Privacy

Privacy Policy

Date of Last Revision: 10 October 2022

Berlin Underwriters Limited (“Berlin Underwriters”) provides price comparison services as well as financial services, insurance products, communications and other products and services across Asia.

The Berlin Underwriters website (“Website”), including the content, features, tools, data, software and functions made available by us through the Website, our mobile applications and any other websites or applications we operate (unless those websites or applications have posted separate or additional terms of service) (together, the “Services”) are owned by Berlin Underwriters have been created to provide information to our visitors (“you” and “your”) about our products and services.

This Privacy Policy explains what information and what Personal Data we collect, why we collect it, how we use and disclose it and how we protect Personal Data in compliance with the Personal Data (Privacy) Ordinance. Please be sure to read this entire Privacy Policy before using our Services. When you use, access or interact with our Services, you are agreeing to our Terms and Conditions and consenting to the practices described in this Privacy Policy with respect to the collection, use and disclosure of your information.

In this Privacy Policy, the term “Personal Data” means any data relating directly or indirectly to a living individual which is capable of being used to identify that individual.

Information We Collect

We collect information about you in three main ways: when you provide it to us, with automatic technologies and when third party sources provide it to us.

Information We Collect

While registering for an account and/or using of our Services (for example, in order to get comparative quotes for personal loans), your Personal Data may be collected or provided by you to us in various ways.

The following are examples (without limitation) of the circumstances in which we collect Personal Data:

When you subscribe to receive updates from us, we will ask for your email address;
When you register an account on our Services, we may ask for your proof of identity and address, your name, email address, telephone number and/or mobile number;
When you register an account on our Services and/or log in through third-party social logins (i.e. Google Sign-in or Facebook Login Feature), we may collect your email address and/or basic profile info (profile picture and full name) and any other data that you would have explicitly consented to our collection;
When you request quotes for certain products, we may ask for information like your age and income, so that we can obtain accurate quotes;
When you redeem a reward on our Services, we may ask for your name, email address, the product you applied for, your application reference number and/or your application date;
When you contact us by telephone, we may ask for your name, email address and/or phone number, so that we can contact you regarding your enquiry; and
When you apply for a product or a service using the application forms on our Services, we will collect information which includes but is not limited to contact details, identification information and financial information; and
If you want to add a child or family member to your application for a product or service, we may collect that family member’s name and date of birth, so that we can process the application.

The Personal Data we may ask you to provide includes (without limitation):

name
address
proof of identity
proof of address
email address
telephone number
date of birth
age
gender
nationality
any messages if you write to us using the “contact us” form
your saving goals
your residency status
your income
details of the products you are looking for (for example, the size of loan)
passport number, HK ID or other identity copies and details (where required for purchasing a product)
education history
assets
employment status
employer or company details
details of beneficiaries, such as joint policy holders and minor beneficiaries (where required for purchasing a product)
family members (where required for purchasing a product or availing of a service)
details of your property (when purchasing home insurance)
details of your travel (when purchasing travel insurance)
financial details about you, including details related to the payment method(s) such as credit card and bank account information (when purchasing a product) and
information related to any of the above.

Most often, the provision of the above data is on a voluntary basis. However, if you do not provide sufficient information to us, third party products and service providers may not be able to provide the requested information, products or services to you.

Automatic Collection of Computer Data

In addition, when you use the Services, we may automatically collect certain data about how you access and interact with our Services which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons and similar technologies help us achieve our goal of providing you with the best possible service. When you access our Services, our servers will record, or track information sent from the browsers. This can include the following information (without limitation):

attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
device locations, including specific geographic locations identified through GPS signals or other means;
connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
the website from which you have reached the Services;
the Website pages viewed;
details of the products and services on the Services that you look at, information, tools and content available on our Services that you use;
time spent on the Services;
links from our Services that you click on;
quotes you request from our Services;
your transactions on our Services and details of any payments made by you (including bank account and credit card details and any other account identification information); and
information related to any of the above.

Our use of cookies enables us to:

provide you with a more personalized experience on our Services. It allows us to remember you when you revisit our Services. You can also access your previously saved quotes;
study browsing habits on the Services. The more we understand what products you are interested in, the greater our ability to offer you customized solutions and targeted advertisements and other marketing materials; and
obtain information regarding the number of visitors to the Services and the pages viewed.

In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Services, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process or use any of your Personal Data in this regard.

You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies of the Services, you may not be able to access certain products or services and this could have an effect on the performance of the Services on your system (for example, banner ads may not display properly). If you have registered an account with us, you may be required to re-enter your password more frequently during your use of our Services if you choose to disable cookies.

In some cases, we also use cookies or similar technologies provided by trusted third parties. The Services use a feature of Google Analytics, a widely consumed analytics solution. This setup allows for a more accurate tracking of our users by associating that user with the same ID over various sessions and devices. This approach may combine analytics data with other Personal Data about you that we have collected by our Services. Any such combined data will be treated as Personal Data by us and used in accordance with this Privacy Policy. By registering an account with us and using the Services, you consent to us using session unification in this way.

We may use features in Google Analytics and Google Display Network, including advertising and remarketing, that allow us to target ads to you and report on demographics and interests. These tools use cookies and other information to show ads based on your past actions on our Services. If you would like to opt out of these features please visit https://www.google.com/settings/ads/.

Finally, when you use the Services, we may also receive information about you from other third parties we have engaged such as business associates, subcontractors, analytics providers, platform providers and search information providers or, pursuant to your request, from third party providers of our Partners.

Information from Integrated Services like Facebook or Google

If you decide to register an account with us or log in through or otherwise grant access to a third-party social networking site such as Facebook or Google (“Integrated Services”), we may also collect Personal Data that is already associated with your Integrated Service account. These Integrated Services will authenticate your identity and provide you the option of sharing additional information with us. Should you choose to register or log in to our Services with your Integrated Services account, you are explicitly giving us permission to use, share and store the credentials you provide, your name, email address(es), date of birth, gender, current city, profile picture URL and other information that the Integrated Service makes available to us, in a manner consistent with this Privacy Policy. You should check your Facebook or other Integrated Services privacy settings to understand and change the information sent to us through Facebook Connect or other Integrated Services. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Services in this way.

Accuracy and Retention of Personal Data

By providing us with your Personal Data or that of a family member, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility. When you give us Personal Data about another person (or persons) such as a family member, you should have the authority to act on such person’s behalf (whether by appointment or by law in your capacity as legal guardian). This includes providing consent to our processing of their Personal Data. If for any reason you are concerned as to whether you are permitted to provide us with another person’s information, please contact us at the email address listed below before sending us anything.

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 permissible by applicable law(s).

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for (further detailed in the “What do we use your Information for?” section below), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

You have the right to request access to and correction of your Personal Data as held by us. Please contact us at any time if you wish to correct, amend or update your Personal Data. We aim to acknowledge and act upon your request promptly. To help us respond in the most timely and appropriate way, please be as specific as possible in your request or inquiry.

What do we use your Information for?

We use the information we collect about you for our legitimate business interests to operate the Services, to enhance and customize users’ experiences with the Services and to improve and grow our business. Depending on the nature of your relationship with us, we may use your Personal Data for some or all of the following purposes:

to set up and administer your account with Berlin Underwriters;
to protect the security of your account by sending a verification code to your phone when you log in from a new device;
to answer your queries and to communicate with you, for example, providing you with alerts, notifications and recommendations;
to allow you to access and use our free comparison services and to provide quotes to you;
to enable you to access online application forms on third party external sites;
to process applications for Partner Products on your behalf (see below section “Partner Products” for further information);
to analyze customer behavior, market trends and client demographics so that we can improve our services and to enable us to provide a more personalized service and more relevant communications to you;
where you have registered an account with us, to enable us to save your Personal Data so that you do not have to re-enter it each time you request a quote or apply for a product;
to enable us to store data and manage our business operations efficiently;
where you have signed up to receive electronic communications from us, to send you marketing and/or promotional materials on our latest products and services or those of carefully selected third parties;
where you have registered an account with us, to send you service-related messages including, without limitation, a welcome/confirmation email when you register your account and to enforce our Terms and Conditions and other policies. You may not opt-out of receiving service-related messages from us, unless you deactivate your account;
where you have registered an account with us, to send you personalized special reports, exclusive member offers and latest feature announcements in relation to your account. You may not opt-out of receiving membership-related messages from us, unless you deactivate your account;
to diagnose and prevent service, security or technical issues affecting the Services;
to monitor, detect and prevent fraud or abuse of the Services;
to protect the safety, integrity and/or rights of our users or any third party;
to comply with our legal and regulatory obligations; and
to enable us to provide services and products related to the above and/or otherwise related to your use of the Services.

In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Partner Products

We save you time by allowing you to apply on our Services for products and services provided by third parties (“Partner Products”). If you apply for a Partner Product via our Services, your Personal Data will be transferred to the provider and your application will be processed by that provider. That provider may contact you directly about your application. Your Personal Data will be used, processed and stored in accordance with that provider’s privacy policy, which is outside Berlin Underwriters’s control.

How do we Disclose your Information?

We are committed to keeping your Personal Data and other information shared with us confidential. There are, however, certain circumstances in which we may disclose or transfer your Personal Data to certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of, or in preparation for, a change of control, merger, acquisition, restructuring, dissolution or similar event, we may disclose or transfer Personal Data to a third party.
Partners: We may be required to share information with our partners who are banks, brokers, lenders, insurance companies and other money and financial service providers whose products may be displayed on our Services from time to time (“Partners“) or when you have requested the products and/or services our Partners, which requires us to provide your Personal Data to them in a pre-populated form or by API. In order for you to redeem a reward on our Services, we may also need to share those details with the relevant Partner in order to authenticate your reward redemption.
Agents, Consultants and Related Third Parties: We rely on service providers to help support our business, for example (without limitation) our third party payment service providers, IT and analytics service providers, back office support, business consultants, legal service providers and marketing service providers. When we engage another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: We and/or any of the third parties listed above may also be required to disclose your Personal Data to any court, law enforcement body, government department, regulator or industry body of any country where required by the laws of Hong Kong or any other jurisdiction, or in response to a lawful request in Hong Kong or elsewhere. We may also need to disclose your Personal Data in order to identify, contact or bring legal action against any person who may be causing damage to or interfere with our and/or any third party’s rights or property (whether intentionally or otherwise) and/or (ii) to help with anti-money laundering and counter-terrorist financing requirements of our Partners or other third parties.

In connection with the purposes set out in this Privacy Policy, your Personal Data may be transferred outside Hong Kong. That means your Personal Data may not be protected to the same or similar level as it would in Hong Kong. However, we will take all reasonable measures to ensure that your data is processed and stored securely, regardless of the country in which it is processed or stored.

By using our Services, you consent to the use and disclosure of your Personal Data as set out above.

Keeping you Updated Regarding our Services & Direct Marketing

After you use our services, and provided you have subscribed to receive our communications, we may use your Personal Data (including your name, address, email address and telephone number) to contact you about news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time.

We may use other data collected about you, including but not limited to your age, location, income bracket, employment, browsing history, purchases and quotes requested in order to provide materials that are customized and relevant to you. You may opt-out of receiving our newsletter and other direct marketing communications at any time by clicking on the unsubscribe link contained in our email to you.

These communications are separate to those you will receive as a result of registering an account with us. In addition to account-related communications, our logged in users will receive exclusive and/or advance access to personalized content available and distributed only to them, which may be sent by email. As a logged in user you may not opt-out of receiving membership-related messages from us, unless you deactivate your account.

With your explicit consent, we may also provide your Personal Data (including your name, address, email address and telephone number) to our Partners so that they may contact you with news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time.

We may also share aggregated data, provided your identity will not be disclosed by such sharing, with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services, but please note that, unless permitted or required by law or as otherwise set out in this Privacy Policy, we will not disclose your Personal Data to any third parties without your prior consent.

If you have any questions or concerns about the communications you are receiving from us, you canget in touch with us at any time, free of charge (see “Your Rights” below).

Third-Party Providers

If you opt to enter into a contract with a third party through our Services, the data you provide to the third party will be transferred to that third party and controlled by the third party in accordance with that third-party provider’s privacy policy. Therefore, you should contact them directly for additional information in relation to their privacy policies and read all policies, terms and conditions before entering a contract. We are not responsible for how third-party providers use your Personal Data.

Data Security

We are fully committed to safeguarding the privacy of our customers, online and otherwise, and the success of our business depends on our ability to maintain the trust of our clients and customers. We apply Defense in Depth approach in securing Personal Data entrusted to us by our customers and continuously improve those measures to address security risks. We use Amazon Web Services, Inc (“AWS”) as our technology infrastructure service provider to power the main core of our Services. Data we collect is stored in data centers operated by AWS which offer best-in-class security. For more information, please visit: https://aws.amazon.com/security/.

When you register for an account with us, you will be asked to choose a password. It is your responsibility to keep your password safe, and not share it with anyone. We are not responsible for any transactions conducted by a third party that has logged in to your account using your password. If you suspect that your account has been used by someone other than you, please notify us straight away.

Despite our security precautions, we cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.

Consent

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

Use of the Services by Minors

The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not access or use our Services.

Improving our Service

In order to ensure that the services we offer you continue to meet your requirements; we might ask for your feedback. Any feedback or other information you submit to us will, unless otherwise stated, be used in accordance with this Privacy Policy and our Terms and Conditions.

Your Rights

You have the right to check whether we hold Personal Data about you and to require access or correction of your Personal Data. You can also unsubscribe from receiving our newsletter and other promotional communications from us at any time by clicking on the unsubscribe link in our email to you. You are also entitled to opt out of receiving direct marketing or promotional

communications from us, our affiliates and any of our Partners.

If you wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data, please kindly address your enquiries to us.

Deleting Your Account

If you wish to delete your account or request that we no longer use your information to provide you with our services, please visit the ‘Settings’ section of the Services to delete your account. If you register or log in to your account through Integrated Services, you can also choose to disable the connection between the Services and the Integrated Services at any time. When deleting your account information (including any identifiable information regarding your family member that you have provided or has been collected), we may retain general demographical information about you such as your general transaction history and will remove any personally identifiable information associated with this data so that it can no longer be associated with you for research or statistical purposes.

Changes to this Privacy Policy

We may need to revise or update this Privacy Policy from time to time in order to reflect changes in our Services, our business or applicable law. We reserve the right to modify this Privacy Policy periodically without prior notice. Your continued access or use of the Services after any changes or revisions to this Privacy Policy will be deemed to constitute your agreement with the terms of such revised Privacy Policy. We will always include a ‘last revised’ date as part of our privacy policy. You may check this page periodically to stay informed of our Privacy Policy.

This Privacy Policy has been prepared in both English and Chinese. In the event of discrepancies between the English and Chinese version, the English version shall apply and prevail.

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