Effective Date: 10th December 2016
Scope and Application
AIG Insurance Hong Kong Limited (“AIG HK”, “we”, “us”) collects and holds information about you when you sign up for and use the AIG Drive Master mobile application (“AIG Drive Master”) and when, through your use of AIG Drive Master or otherwise, you purchase insurance from AIG HK or have any communications with AIG HK for these purposes. This Privacy Statement sets out what and how information is collected, why it is collected, to whom it may be transferred and how you may gain access to/request correction of such information or change your choice with regards to receiving promotional material. It is entirely voluntary for you to provide such information, but there is certain information you must provide a) to access AIG Drive Master in the first place; and b) to use all functionalities of AIG Drive Master.
By signing up to use AIG Drive Master you agree to the information you submit or which is collected through AIG Drive Master being collected, processed, used and transferred in the manner identified in this User Privacy Statement.
A feature of AIG Drive Master is that you are able to purchase car insurance any time from AIG HK. The discount feature of AIG Drive Master enables you to see the type of premium discount you may be able to obtain based on your driving record.
What information do we ask you to provide directly to us and why?
You will note that we collect your e-mail address when you first register for AIG Drive Master and ask you to complete certain information in the “Personal Information” section of the app. The information we ask you to provide and why is as follows:
Your e-mail address - When you first download AIG Drive Master we ask you to provide your e-mail address, which we use to generate a password for you. Without you providing this information, therefore, you will not be able to access AIG Drive Master. We also use this to communicate with you on queries you have on, or to provide you with information in relation to AIG Drive Master. Further (unless you have exercised your right to “opt out” of receiving promotional material), we may use this to send you special promotions of our insurance products.
Address/City/Phone number – You may use AIG Drive Master without filling in this information. However, we do give you the option to enter this information. The purpose of asking for this information is to provide us with alternative means of communicating with you about AIG Drive Master if you have any queries (for example, if we cannot get hold of you by your e-mail address). If you choose to purchase insurance from us through AIG Drive Master, then we will collect this information and this information would be necessary for your insurance purchase to be effected. In that event, your information will be used for the insurance related purposes as shown in our standard Privacy Statement [LINK].
Birthday –You may use AIG Drive Master without filling in this information. However, we do give you the option to enter this information. The purpose of asking for this information is that it provides us with a check on your eligibility to use AIG Drive Master. It is also another check on your identification. If you choose to purchase insurance from us through AIG Drive Master, then we will collect this information and this information would be necessary for your purchase to be effected. In that event, your information will be used for the insurance related purposes as shown in our standard Privacy Statement. Further (unless you have exercised your right to “opt out” of receiving promotional material), we may use this to send you special promotions of our insurance products related to your birthday.
Car make/car model/car year/vehicle registration number – We collect this information to ensure AIG Drive Master works accurately for your purposes (the make, model and year of the car are important for that), but also for eligibility and identification purposes. You are only eligible to use AIG Drive Master if you are a qualified driver with a registered vehicle. As such, the provision of this information is a necessary condition of you accessing the functionality of AIG Drive Master. If you choose to purchase insurance from us through AIG Drive Master, then we will also use this information to effect that purchase. In that event, this information will be used for the insurance related purposes as shown in our standard Privacy Statement [LINK].
Expiry date of your current car insurance – This information is not mandatory for you to provide in order to use AIG Driver Master. We may use this information for reminding you of the discount you could obtain for our insurance, based on your AIG Drive Master score, at the time your insurance comes up for renewal, if you fill this in. As such, we only use this information (and only ask you to provide it) if you have not exercised your right to “opt out” of receiving promotional material in relation to our insurance products.
What information does AIG Drive Master collect and access when it is used and why?
When you sign up for AIG Drive Master, you will note that we indicate AIG Drive Master requires access to certain information. This information, the reasons access to it is required and the time at which it is accessed are set out below:
Location Information – AIG Drive Master functions by collecting precise location data about your trip when you drive. This is necessary to enable AIG Drive Master to detect your acceleration, cornering, speed and other measurements which make for safe driving. It is therefore necessary for permission to be given through the permission system of your mobile operating system for AIG Drive Master to be used for its main purpose of assessing your record as a safe driver.
Motion Detection – To record the safety measurements of your driving (accelerating, cornering, speed, braking) AIG Drive Master needs to access the activity recognition functionality of your mobile phone’s operating system. It is therefore necessary for permission to be given through the permission system of your mobile operating system for AIG Drive Master to be used for its main purpose of assessing your record as a safe driver.
Network/Wifi states – AIG Drive Master collects the location information in real time whilst you are online. If, however, that connection is interrupted the information is stored locally until a connection is available. It is therefore necessary for permission to be given through the permission system of your mobile operating system for AIG Drive Master to be used for its main purpose of assessing your record as a safe driver
Contacts Information – AIG Drive Master provides you with the functionality to invite friends in your contacts list to register for AIG Drive Master. If you wish to do this, however, it is necessary for you to permit access to the address book on your device through the permission system used by your mobile phone platform. We will only use such information if you use the “invite friends” function.
Call and SMS Data – As a safety feature, AIG Drive Master has the functionality to turn on automatic call and SMS replies for incoming calls and SMS’s received whilst AIG Drive Master is being use to record a driving trip. This enables you to drive without interruption and improve your safety. It is optional for you to use this function. If, however, you choose to use it, it is necessary for you to permit access to the SMS and call functions through the permission system used by your mobile phone platform. We will only utilize these functions for the stated purposes.
Important information about platform permissions
Most mobile platforms have defined certain types of device data that apps cannot access without your permission and platforms provide different permission systems for gaining your consent. The iOS platform alerts you the first time AIG Drive Master wants access to a particular function (usually the first time you use that function) and asks you to give permission for that function to be used at that point. Android devices will notify you of all the permissions AIG Drive Master may need for all functions when you first register for the app and your use of the app constitutes your consent. The above explanations, we hope, gives you full details of the functionalities which AIG Drive Master needs access to, why and when it will use them.
What information might be collected from other sources
A feature of AIG Drive Master enables you to share your score and other information on your social media sites. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you set with your social media service. Please check the privacy policies of your social media sites for further information.
To which third parties may we transfer your data?
Information collected through AIG Drive Master is collected on cloud servers run by a third party cloud hosting provider. The information is also downloaded to AIG HK which utilizes shared service hubs run by AIG affiliate or third party cloud hosting companies for data storage and management. On-going application support for AIG Drive Master is provided by a third party software service provider with whom AIG HK contracts, who in providing such support requires access to the data collected through AIG Driver Master.
For the above third parties to have the data access required, data collected through AIG Drive Master is transferred to places outside of Hong Kong (where the cloud data centres and AIG data centres are based and where the service providers are based). Where such a transfer is performed, it will be done in compliance with the requirements of the Personal Data (Privacy) Ordinance. The countries/jurisdictions to which personal data is transferred by AIG HK include, without limitation,
- the United States of America,
- the Philippines; and
- the European Union
If you purchase insurance from AIG HK using AIG Drive Master, the third parties to whom your data may be transferred and the purposes related to this are set out in Privacy Statement [LINK] on our website.
Opt- out for Promotional communications - In addition to this, however, we wish to use your contact information (e-mail address, phone number, address) to contact you from time to time about insurance products which may of interest. In the context of AIG Drive Master this may include contacting you on or around your birthday or on the date your current car insurance expires with special offers (which is why we ask to collect this date from your). You may opt out of receiving such promotional messages from us at any time by following the instructions on those messages, or alternatively, by contacting us at GPO Box 456 or email@example.com.
Upon receipt of any opt-out request from you, AIG HK will, at no cost to you, act on your request and ensure that your personal data will not be used as indicated in your request.
Your right of access and correction
In respect of any personal data collected from you and held by us through AIG Drive Master, you have the following rights:
i.to check whether AIG HK holds data relating to you and to access such data;
ii.to require AIG HK to correct any data relating to you which is inaccurate; and
iii.to ascertain AIG HK’s policies and practices in relation to personal data and to be informed of the kind of personal data held by AIG HK.
To exercise any right of access and correction of personal data above you may write to the Privacy Compliance Officer of AIG HK at GPO Box 456 or firstname.lastname@example.org. The Privacy Compliance Officer of AIG HK will, upon satisfying itself of the authenticity and validity of the access request, make every endeavour to comply with and respond to the request within the period set by the Personal Data (Privacy) Ordinance (the “Ordinance”). In accordance with the terms of the Ordinance, AIG HK has the right to charge a reasonable fee for the processing of any data access request.