/en/privacy-statement-main. The Privacy Addendum applies to you if you are within mainland China.

Issued by AIA Company (Trustee) Limited
Last updated: Oct 2024