Our global privacy statement

We collect personal information from you that’s necessary to:

• deliver products and services
• enhance your experience and interactions with us
• manage our business operations
• fulfil our legal and security obligations 

Depending on your products, services you use and your interactions with us, the information we need may include:

• contact information such as your name, mailing address, email, phone number
• demographic information such as your age, employment details, marital status, beneficiary information, nationality
• health information such as your lifestyle information, health and smoking status, medical history, diagnosis
• financial information such as contributions, investment funds and accounts, retirement goals, source of income, risk tolerance
• identifiers such as bank account number and government issued IDs
• supporting documents such as tax slips, bank statements, identity verification, wills, proof of relationship, power of attorney
• information about your interactions with us such as your survey responses, call centre interactions, complaints

You don’t have to provide personal information to use our Digital Properties unless a particular feature requires it. Here are some situations that will require you to provide personal information:

• accessing your account online or through a mobile app 
• connecting online with a licensed agent 
• signing up for a newsletter 
• applying for a product online

We maintain appropriate procedures to ensure that personal information in our possession and the information we exchange with our service providers and agents is accurate and kept up to date. As permitted by applicable law, you can request to access and correct your personal information. 

We conduct Privacy Impact Assessments (“PIAs”) for new business initiatives and any significant changes to processes that involve personal information. The PIA is a strong risk management practice that helps us protect your privacy when we collect, use and share personal information. 

Children’s information

We don’t knowingly collect information from or market products and services directly to children under the age of majority. We only collect information about children from parents or legal guardians when they are covered under their policies or assigned as beneficiaries.

We maintain technical, physical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. We limit access to those who have a business need to know.

Our online security safeguards include a wide variety of technical solutions and security practices designed to work together to protect your information. As required in local privacy and data protection laws, we’ll notify you if we become aware of unauthorized access to your personal information. You can find more information on our Security pages. 

Links to third-party websites 

We want to provide our website visitors with more information that may be helpful to them. That’s why some of our websites contain links to other websites that are not affiliated with or maintained by us. We are selective about the websites we link to, but we don’t monitor or manage the privacy practices of these third-party websites. As a result, we can’t assume any responsibility for the data collection policies and procedures of these websites. We’ll let you know when you are leaving our Digital Properties to link to an external website.

Some examples of how we use your personal information:  

Delivering products and services 

• manage your accounts and provide administrative support
• understand your needs and suitability of our products
• process your applications and transactions
• manage your investments and claim payments
• provide you with updates on your accounts, products and services
• investigate complaints and respond to inquiries

Enhancing your experience and interactions with us 

• personalize and improve your experience while using our Digital Properties
• better understand your interest in our products and services 
• enable the use of our online tools and investment calculators
• better understand your preferences, needs and how you use our Digital Properties
• deliver targeted and personalized marketing 
• display customized preferences (language, time zone, etc.) when you return to our websites or use our mobile apps

Managing our business operations

• analyze and improve our internal business processes
• develop products and services
• determine effectiveness of our marketing and advertising 
• evaluate and improve the functionality of our Digital Properties
• measure engagement and gain a better understanding of client behaviours on our Digital Properties

Fulfilling security and legal obligations 

• confirm your identity to make sure no one else is accessing your information without authorization
• enhance digital security including preventing and detecting security threats and unauthorized activities
• implement risk management programs and procedures to protect against fraud, errors or misrepresentations
• meet regulatory or contractual requirements, such as financial and regulatory reporting 

We may need to use your information in other ways, as required by law. If we need to use your information for any other purposes, we will do so only with your consent.

We are responsible for protecting the confidentiality of all personal information in our possession. That includes information transferred to third parties performing services on our behalf such as our agents, service providers or our affiliates, along with our reinsurers. Unless prohibited by legal or contractual requirements, we and some of these third parties may store or process your information outside the jurisdiction where it was collected. In those cases, we follow all local laws, and the processing of your personal information may be subject to the laws of those other jurisdictions. We always require that these third parties protect your personal information consistent with our privacy policies and practices and comply with relevant laws.

We are careful what information we share and why. We aim to limit the personal information we share with third parties to what is needed for the service they provide.

Here are some of the services third parties provide:

• providing cloud hosted digital solutions and advanced technologies, IT support, security and consulting services
• supporting our administrative, underwriting and claims processes
• facilitating marketing campaigns, product promotion, surveys and market research activities

In some cases, laws require us to share information with regulators or government agencies.

We may enhance our data by combining it with information from external sources. These sources may include publicly available databases, social media platforms or third-party mobile apps. This helps us understand the characteristics and behaviours of certain groups or individuals. It also allows us to provide more personalized offers and services. 

If the data from external sources is personal information and linked to identifiable individuals, we are committed to use it in line with the original purposes for which it was collected. 

We may engage with you using advertising tools on various social media and networking platforms. For this purpose, we use certain demographic characteristics and other information we have about you to create more targeted advertising. To match the information we have about you with your user profile on these platforms, we use limited data points that are modified in a way that cannot directly identify you. 

We don’t exchange any financial or health information about you with these platforms. If required, we’ll also respect the marketing preferences you communicated to us.  

We may also use services provided by these platforms and other search engines to provide targeted advertising to their users that don’t have an existing relationship with us. In those scenarios, we may use our own Client data to create a profile of the audience we want to target. The platforms match the characteristics of their users based on the data they collect from them. These platforms have privacy policies and terms of use that govern their advertising rules. Users can change advertising preferences there. 

We also use partnerships with some web platforms, online marketplaces or other financial institutions to promote and distribute our products and services. For example, we may track how many individuals visit advertisements promoting our products that appear on other websites. In some cases, we track whether the interactions with our marketing content result in a purchase of our products and services.

We inform you why we collect, use and share your personal information. In some cases, we may request your express consent for the use of your personal information. You have a choice to withdraw your consent for processing of your personal information. Sometimes, this is not possible because of legal or contractual requirements. Withdrawing your consent may limit our ability to provide you with a full range of services. Here are some of the choices you may have depending on your jurisdiction: 

• You may request not to receive marketing and other commercial messages.
• You may choose to communicate with us and provide your information using multiple channels: digital, telephone, fax or regular mail.
• You have a number of options to manage cookies. If you choose to delete or refuse cookies, or choose not to share certain device information, some functionalities on our Digital Properties may not be available to you. 
• You can select different accessibility options on our websites or when communicating by phone, if you have special vision or hearing needs. 

Be sure to visit our local privacy policies for more details.

Our Digital Properties may use cookies and other tracking technologies, such as pixel tags and web beacons. Here are some of the ways we use these technologies:

• help us better understand how our websites and mobile apps are being used 
• measure the effectiveness of our advertising and marketing activities 
• support our security and fraud prevention efforts

A cookie is a small file of data that a website or mobile app sends and stores on your device. The next time you visit our website or mobile app, we may use the information stored in your cookie to make your visit easier. A cookie doesn’t tell us your identity unless you have chosen to provide it to us. Cookies can’t access information or files from your device. There are two types of cookies: session cookies and persistent cookies.

• A session cookie is erased when you close your Internet browser and leave our website or mobile app. 
• A persistent cookie is a file that remains on your device when you close your Internet browser. Only the website that created the cookie can read it when you revisit that site.

Cookies can be used to identify a visitor only if the visitor has used a website's login feature. Sometimes you may ask us to save your access ID for use the next time you visit our website or mobile app. In that case, we’ll use a cookie or a mobile secure storage to store your access ID in an encrypted format on your device. The website or mobile app will recognize you the next time you visit and sign in. In this way, we can recall your preferences and provide a more customized experience.

Persistent cookies have expiry dates and are automatically deleted from your device after that date. You can also clear your stored cookies through your browser preferences on your device. Unless you have settings that disallow cookies, the next time you visit our website or mobile app, a new cookie will be added. 

You can set your website browser to notify you when you receive a cookie, so you can decide whether to accept or reject it. You can also use your device settings to control whether certain information is collected, such as geolocation or certain device information. You may choose not to accept cookies or not to provide location and other device information. In those cases, you may notice some digital services may not function effectively. Review our local privacy policies for cookies used on our U.K. and Ireland websites. 

We use advanced data analytics technologies such as artificial intelligence (AI) and machine learning to gather more meaningful insights. As a result, we’re able to: 

• make better decisions about our business processes 
• offer you more relevant products and services
• personalize interactions through all our communication channels 

We use multiple data points collected through various business lines and communication channels to understand your needs.  

We use your information for analytics in a respectful and fair manner. Whenever possible, we de-identify it to further protect your privacy. We are taking steps to ensure our use of data doesn’t introduce unintended bias. Our goal is to always treat you fairly.   

Advanced analytics helps us be more relevant to you and conduct our business in a more efficient way. We also use analytics insights to innovate and implement new technologies and automation.