私隱政策（只提供英文版本）

Chubb Investment Management (HK) Limited 安達資產管理(香港)有限公司 is a licensed corporation under the Securities and Futures Commission in the Hong Kong Special Administrative Region (referred to as “CIM”, “Company”, “we”, “our”, “us”).

Please read this Privacy Policy carefully before using this Portal (as defined below). By using this Portal, you consent to how we collect, use, hold, store, transfer and disclose your personal data as set out in this Privacy Policy. CIM may revise this Privacy Policy and/or introduce additional terms and conditions from time to time by updating this Privacy Policy and its Personal Information Collection Statement (“PICS”).  Please read this Privacy Policy and any applicable PICS provided to you every time you visit this Portal for your understanding of the most current terms and conditions to which you are bound.

Privacy Policy

CIM is committed to safeguarding your personal data and implementing and complying with the data protection principles under the requirements of the Personal Data (Privacy) Ordinance (Chapter 486), Laws of the Hong Kong Special Administrative Region, and other applicable laws. This Privacy Policy applies to all products and services provided by CIM and sets out how CIM may collect, use, hold, store, transfer and disclose your personal data.

CIM collects personal data in a number of ways including but not limited to when you (i) access the Portal, Mobile App and Platform owned by CIM (the “Portal“), (ii) request services or products, (iii) contact us in person, phone, mail, e-mail or online, (iv) participate in our programs, or (v) access our Portal and/or receive services from us. When you visit this Portal, CIM will not collect any of your personal data until you submit a completed on-line form to us, register as a member, file information for job application purposes, log into the on-line service(s), and/or submit personal data whilst using the on-line service(s).

Types of Personal Data Held

The types of personal data CIM collects from you will depend on the circumstances. Generally, CIM may directly or indirectly collect personal data from you and/or your dependents, the beneficiaries, your authorized representatives and any other individuals whom you have provided personal data of (“relevant persons”), which personal data may include without limitation:-

1. personal contact data including name, telephone number, email address, residential address and correspondence address;

2. specimen signature(s);

3. occupation, education, employment status and income levels, including whether you have any professional qualifications relating to finance;

4. identification card or passport number, nationality, date of birth, place of birth and other information for the verification of identity

5. financial and banking information (e.g. information on source and amount of regular income, your financial situation, net assets, income, expenses, cash flow, financial commitments, credit history, bank account and banking transactions);

6. images, voice recordings of our conversations with you and/or your biometric information;

7. tax and relevant information;

8. information about your financial or investment objectives, risk profile and risk tolerance, investments, investment objectives, knowledge and experience and/or business interests and assets, including current investment portfolio, including any life policies, your current securities trading account, whether the amount to be invested with is a substantial portion of your assets and prior investment experience in relation to specific investment products;

9. personal opinions made known to us (e.g. your feedback or responses to any surveys);

10. browsing history, patterns or other unique information;

11. your internet protocol address and information associated with such address;

12. any other personal data reasonably required in order for us to provide the Services requested by you; and

13. any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Hong Kong or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.

Some of the personal data we collect may be considered sensitive personal data under applicable laws. This may include your transaction records, identity document number, marital status, medical/health records, biometric data, religion, specific social status, tracking/location information, credit information, financial details, bank account information, tax information and if applicable, data of minors under the legal age of your country of residence. You understand that the processing of this sensitive personal data is necessary for us to evaluate your eligibility for our financial services and products and for the purposes as set forth in “Main Purposes of the Collection of Personal Data”. We will take necessary security measures to protect your personal data to avoid any material harm to your legitimate rights and interests associated with your sensitive personal data.

When you provide personal data of the relevant persons to CIM, you confirm you have obtained that relevant persons’ consent and have the authority to provide such personal data for use and transfer by CIM for the purposes set out in this Privacy Policy.

Main Purposes of Collection of Personal Data

The purposes for which your or relevant persons’ personal data will be used will depend on the circumstances under which that personal data is collected. CIM will inform you of the purposes for which we intend to use your or your relevant persons’ personal data in our PICS at or before the time of such collection.

Your or your relevant persons’ personal data held or stored by us may be used for the following purposes:

1. evaluating or processing any financial investment application;

2. administering and processing your application and payment instructions;

3. assessing and processing payments;

4. providing financial investment products and related services;

5. with your consent and where permissible by applicable laws, to promote and directly market to you: (a) the financial investment products and services of CIM; (b) fund-related products/services sponsored by the third party providers connected with us; (c) financial or investment related products/services, rewards, loyalty, co-branding and/or other privileges programs offered by us, our affiliates, our co-branding partners, our business partners (please refer to “Use of personal data for direct marketing purposes” section below);

6. performing data matching and communicating with you and/or your relevant persons for such purposes;

7.  cooperating with law enforcement bodies for law enforcement purposes, to prevent any serious threat to public safety; for police investigation purposes; or to comply with laws, rules, regulations, codes of practice, guidelines or requirements imposed by or agreed with government or regulatory bodies or for litigation;

8. applying registration of activities organized and/or sponsored by CIM;

9. enabling industry associations, federations, government or regulatory bodies to carry out their functions and requirements that may be assigned to them from time to time as are reasonably required and in the interests of the financial or investment industry;

10. conducting research, surveys, data analytics and statistics, administration, communications, computer, security and other services (including financial services, mailing and IT services); in connection with the usual operations of the Company as a financial or investment company; and

11. for any other purpose directly relating to any of the above or as notified at the time of collection.

It may be necessary and required for you to provide certain categories of personal data to us and we will specify such categories to you at the time of collection. If you do not provide such specified personal data as required, CIM may not be able to issue grant you access to the Portal, process your requests, applications and/or provide you with our products and/or services.

Classes of transferees and international transfers

Generally, your and your relevant persons’ personal data held by us will be kept confidential, but may be transferred to any of the following parties (whether within or outside the Hong Kong Special Administrative Region) where such disclosure is necessary to satisfy the purposes set out above:

1.  any branch, subsidiary, holding company, associated company or affiliates of CIM (“Group Companies”);

2. any advisor(s), intermediaries, in connection with the distribution of our products and services, placement or handling of your financial or investment policy and any other services;

3. any advisor(s), contractors, advisors or third party service providers providing accounting, finance, legal, payment, data processing and storage, administration, telecommunications, mailing, printing, computer, technology, security, analytics, research, funds management, regulatory screenings, customer services, call centre services, and/or other services in connection with our operations;

4. medical advisors; 

5. credit reference agencies;

6. debt collection agencies;

7. law enforcing bodies and police;

8. financial industry associations and federations;

9. organizations that consolidate financial information for the investment industry, fraud prevention/detection agencies, and databases or registers (and their operators) used by the financial industry to analyze and check information provided against existing information;

10. government or judicial or competent regulatory bodies or any person to whom CIM is under legal and/or regulatory obligations to make disclosure; and

11. other parties as notified to you at the time of collection.

For Mainland China residents, you understand that your personal data will be stored and processed in Hong Kong and other countries/regions outside the country/region where you are located, for the purposes listed in this Privacy Policy. We will take necessary steps to comply with applicable legal requirements in this respect.

We may also purchase or sell one or more business(es) (or portions thereof), and where permissible by applicable laws, your or your relevant persons’ personal data may be transferred as a part of such purchase or sale, or proposed purchase or sale.

Use of personal data for direct marketing purposes

In respect of use of your personal data for direct marketing purposes, under applicable law, CIM may, with your prescribed consent:

1. use your name, contact details and other details provided by you (“Relevant Data”) for direct marketing of the following classes of products and services that CIM, our Group Companies, our co-branding partners and/or our business partners may offer:

(i) financial or investment related products/services;

(ii) rewards, loyalty, co-branding and/or other privileges programs related to health, wellness, medical, entertainment, media, social networking, recruitment, education, training, sport activities, travel, transportation, hospitality, household, food and beverages, telecommunications, charitable and non-profit making purposes.

2. provide your Relevant Data to any advisor(s), contractors, or intermediaries, for the purpose of carrying out direct marketing of the above classes of products or services on behalf of CIM;

3. provide your Relevant Data to third party providers connected with us for their direct marketing of their mandatory provident fund-related products and services; and

4. for gain, provide your Relevant Data to any third party providers or companies (within or outside our Group Companies) for their direct marketing of any of the classes of products or services as described in paragraph 1 above.

CIM may only use your Relevant Data or disclose the same to the above specified transferees and any other third parties for direct marketing purposes with your prescribed consent. CIM will inform you of the details of any such proposed use in the PICS at or before the time of such collection. You will be provided with an opportunity to opt-out of direct marketing at that time. If you do not opt-out of direct marketing at that time, but you later decide that you no longer wish to receive direct marketing, you may ask us to cease any further direct marketing by writing to: The Data Protection Officer of Chubb Investment Management (HK) Limited, Room 4801 Central Plaza, 18 Harbour Road, Wanchai, Hong Kong.

Use of Artificial Intelligence

We or our third-party service providers may use artificial intelligence (AI) to assist us in providing products or services to you. This may involve the use of your Personal Data.

We may also use AI to help improve our business and provide a better service, for example to assist in application processing, transaction activity, financial assessment or service handling in general, data analytics, as well as to enhance performance and user experience on our Portal. We use various types of AI, which vary based on your relationship with us and the relevant product or service offered. Where appropriate, additional information will be provided to help you understand where AI is being used and how any decisions based on AI are made.

Linked Portal(s)

This Portal may contain links to third party websites. You may be linked from this Portal to sites provided by the third-party organizations and should be aware that the information on those sites has been compiled and issued by those organizations. CIM has no control over the content of such third-party websites or the way that the operators of those websites deal with your personal data. You should review the privacy policies applicable to those third-party websites to understand the ways in which those third parties may deal with your personal data. CIM accepts no responsibility for the content of those websites and shall not be liable for any loss or damage arising from or related to their uses.

Information collected when you visit our Portal

When you access this Portal, anonymous technical information may be collected about your activities on the Portal (e.g. your IP address, the date and time that you accessed the Portal, information relating to your browser and operating system, the pages visited etc.). CIM may use "cookies" (pieces of information relating to your preferences sent by the Portal to your browser and stored on your computer hard drive). Cookies enable the Portal to remember you and your preferences when you visit the Portal and enable us to tailor the Portal to your needs. Our cookies will track only your activity relating to your online activity on our Portal and will not track your other internet activity. Our cookies do not identify you personally and do not gather any of your personal data. However, if you do not want to receive cookies you can disable this function by changing your browser settings.

Protection measures

CIM will take all practical steps to implement appropriate organizational and technical safety measures to safeguard your personal data held by us against unauthorized or unlawful use, accidental access, alteration, disclosure, processing, erasure, loss or use, or other use not stipulated herein. CIM provides a highly secure online infrastructure for activities conducted via our Portal, including SSL (secure socket layer) encryption, IDS (intrusion detection system) and the use of firewalls and anti-virus software. CIM also adopts stringent security procedures with the use of your user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy. Our online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms.

Retention of personal data

CIM will also take all reasonable steps to ensure that the personal data you provide to us are properly stored. CIM will keep your personal data as long as necessary to achieve the purpose for which it was collected unless a longer retention period is necessary to perform any legal obligations or is permitted by applicable law. and to comply with legal and regulatory requirements. If CIM no longer needs your personal data for any purpose, it will take reasonable steps to securely delete or destroy your personal data.

CIM will also comply with other applicable laws, including any Do Not Call and Do Not Spam legislation, in relation to conducting business via the internet, email marketing, telemarketing, direct mail marketing and legislation regarding identifying numbers. You warrant that all personal data and other relevant information provided by you are true, complete and up-to-date and that you agree to notify CIM of all changes to the information previously provided.

Data access and correction rights; other rights

CIM will take all practicable steps to ensure that the personal data kept about you is accurate. If you have any questions or requests regarding your personal data held by us, including requests for access to and/or for correction of any your personal data held by us, please make the request in writing to:

• For all customers (except for Mainland China residents): The Data Protection Officer of Chubb Investment Management (HK) Limited, Room 4801 Central Plaza, 18 Harbour Road, Wanchai, Hong Kong or privacy.hk@chubbinvestment.com.
• For Mainland China residents: The Data Protection Officer of Chubb Investment Management (HK) Limited at privacy.hk@chubbinvestment.com.

Any request for access to and correction of information will be dealt with promptly and CIM will use its best endeavors to handle such requests before the expiry of 30 days after receipt of your written request. A reasonable charge may be imposed for processing your access request, where permitted by applicable laws; however no charge will be imposed for a correction request.

You may have additional rights as regards your personal data under other applicable laws (including the right to copy or supplement your personal data, withdraw consent to use of your personal data where consent is the lawful basis relied upon for its processing, and/or delete your personal data where permitted by applicable laws).

Enquiries

If you have any queries about our Privacy Policy and practices, please e-mail them to privacy.hk@chubbinvestment.com.

Inconsistency

In the event of any ambiguity or inconsistency between the English and Chinese versions of this Privacy Policy or any PICS, the English version will prevail.

Release Date: December 2025

Personal Information Collection Statement

Chubb Investment Management (HK) Limited 安達資產管理(香港)有限公司 (collectively “we”, “us” or “our”) is a licensed corporation under the Securities and Futures Commission in the Hong Kong Special Administrative Region.

We are committed to protecting Your privacy. We collect, use and retain Your Personal data in accordance with the Data Protection Principles set out in the Hong Kong Personal Data (Privacy) Ordinance. Our detailed privacy policies are available on our Portal at www.chubbwealth.com.

We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):

1. provision of the Services as requested by you, including instructing any Intermediaries and/or third party services providers in order to provide the Services to you;

2. carrying out any transactions on your behalf contemplated on the Platform and the Services thereto;

3. assessing and processing applications, instructions or requests from you;

4. communicating with you, including providing you with updates on changes to our Services;

5. to verify your identity for the purposes of providing the Services to you;

6. conducting due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;

7. for the specific purpose for which it was volunteered or provided to us;

8. to detect and protect us or any third parties against negligence, fraud, theft and other illegal activities;

9. to understand your needs and preferences;

10. improving the content, appearance and utility of the Platform;

11. to manage and develop infrastructure and business operations;

12. to administer any account which you may open with us;

13. to process payments;

14. to comply with our internal policies and procedures;

15. to respond to queries or feedback;

16. to address or investigate any complaints or disputes;

17. as permitted by any Applicable Laws;

18. to comply with any Applicable Laws or any request from any relevant governmental or regulatory authority;

19. financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;

20. enforcing obligations owed to us;

21. seeking professional advice, including legal advice;

22. any other reasonable purposes in connection with the provision of our Product or Services;

23. with your consent, providing you with marketing materials in connection with the Services we may provide;

24. fulfilling any purpose directly related to the above Purposes;

25. to enable any actual or proposed assignee or participant or sub-participant or transferee to evaluate an assignment, participation or sub-participation or transfer of our rights in respect of you or all or any part of our assets or business; and to assign or sub-contract, procure products/services for, or outsource any part of our normal business functions to third parties;

26. any other purposes that are appropriate or authorized by any Applicable Laws; or

27. any other purposes that are specified in the data service agreement between us and service provider.

With Your consent, we may also use Your name, contact, demographic and payment details to contact You with marketing information regarding our products and service by mail, email, phone or SMS. We will inform You of that at or before the time of such collection. You will be provided with an opportunity to opt-out of that direct marketing at that time. If You do not opt-out of direct marketing at that time, but You later decide that You no longer wish to receive direct marketing, You may ask us to cease any further direct marketing.

We may use, store, disclose and/or transfer Your Personal data to third parties for or in connection with those purposes, including to service providers engaged by us to deliver our services or carry out certain business activities on our behalf (such as banks and call centres), other companies in the Chubb group, intermediaries, other insurers, our reinsurers, and any financial industry association/federation and its members of the association/federation, law enforcing bodies, competent regulatory authorities, any individuals/organizations associated with us (whether within or outside the Hong Kong) for the purposes as specified above and regulatory and law enforcement agencies (where required by law). Those third parties may be located outside Hong Kong. If we transfer all or a substantial part of our business we may also disclose and transfer Your Personal Data to the transferee of that business who may then use Your Personal Data to carry out that business as our successor.

If applicable, We or our third-party service providers may use artificial intelligence (AI) to assist us in providing products or services to You. This may involve the use of Your Personal Data. We may also use AI to help improve our business and provide a better service as well as to enhance performance and user experience on our Portal and applications. We may use various types of AI, which vary based on Your relationship with us and the relevant product or service offered. Where appropriate, additional information will be provided to help You understand where AI is being used and how any decisions based on AI are made.

If You do not provide us with this Personal Data, we may not be able to provide You or Your organisation with a product or service or respond to a request or we may be delayed in doing so.

You consent to us using and disclosing Your Personal Data as set out above.

When collecting Personal Data on-line, we do so in a secure and confidential manner by utilizing Secure Socket Layers Protocol which will encrypt Your Personal Data to ensure secure transmission of the same to our web site server.

You have the right to access a copy of and/or correct Your Personal Data, subject to certain exemptions. If You would like to access or correct Your Personal Data, please make Your request in writing to us at privacy.hk@chubbinvestment.com.

In the event of any ambiguity or inconsistency between the English and Chinese versions of this Personal Information Collection Statement, the English version will prevail.

Please note: Your Personal Data may be collected and used for other purposes, as notified to You at or before the time of collection. Please refer to the relevant Privacy Policy and Personal Information Collection Statement of Chubb Investment Management (HK) Limited for further details.