Privacy Policy Statement

Tahoe Life Insurance Company Limited and Tahoe Club VIP Programme (collectively “the Company and Tahoe Club”) are committed to ensuring the privacy and security of the Personal Data it holds. This Privacy Policy Statement is intended to explain the Company and Tahoe Club's privacy practices.

Collection of Personal Data

From time to time and for the purpose of carrying on the Company and Tahoe Club's businesses and operations, including the provision of services and facilities to you, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data") such as, but not limited to, the following:

1. Your name;
2. Contact details such as WeChat account, email address, mailing and residential address, telephone number, and fax number;
3. Membership number;
4. Information for verification of identity, including identification type and identification number and other related information;
5. Demographic information such as age, gender, birthday, nationality and marital status.

Supply of Personal Data to the Company and Tahoe Club is non-obligatory, but failure to do so may result in the Company and Tahoe Club being unable to process your application(s) or to provide facilities and services to you.

Occasionally, you may need to provide Personal Data about other individuals to the Company and Tahoe Club (e.g. spouse or children or guests). In that event, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to the Company and Tahoe Club's possible use, disclosure and transfer of their Personal Data, for the purposes you would want to achieve from the Company and Tahoe Club. If necessary, the Company and Tahoe Club may require you to provide to the Company and Tahoe Club any supporting documents which may be necessary to prove such authorisation. You should also advise them that the Company and Tahoe Club can be contacted for further information.

Use of Personal Data

Your Personal Data may be used for the following purposes:

1. Providing facilities, goods, services and support or performing transactions and administration work related to the following operations of the Company and Tahoe Club:
   1. the Tahoe Club's core operations of membership; and/or
   2. insurance product(s) and its preferential discount, catering, hospitality, conferences and entertainment;
2. Processing of your application to subscribe to the Company and Tahoe Club's products, services and facilities as set out in paragraph 1;
3. Conducting assessments and checks regarding eligibility for membership, facilities or services;
4. Verifying your identity;
5. Monitoring access to the Tahoe Club's premises;
6. Matching your Personal Data with other data collected (by the Company and Tahoe Club or third parties) for other purposes, in relation to, the provision of facilities, products, goods and services to you and/or the performance of any transactions and administration work related to the Company and Tahoe Club's operations;
7. Marketing and advertising of any facilities, products, goods and services to you by the Company and Tahoe Club (as defined below), such as sending you offers and promotions (please see further details in "Direct Marketing" below);
8. Maintaining and developing the Company and Tahoe Club's business systems and infrastructure, including testing and upgrading of these systems;
9. Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, of the Company and Tahoe Club to comply with, or in connection with: 
   1. any guidelines, guidance, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside the HKSAR; or 
   2. any of the Company and Tahoe Club's rules or bye-laws relating to the Company and Tahoe Club's core operations.
10. Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Company and Tahoe Club and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
11. Prevention, detection or investigation of crime; and/or
12. Facilitating communications between you and the Company and Tahoe Club.

The Company and Tahoe Club may also use from time to time aggregate non-identifying information about its customers to better design and improve the Club's facilities, goods and services that it offers. This information will not identify any individual in particular.

Direct Marketing

The Company and Tahoe Club intends to use your Personal Data for direct marketing carried out by the Company and Tahoe Club, your Personal Data held by the Company and Tahoe Club may be provided to the Company and Tahoe Club for their use for direct marketing. The intended kinds of Personal Data to be used and the intended classes of marketing subjects are specified below. However, the Company and Tahoe Club may not so use or provide your Personal Data unless exempted or permitted by applicable laws or regulations or the Company and Tahoe Club has received your consent.

For the above direct marketing use, the Club intends to:

1. use your name, contact details and demographic information; and
2. market or promote the following classes of products, facilities, goods, services, support and related events and activities offered or arranged by the Club or a Club Entity or their respective business partners:
   1. membership;
   2. insurance products, catering, hospitality, conferences and entertainment;

You can always opt-out free-of-charge by contacting the Company and Tahoe Club's Data Protection Officer if you no longer wish any of your Personal Data to be used in any of the described direct marketing purposes.

Disclosure of Personal Data

Personal Data supplied to the Company and Tahoe Club will be kept confidential. However, the Company and Tahoe Club may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:

1. the Company and Tahoe Club for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to the Company and Tahoe Club's business partners for direct marketing use as described in "Direct Marketing" above;
2. any person or company who is acting for or on behalf of the Company and Tahoe Club, or jointly with the Company and Tahoe Club, in respect of the purpose or a directly related purpose for which the data was provided;
3. any other person or company who is under a duty of confidentiality to the Company and Tahoe Club and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
4. the Company and Tahoe Club's agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to the Company and Tahoe Club in connection with the operations of its business;
5. government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law.

The Company and Tahoe Club may also disclose your Personal Data to third parties: (i) when required by law, by court order or in response to a search warrant or other legally valid inquiry; or (ii) pursuant to the Club's good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend the Company and Tahoe Club's legal rights or to protect the life, body or property of any individual. This also applies when the Company and Tahoe Club has reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with the Company and Tahoe Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference. The Personal Data that the Company and Tahoe Club collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. By submitting Personal Data to the Company and Tahoe Club or using any of the Company and Tahoe Club's services and facilities, you understand and consent to such transfer.

Links to Third Party Websites

The Company and Tahoe Club's website may contain links to other sites and pages which are operated by third parties. The Company and Tahoe Club has no control over the content of the linked websites or the way in which the operators of those websites deal with your Personal Data. You should review the privacy policy for those third party websites to understand the ways in which your Personal Data may be used by those third parties.

Data Retention

All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.

Commitment to Data Security

The Company and Tahoe Club is committed to protecting the security of your Personal Data. It uses a variety of physical, technological and organisational measures to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.

Changes to the Privacy Policy Statement

The Company and Tahoe Club will post on its website at https://www.tahoelife.com.hk/tl/en/tahoeclub/ any changes to its Privacy Policy Statement, so that you will always know what information the Company and Tahoe Club gathers, how it might use that information and whether it discloses such information to anyone.

Access to and Correction of Personal Data

You are entitled to request access to Personal Data held by the Company and Tahoe Club about you and to correct such data. The Company and Tahoe Club may charge a reasonable fee for the processing of such data access request.

You may direct your request in writing to:

Data Protection Officer, Tahoe Life Insurance Company Limited.，15/F, Cityplaza One, 1111 King’s Road, Taikoo Shing, Hong Kong

Telephone: 3767 8777.    

This notice is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.