Personal Information Collection Statement

For Hong Kong Customers

For Macau Customers

AIA VITALITY PERSONAL INFORMATION COLLECTION STATEMENT

(this "Vitality PICS")

AIA Vitality is a health and wellness program, encouraging you to get healthier and earn great rewards. AIA Vitality is operated by AIA Group Limited, AIA Company Limited, and AIA Vitality (Hong Kong) Limited, (together known as "AIA Vitality Operator"), and is administered, managed and distributed in Hong Kong by AIA International Limited (acting through its Hong Kong branch) (collectively "we", "us" or "our"). We receive ongoing support from Discovery Limited (a company based in South Africa) and/or its affiliates (collectively, "DSY"), the global operators of the AIA Vitality program.

In order for us to provide AIA Vitality-related services to you, it will be necessary for us to collect, use and share certain personal data about you. Customers and potential customers expect us to maintain their information accurately, protected against manipulation and errors, secure from theft and free from unwarranted disclosure. We protect the data security of our customers and potential customers by complying with the Personal Data (Privacy) Ordinance (the "Ordinance"), and all relevant local laws, and ensure compliance by our staff with strict standards of security and confidentiality.

This Vitality PICS provides you with notice as to what personal data we will collect from you, why your personal data is collected, how it is intended to be used, to whom your personal data may be provided, from whom your personal data may be collected and how to access, review and amend your personal data.

It is important for you to note that we will not share any health or medical-related personal information that you provide as part of your participation in the AIA Vitality program with our underwriting or claims departments, except with your express consent.

From time to time, it is necessary for you, as an applicant for a membership under the AIA Vitality program or as a member of AIA Vitality (collectively referred to as "you" or "your"), to provide us with certain personal data relating to you in connection with your application for a membership and our provision of the AIA Vitality-related products and services. The provision of your personal data is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to provide you with the AIA Vitality-related products and services. During the course of your AIA Vitality membership, further personal data relating to you may also be collected in the ordinary course of our business. If you provide personal data to us 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 us, and for such personal data to be used, processed, disclosed and transferred in accordance with this Vitality PICS.

(1) PURPOSES FOR COLLECTING PERSONAL DATA

Personal data relating to you held or collected by us may be used by us for the following purposes ("Purposes"):

to process, administer, implement and effect the requests, transactions or membership services under AIA Vitality. In this regard, in addition to any personal data that the AIA Vitality Operator may collect directly from you, the AIA Vitality Operator may also need to collect from the AIA Vitality Partners (as defined below) information regarding your use of, and participation in (including progress and results from), the membership goods or services provided by the AIA Vitality Partners (as defined below);
to personalize, enhance and / or develop our benefits, services and recommendations to meet your needs under AIA Vitality, performing functions and activities incidental to AIA Vitality, including, without limitation, maintenance of online and other services, identity verification, data analysis, research and statistical analysis;
to communicate with you regarding updates and future changes to AIA Vitality, your AIA Vitality membership and account, or in relation to any of the purposes set out in this Vitality PICS;
to provide other AIA Vitality and/or loyalty program-related services such as online shopping at AIA Vitality website or AIA Vitality purchases to you;
to facilitate the friend searching and/or friend adding feature in the "ADD FRIEND" function in the AIA+ app or website, where other AIA Vitality members will be able to search your name and email address;
for statistical or actuarial research undertaken by us, our partners who provide goods and services under AIA Vitality ("AIA Vitality Partners"), DSY, or the respective regulators of the aforementioned parties;
to facilitate payment for products and/or services provided by AIA Vitality Operator, any other member of AIA Group Limited, together with its subsidiaries and affiliates ("AIA Group") or any AIA Vitality Partner, including but not limited to the verification of credit card details with credit card issuers or other third party service providers, obtaining consumer credit reports from a credit reference agency and conducting match making procedures against databases of known fraudulent transactions maintained by AIA Vitality Operator, any other member of the AIA Group, any AIA Vitality Partner or third party;
complying with the obligations, requirements and/or arrangements for disclosing and using data that bind on or apply to us and/or we are expected to comply with according to:
1. any law binding on or applying to us 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 us 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, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within us 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;
to enable an actual or proposed assignee or transferee of our rights or business (or portions thereof) to evaluate or carry out the transaction intended to be the subject of the assignment or transfer or to enable us to evaluate or carry out a proposed or actual assignment or transfer of a third party's rights or business (or portions thereof) to us. In the event that we purchase a third party's rights or business, the personal data received from the third party, to the extent that the rights or business are/is relevant to AIA Vitality, will be treated in accordance with this Vitality PICS. In the event that we sell our rights or business, to the extent that the rights or business are/is relevant to AIA Vitality, a provision will be included in the sales contract requiring the assignee or transferee to treat your personal data in the same manner required by this Vitality PICS;
for promotional and marketing purposes – subject to paragraph (3) below; and
other purposes relating to the purposes listed above.

(2) TRANSFER OF PERSONAL DATA

Personal data held by us relating to you will be kept confidential but we may provide such data to the following parties, whether inside or outside of Hong Kong, to fulfill one or more of the Purposes set out above in paragraph (1) of this Vitality PICS:-

AIA Group Limited and any company that is under its direct or indirect control, and DSY, for the purposes specified above;
any person authorized to act as an agent of the AIA Vitality Operator for the distribution of information in relation to AIA Vitality;
the AIA Vitality Partners and their agents for the provision of membership goods and/or services under AIA Vitality;
any agent, contractor or third party service provider who provides membership servicing support to us including but not limited to administration, data processing, data storage, call centre services, mailing, system infrastructure and operation, website administration, marketing, finance, rewards, invoicing and training;
other companies who assist us with statistical or actuarial research relating to AIA Vitality, such as research companies and ratings agencies;
any other person or entity under a duty of confidentiality to us which has undertaken to keep such data confidential;
any person or entity to whom we are 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, self-regulatory, industry bodies or associations, governmental, tax, law enforcement or other authorities, financial services providers binding on or applying to us, or with which we are expected to comply, or to establish, exercise or defend or to protect legal claims, to protect our rights, property or safety, or any disclosure pursuant to any of our contractual or other commitment(s) with local, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, financial services providers, all of which may be within or outside Hong Kong and may be existing currently and in the future;
any actual or proposed assignee or transferee of our rights or business or any third party whose rights or business is the subject of an actual or proposed assignment or transfer to us;
external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that we engage for the purposes set out in paragraph (1)(iv) of this AIA Vitality PICS; and
any persons who/which you have given instructions, authorization and consent to us in order to communicate with and provide information to them.

(3) USE AND PROVISION OF PERSONAL DATA IN DIRECT MARKETING

Subject to your consent, the AIA Vitality Operator may use your personal data we collected for direct marketing and provide your personal data to the Alliance Program Partners (as defined below) for their direct marketing as described below:

your name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data collected by us from time to time may be used by us for direct marketing;
the following services, products, advice and subjects may be marketed:
1. insurance, annuities, pension schemes, wealth management, credit cards, financial, banking and related services and products;
2. reward, loyalty, lucky draw programs or privileges programs and related services and products;
3. services and products offered by our co-branding partners and/or marketing partners (the names of such co-branding partners and/or marketing partners can be found in the application form(s) and/or promotional material for the relevant services and products, as the case may be);
4. charitable/ non-profitable, educational, recruitment and training causes; and
5. medical/health treatment; medicine; educational; recruitment; training; reward/loyalty/privilege programs; travel; airlines, accommodation; apparel; concerts; movies; gymnasium and fitness; sporting and special events; sports and fitness equipment; food and beverage; health supplement; household; media; social networking; spa and similar relaxation activities and other leisure services; telecommunication and mobile services; internet; other retail/consumer products and services; health and wellness; hospitality services; transportation; electronics; fine art; gallery/exhibition,
  
  (collectively "Classes of Marketing Subjects");
the above Classes of Marketing Subjects may be provided by us and/or the persons/providers below:
1. each of the AIA Vitality Partners;
2. third party reward, loyalty, co-branding or privileges program providers;
3. our co-branding partners and/or marketing partners (the names of such co-branding partners and/or marketing partners can be found in the application form(s) and/or promotional material for the relevant services and products, as the case may be); and/or
4. medical/ healthcare and wellness service providers,
  
  (collectively "Alliance Program Partners");
in addition to our marketing of the Classes of Marketing Subjects, we also intend to provide your personal data described in paragraph 3(i) above to all or any of the Alliance Program Partners for use by them in any of the Classes of Marketing Subjects to contact you and/or send you promotional materials for direct marketing in relation to the Classes of Marketing Subjects that they offer (these materials may be sent to you by postal mail, email or other means). We will obtain your written consent (which includes an indication of no objection) before we pass your personal data to Alliance Program Partners for any direct marketing purposes.

If you do not wish us to use or transfer your personal data we collected to our Alliance Program Partners for direct marketing, you may exercise your opt-out right by notifying us. To exercise your opt-out right, you may write to our Data Protection Officer at the address and email address provided in paragraph (4) of this Statement, or provide us with your opt-out choice in the relevant application form (if applicable).

(4) DATA ACCESS AND CORRECTION RIGHT

In accordance with the Ordinance, you have the right to request access to and the correction of any of your personal data held by us, by writing to our Data Protection Officer at the following address and email:

The Data Protection Officer

AIA International Limited

12/F, AIA Tower, 183 Electric Road,

North Point,

Hong Kong

Email: AIAHK.Compliance@aia.com

According to the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.

You also have the right to request our policies and practices in relation to personal data and to be informed of your personal data that is held by us by writing to our Data Protection Officer at the address and email provided in paragraph (4) above.
Nothing in this Vitality PICS shall limit your rights under applicable laws.
We retain the right to change this Vitality PICS.
A Privacy Addendum under the Personal Information Protection Law of the People's Republic of China supplements this Vitality PICS 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.

Last updated: Oct 2024

AIA VITALITY PERSONAL INFORMATION COLLECTION STATEMENT

(this "Vitality PICS")

AIA Vitality is a health and wellness program, encouraging you to get healthier and earn great rewards. AIA Vitality is operated by AIA Group Limited, AIA Company Limited, and AIA Vitality (Hong Kong) Limited, (together known as "AIA Vitality Operator"), and is administered, managed and distributed in Macau by AIA International Limited (acting through its Macau branch) (collectively "we", "us" or "our"). We receive ongoing support from Discovery Limited (a company based in South Africa) and/or its affiliates (collectively, "DSY"), the global operators of the AIA Vitality program.

In order for us to provide AIA Vitality-related services to you, it will be necessary for us to collect, use and share certain personal data about you. Customers and potential customers expect us to maintain their information accurately, protected against manipulation and errors, secure from theft and free from unwarranted disclosure. We protect the data security of our customers and potential customers by complying with the Macau Personal Data Protection Act (the "Act"), and all relevant local laws, and ensure compliance by our staff with strict standards of security and confidentiality.

From time to time, it is necessary for you, as an applicant for a membership under the AIA Vitality program or as a customer or member of AIA Vitality (collectively referred to as "you" or "your"), to provide us with certain personal data relating to you in connection with your application for a membership and our provision of the AIA Vitality-related products and services. The provision of your personal data is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to provide you with the AIA Vitality-related products and services. During the course of your AIA Vitality membership, further personal data relating to you may also be collected in the ordinary course of our business. If you provide personal data to us 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 us, and for such personal data to be used, processed, disclosed and transferred in accordance with this Vitality PICS.

(1) PURPOSES FOR COLLECTING PERSONAL DATA

Personal data relating to you held or collected by us may be used by us for the following purposes ("Purposes"):

to process, administer, implement and effect the requests, transactions or membership services under AIA Vitality. In this regard, in addition to any personal data that the AIA Vitality Operator may collect directly from you, the AIA Vitality Operator may also need to collect from the AIA Vitality Partners (as defined below) information regarding your use of, and participation in (including progress and results from), the membership goods or services provided by the AIA Vitality Partners (as defined below);
to personalize, enhance and / or develop our benefits, services and recommendations to meet your needs under AIA Vitality, performing functions and activities incidental to AIA Vitality, including, without limitation, maintenance of online and other services, identity verification, data analysis, research and statistical analysis;
to communicate with you regarding updates and future changes to AIA Vitality, your AIA Vitality membership and account, or in relation to any of the purposes set out in this Vitality PICS;
to provide other AIA Vitality and/or loyalty program-related services such as online shopping at AIA Vitality website or AIA Vitality purchases to you;
to facilitate the friend searching and/or friend adding feature in the "ADD FRIEND" function in the AIA+ app or website, where other AIA Vitality members will be able to search your name and email address;
for statistical or actuarial research undertaken by us, our partners who provide goods and services under AIA Vitality ("AIA Vitality Partners"), DSY, or the respective regulators of the aforementioned parties;
to facilitate payment for products and/or services provided by AIA Vitality Operator, any other member of AIA Group Limited, together with its subsidiaries and affiliates ("AIA Group") or any AIA Vitality Partner, including but not limited to the verification of credit card details with credit card issuers or other third party service providers, obtaining consumer credit reports from a credit reference agency and conducting match making procedures against databases of known fraudulent transactions maintained by AIA Vitality Operator, any other member of the AIA Group, any AIA Vitality Partner or third party;
complying with the obligations, requirements and/or arrangements for disclosing and using data that bind on or apply to us and/or we are expected to comply with according to:
1. any law binding on or applying to us within or outside the Macau Special Administrative Region ("Macau") existing currently and in the future (e.g. Macau's relevant tax laws 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 Macau existing currently and in the future (e.g. guidelines or guidance given or issued by the Financial Services Bureau of Macau 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 us 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, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within us 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;
to enable an actual or proposed assignee or transferee of our rights or business (or portions thereof) to evaluate or carry out the transaction intended to be the subject of the assignment or transfer or to enable us to evaluate or carry out a proposed or actual assignment or transfer of a third party's rights or business (or portions thereof) to us. In the event that we purchase a third party's rights or business, the personal data received from the third party, to the extent that the rights or business are/is relevant to AIA Vitality, will be treated in accordance with this Vitality PICS. In the event that we sell our rights or business, to the extent that the rights or business are/is relevant to AIA Vitality, a provision will be included in the sales contract requiring the assignee or transferee to treat your personal data in the same manner required by this Vitality PICS;
for promotional and marketing purposes – subject to paragraph (3) below; and
other purposes relating to the purposes listed above.

(2) TRANSFER OF PERSONAL DATA

Personal data held by us relating to you will be kept confidential but we may provide such data to the following parties, whether inside or outside of Macau, to fulfill one or more of the Purposes set out above in paragraph (1) of this Vitality PICS:-

AIA Group Limited and any company that is under its direct or indirect control, and DSY, for the purposes specified above;
any person authorized to act as an agent of the AIA Vitality Operator for the distribution of information in relation to AIA Vitality;
the AIA Vitality Partners and their agents for the provision of membership goods and/or services under AIA Vitality;
any agent, contractor or third party service provider who provides membership servicing support to us including but not limited to administration, data processing, data storage, call centre services, mailing, system infrastructure and operation, website administration, marketing, finance, rewards, invoicing and training;
other companies who assist us with statistical or actuarial research relating to AIA Vitality, such as research companies and ratings agencies;
any other person or entity under a duty of confidentiality to us which has undertaken to keep such data confidential;
any person or entity to whom we are 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, self-regulatory, industry bodies or associations, governmental, tax, law enforcement or other authorities, financial services providers binding on or applying to us, or with which we are expected to comply, or to establish, exercise or defend or to protect legal claims, to protect our rights, property or safety, or any disclosure pursuant to any of our contractual or other commitment(s) with local, national or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, financial services providers, all of which may be within or outside Macau and may be existing currently and in the future;
any actual or proposed assignee or transferee of our rights or business or any third party whose rights or business is the subject of an actual or proposed assignment or transfer to us;
external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that we engage for the purposes set out in paragraph (1)(iv) of this Vitality PICS ; and
any persons who/which you have given instructions, authorization and consent to us in order to communicate with and provide information to them.

(3) USE AND PROVISION OF PERSONAL DATA IN DIRECT MARKETING

your name, your contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data collected by us from time to time may be used by us for direct marketing;
the following services, products, advice and subjects may be marketed:
1. insurance, annuities, pension schemes, wealth management, credit cards, financial, banking and related services and products;
2. reward, loyalty, lucky draw programs or privileges programs and related services and products;
3. services and products offered by our co-branding partners and/or marketing partners (the names of such co-branding partners and/or marketing partners can be found in the application form(s) and/or promotional material for the relevant services and products, as the case may be);
4. charitable/ non-profitable, educational, recruitment and training causes; and/or
5. medical/health treatment; medicine; educational; recruitment; training; reward/loyalty/privilege programs; travel; airlines, accommodation; apparel; concerts; movies; gymnasium and fitness; sporting and special events; sports and fitness equipment; food and beverage; health supplement; household; media; social networking; spa and similar relaxation activities and other leisure services; telecommunication and mobile services; internet; other retail/consumer products and services; wellness and charitable/non-profitable causes; hospitality services; transportation; electronics; fine art; gallery/exhibition.
  
  (collectively "Classes of Marketing Subjects");
the above Classes of Marketing Subjects may be provided by us and/or the persons/providers below:
1. each of the AIA Vitality Partners;
2. third party reward, loyalty, co-branding or privileges program providers;
3. our co-branding partners and/or marketing partners (the names of such co-branding partners and/or marketing partners can be found in the application form(s) and/or promotional material for the relevant services and products, as the case may be); and/or
4. medical/ healthcare and wellness service providers.
  
  (collectively "Alliance Program Partners");
in addition to our marketing of the Classes of Marketing Subjects, we also intend to provide your personal data described in paragraph 3(i) above to all or any of the Alliance Program Partners for use by them in any of the Classes of Marketing Subjects to contact you and/or send you promotional materials for direct marketing in relation to the Classes of Marketing Subjects that they offer (these materials may be sent to you by postal mail, email or other means). We will obtain your written consent (which includes an indication of no objection) before we pass your personal data to Alliance Program Partners for any direct marketing purposes.

If you do not wish us to use or transfer your personal data we collected to our Alliance Program Partners for direct marketing, you may exercise your opt-out right by notifying us. To exercise your opt-out right, you may write to our Data Protection Officer at the address provided in paragraph (4) of this Statement, or provide us with your opt-out choice in the relevant application form (if applicable).

(4) DATA ACCESS AND CORRECTION RIGHT

In accordance with the Act, you have the right to request access to and the correction of any of your personal data held by us, by writing to our Data Protection Officer at the following address:

The Data Protection Officer

AIA International Limited

1903, AIA Tower
Nos. 251 A - 301
Avenida Comercial de Macau
Macau

According with the Act, we have the right to charge a reasonable fee for the processing of any data access request.

You also have the right to request our policies and practices in relation to personal data and to be informed of your personal data that is held by us by writing to our Data Protection Officer at the address provided in paragraph (4) above.
Nothing in this Vitality PICS shall limit your rights under applicable laws.
We retain the right to change this Vitality PICS.
A Privacy Addendum under the Personal Information Protection Law of the People's Republic of China supplements this Vitality PICS 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.

Last updated: Oct 2024