Main purposes of storing personal data
Personal data held in:
1.Insurance policy/pension scheme records are kept for the purposes of: (i) processing and evaluating the application of a policy or pension scheme (ii) administering and providing services in relation to the product the policy owner or the scheme participant holds; (iii) processing and investigating claims; (iv) conducting customer surveys; (v) researching and designing financial, insurance or pension products for customer use; (vi) selecting and participating in reward, loyalty or privileges schemes and related services; (vii) contacting the policy owner or scheme participant for the above purposes; (viii) purposes which are directly related to the above purposes; (ix) complying with applicable laws, regulations or court orders; and (x) contacting the policy owner or scheme participant with marketing information regarding Flywheel Financial Strategy and third party pension, financial and insurance products.
2.Personnel records of employees and agents are kept for recruitment and human resource management purposes, including: (a) processing and evaluating job applications; appointing employees or agents; (b) facilitating and administering employment or agent contracts; (c) administering the registration, renewal, and cancellation of insurance and MPF intermediary licenses with regulatory bodies such as the Hong Kong Federation of Insurers (“HKFI”) or its successor and the Mandatory Provident Fund Authority (“MPFA”), including but not limited to reporting of training records and responding to their enquiries; (d) administering all aspects of employment or agency relationships with Flywheel Financial Strategy, including but not limited to accounting, auditing, regulatory and tax requirements; (e) enrolling and administering employees or agents in pension and retirement fund schemes; (f) providing group medical and life insurance and other benefits offered by Flywheel Financial Strategy; (g) performing the obligations of Flywheel Financial Strategy and enforcing its rights under the agreement, including but not limited to any post-termination debt recovery; (h) performing appraisals and implementing disciplinary action; (i) purposes which are directly related to the above purposes.
3.Other records are kept for various purposes depending on the nature of the record. We will specify these purposes as and when we collect such personal data.
4.Records collected from our website are kept in order to improve our website’s performance and functionality, create a better experience for visitors and measure the response to web marketing campaigns.
In addition to the main purposes stated above, we intend to use your personal data in direct marketing of Flywheel Financial Strategy products and services. However, we will only do so where we have your written consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
1.Your name, contact details, other products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by us from time to time may be used in direct marketing of our products and services; and
2.the products and/or services offered by entities of Flywheel Financial Strategy may be marketed where permitted by law.
However, we will not provide your personal data to third parties for their use in direct marketing without your express consent to the same.
Should you subsequently not wish us to continue using your personal data for direct marketing as described in this paragraph, you may exercise your opt-out right by notifying us. Please write to us using the contact details stated below in the data access and correction section.
Please read our online privacy statement for details of the data security and data protection measures for information we receive and collect when you visit our website.
Outsourcing arrangements
Flywheel Financial Strategy may engage service providers to process personal data on our behalf. All service providers engaged by Flywheel Financial Strategy are bound by a contractual duty to keep any data they come into contact with confidential, and to protect such data against unauthorized access, use and retention.
Protection measures
Flywheel Financial Strategy takes appropriate steps to protect the personal data we hold against loss, unauthorized access, use, modification or disclosure. Only our authorized staff are permitted to access personal data collected by us.
Retention
Flywheel Financial Strategy maintains and executes retention policies of records containing personal data to ensure personal data is not kept longer than is necessary for the fulfilment of the purpose for which the data is or is to be used. Different retention periods apply to the various kinds of personal data collected and held by Flywheel Financial Strategy in accordance with our record management policy.
Disclosure of personal data
For insurance policy or pension scheme records, Flywheel Financial Strategy may disclose your personal data (a) to third parties who provide services in Hong Kong or elsewhere in order to assist Flywheel Financial Strategy to carry out the above purposes, including but not limited to claims investigators, medical advisors, medical service providers, emergency assistance service providers, reinsurers and professional advisors (provided that such contractors are required to keep all such personal data confidential and may only use the personal data to provide those services); (b) to your bank for payment purposes; (c) to your insurance broker (if any); (d) to the insurance agents and MPF intermediaries of Flywheel Financial Strategy; (e) to the related companies of Flywheel Financial Strategy, including pensions services providers, insurance companies and financial services companies; (f) to the Hong Kong Federation of Insurers (or any similar association of insurance companies) or its successor and its members; (g) to any person to whom Flywheel Financial Strategy or its related companies (inside or outside Hong Kong) is under an obligation to make disclosure under the requirements of any law, regulation or court order binding on or applying to or to which Flywheel Financial Strategy or its related companies (inside or outside Hong Kong) is subject to, or under and for the purposes of any guidelines issued by regulatory or other authorities with which Flywheel Financial Strategy or its related companies (inside or outside Hong Kong) is expected to comply; and (h) as otherwise required or permitted by law. Flywheel Financial Strategy may also use and disclose your personal data in other ways with your consent or as otherwise required or permitted by law.
For personnel records of employees, Flywheel Financial Strategy may disclose your personal data to (a) any agent, contractor, or third party service provider who provides administrative, telecommunications, computer or other services to Flywheel Financial Strategy in connection with its business; (b) any companies within the Flywheel Financial Strategy group of companies for internal purposes and direct marketing of products and services provided by those companies; (c) persons seeking employee references (in circumstances where the express consent of the employee has been obtained); (d) any person to whom Flywheel Financial Strategy is compelled to make disclosure under the requirements of any law binding on or applying to or to which Flywheel Financial Strategy or its related companies (inside or outside Hong Kong) is subject to, or under and for the purposes of any guidelines issued by regulatory or other authorities with which Flywheel Financial Strategy or its related companies (inside or outside Hong Kong) is expected to comply; and (e) third parties involved in a possible reorganization or sale of all or part of Flywheel Financial Strategy or its business or assets. If you are an employee and have queries on this matter, please contact the Flywheel Financial Strategy Chief Human Resources Officer at Flywheel Financial Strategy Limited, Unit 1116, Star House, Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong.
For personnel records of agents, Flywheel Financial Strategy may disclose your personal data to (a) third parties who provide services in order to assist Flywheel Financial Strategy to carry out the permitted purposes, including but not limited to legal advisors, insurance providers, private investigators and debt collection companies; (b) the HKFI or (its successor) and its members, MPFA and other regulators; (c) providers of pension and retirement fund schemes; (d) related companies of Flywheel Financial Strategy; and (e) government authorities and agencies as required or permitted by law.
For other records, Flywheel Financial Strategy will specify the disclosure parties as and when we collect such personal data.
Data access and correction
Should you have any queries regarding our personal data privacy policy and practices, please address them in writing to our Data Protection Officer at Flywheel Financial Strategy Limited, Unit 1116, Star House, Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong.
Last updated on 4 December 2021
