Aon Privacy Statement
Aon Hong Kong Limited (“Aon”, “we”, “us”, “our”) respects personal data privacy and is committed to fully implementing and complying with the requirements under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.
This Privacy Statement ("Statement") explains our information processing practices. It applies to any personal data you provide to Aon and, subject to local law, any personal information we collect from other sources.
What type of information does Aon collect?
We collect personal data to offer and administer our services and products. These include insurance broking, claims management, risk management consulting, other forms of insurance services (including underwriting of insurance products and reinsurance), employee benefits program administration and investment advisory services.
We may collect data such as your name, contact details, date of birth, gender, marital status, financial details, employment details and benefit coverage. We may also collect sensitive data about you such as criminal convictions or health data in relation to life, health, professional liability and workers compensation insurance or employee benefit programs.
When you request services, we ask that you provide accurate and necessary data that enables us to respond to your request. In doing so, you consent to our collection, use, storage and disclosure of this data to appropriate third parties for the purposes described in this Statement.
While the personal data we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, insurance companies, insurance brokers or agents, credit organizations, motor vehicle and driver licensing authorities, financial institutions, medical professionals, etc.). If you provide personal data about other individuals (such as employees, dependents, etc.), you must obtain their consent prior to your disclosure to Aon.
Aon may collect information online when you:
Visit Aon Websites
For purposes of this Privacy Statement, "website" includes our mobile applications.
By using Aon websites and associated microsites, you agree to the processing of your personal data as explained in this Privacy Statement, including placing cookies on your device as described in the Cookie Notice.
We collect personal data to fulfill your requests for products and services and to improve your online experience. We strive to limit the amount of personal data collected to support the intended purpose of the collection.
We may ask you for some or all of the following types of data when you register for events, request services, manage accounts, access various content and features or directly visit our websites. This includes, but is not limited to:
- contact information, such as name, e-mail address, postal address, phone number and mobile number;
- user name, password, password reminder questions and password answers;
- communication preferences, such as which newsletters you would like to receive;
- search queries;
- contact information about others when you refer a friend to a particular site or service (note: this information is used solely to facilitate requested communications); and
- information posted in community discussions and other interactive online features.
In some instances, Aon automatically collects certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. The collection of this information will allow us to improve the effectiveness of Aon websites and our marketing activities.
In addition, on some occasions, Aon may use tracking technologies such as web beacons, to collect information about your visits to Aon websites. These are small electronic images embedded in web content or e-mail messages and are ordinarily not visible to users. Like cookies, this tracking technology enables us to track pages and content accessed and viewed by users on Aon websites. The use of these technologies also helps us to provide you with a positive experience when you browse our websites, and it also helps refine our content and personalize your experience. For more detailed information, you may wish to visit our Cookie Notice.
For more detailed information about cookies, you may wish to visit www.allaboutcookies.org.
Links to Other websites: Aon websites may contain links to other sites which are outside our control and are not covered by this Privacy Statement. If you access other sites using the links provided, the operators of these sites may collect data from you which will be used by them in accordance with their privacy statement. We encourage you to read the privacy statements on other websites you visit. Aon is not responsible for the content or privacy practices of linked sites or any use of those sites.
Please be aware that Aon websites may contain links to sites maintained by other Aon entities that are not governed by this Statement but by other privacy statements that may differ slightly from this Statement. We encourage you to review the privacy statement of each website you visit.
Engage with Aon through Social Media
You can engage with us through social media websites or through features such as plug-ins or applications on Aon websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).
Access our Websites through Mobile Devices
If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information.
When you provide us your mobile device phone number as your contact phone number, you consent to the use of your mobile device phone number for the purposes identified in this Privacy Statement. If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose.
How does Aon use your personal data?
The purposes for which we collect your personal data, which may be used, stored, held, processed, transferred, disclosed or shared by Aon, are as follows:
- provide information and services as requested by you;
- determine eligibility and process applications for products and services;
- provide information and services as requested by clients;
- understand and assess clients' ongoing needs and offer products and services to meet those needs;
- carry out client communication, service, billing and administration;
- administer claims;
- conduct data analysis;
- obtain and update credit information with appropriate third parties, such as credit reporting agencies, where transactions are made on credit;
- execute monitoring and training;
- develop new services;
- market products and services (subject to appropriate consent); and
- conduct processing necessary to fulfill other contractual obligations for the individual.
With your consent, we may also use your personal information for additional purposes. It is up to you whether you provide your personal data to us. However, if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or to process your request.
Use and provision of personal data in direct marketing
From time to time, your personal data provided to us including name, contact details and demographic data, may be used, provided, disclosed and transferred by us to our affiliated businesses and third party service providers acting on Aon’s behalf including but not limited to mailing house, telemarketing and direct sales agents and call centres (within or outside Hong Kong) for the purpose of direct marketing in relation to insurance and financial products and services via different communication channels including fax, direct mail, email, SMS and telemarketing. We would not use your personal data for any direct marketing activities unless we have received your consent.
You may withdraw your consent to the use and provision of your personal data for direct marketing by contacting us using the contact information provided below.
Does Aon disclose your personal data?
We disclose personal data to business partners that are necessary to provide our products and services, which may be located either within or outside of Hong Kong. Examples include:
- banking and finance products - credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers, and managed fund organizations for financial planning, investment products and trustee or custodial services in which you invest
- insurance broking and insurance products - insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants and others involved in the claims handling process
- human capital consulting, business process outsourcing, benefits administration services - background checking agencies, fraud detection agencies, payroll service providers, insurers, medical service providers, trustees, administrators or managers of any employee benefit schemes or any relevant financial institutions
- our related companies and affiliates who in the provision of our products and services may wish to tell you about their services, products or promotional opportunities which may be of advantage to you, unless you tell us not to, and your representatives such as your lawyers, accountants, financial advisers etc.
We do not rent, sell or otherwise disclose personal data about our online visitors with unaffiliated third parties for their own marketing use.
Authorized Service Providers
We may disclose your data to service providers we have retained to perform services on our behalf. These service providers are contractually restricted from using or disclosing the data except as necessary to perform services on our behalf or to comply with legal requirements.
Legal Requirements and Business Transfers
We may disclose personal data (i) if we are required to do so by law or legal process, (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that Aon is subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.
Does Aon transfer your personal data across geographies?
Aon may transfer certain personal data across geographical borders to Aon entities or service providers in other countries working on our behalf in accordance with applicable law.
By providing us with your data or using our websites, you consent to the collection, international transfer, storage, and processing of your data. These transfers are governed by the appropriate data transfer mechanisms in order to protect the security and confidentiality of personal data.
How can you access and correct your data?
Aon takes reasonable steps to keep your personal data accurate and complete. You can access or update your personal data in the following ways. Aon relies on personal data to provide products and services and you shall ensure that the personal data you provide us is accurate, complete and correct and promptly inform us of changes to such personal data.
A reasonable fee may be charged to offset Aon’s administrative and actual costs incurred in complying with your data access requests.
If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.
If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.
If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.
Contact us at the e-mail or postal address listed in the "Contact Us" section at the bottom of this Privacy Statement. Please include your current contact data, the data you are interested in accessing and your requested changes. We will provide you access to the personal data requested, subject to reasonable limitations provided by law, unless it infringes on the privacy of other individuals.
If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.
Does Aon have security measures in place to protect your data?
Aon has implemented reasonable physical, technical and administrative security standards to protect personal data from loss, misuse, alteration or destruction.
Our service providers and agents are contractually bound to maintain the confidentiality of personal data and may not use the data for any unauthorized purpose.
Does Aon collect data from children?
Our websites are not directed to children and we do not knowingly collect personal data from children on our websites.
We ensure personal data is not kept longer than is necessary for the fulfillment of the purpose for which the data is or is to be used.
If you have any questions relating to this Statement, please contact us at the Aon Global Privacy Office, Aon plc, 200 E. Randolph, Chicago, Illinois 60601 or email@example.com. You may also direct your query to the Data Privacy Officer, Aon Hong Kong Limited, 28/F, Tower 1, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong.
Changes to this Statement
We may update this Statement from time to time. We encourage you to periodically review this Statement so that you will be aware of our privacy practices. This Statement was last updated on 21 January 2016.
In the event of any conflict between the English and Chinese versions, the English version shall prevail.