Protecting Your Privacy
FWD MAX (“Programme”) is a programme operated and managed by FWD Life Insurance Company (Bermuda) Limited ("FWD"). In order for you to enjoy the services and rewards provided through the Programme, FWD may collect personal data from you. Because FWD respects your privacy, it has implemented procedures to ensure that your personal data is handled in a safe, secure, and responsible manner.

Use of Personal Data
  1. Membership Enrolment/Registration
    1. Processing your registration for or request of termination of membership of the Programme;
    2. Managing and maintaining your membership account held with the Programme;
    3. Verifying your identity and eligibility to register as a member of the Programme;
    4. Processing your request for redemption of rewards under the Programme and sending you confirmation email for redemption;
    5. Sending you notifications regarding the balance of your MAX points, rewards that you can redeem with your MAX points, tips or information which helps you to pursue your passion and the latest events or workshops available under the Programme;
    6. Providing you with the services under the Programme;
    7. Handling and responding to your enquiries in relation to the Programme;
    8. Designing new or enhancing existing services to be provided under the Programme;
    9. Performing statistical or actuarial research and analysis;
    10. Meeting disclosure obligations and other requirements imposed by or for the purposes of any laws, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong) binding on FWD; and
    11. Fulfilling any other purposes directly related to any of the above.
  2. You must provide FWD with personal data not marked as “optional” in the registration page of the Programme, otherwise FWD will not be able to process your registration and provide you with the services under the Programme.
  3. Your personal data will be kept confidential, but to facilitate the purposes set out in paragraph 1 above, FWD may transfer, disclose, grant access to or share your personal data with the following parties (which may be located in or outside Hong Kong):
    1. subsidiaries, holding companies, associated or affiliated companies of FWD;
    2. data processors engaged by FWD;
    3. business partners providing the offers, rewards or privileges under the Programme; and
    4. any official, regulator, ministry, law enforcement agent or other person (whether within or outside Hong Kong) to whom FWD is under an obligation or otherwise required or expected to make disclosures under the requirements of any law, rules, regulations, codes of practice or guidelines (whether applicable in or outside Hong Kong).
  4. In addition to the purposes set out in paragraph 1 above, FWD intends to use your name and contact details to send you updates or promotional materials (“Updates”) relating to the rewards, loyalty and privilege programmes relating to the products and/or services offered by FWD as well as products and/or services offered by its business partners under the Programme relating to lifestyle, sports, music, entertainment, travelling, food and beverages, networking events, banking, alcohol and tobacco, gaming, transportation, household, finance, insurance, betting, education, health and wellness, beauty products and services, fashion and accessories, electronics, social networking, technology, e-commerce, logistics, retail, home and décor, media and high-end consumer products and services which FWD thinks will be of interest to you. The Updates will be sent or communicated to you by way of e-mail, SMS, telephone calls or other appropriate means of communication.
  5. FWD will only use your personal data for the purpose set out in paragraph 4 above if you provide your consent or do not object in writing. If you do NOT wish to receive the Updates from FWD, you may exercise your right to opt-out anytime in your profile page. It will take FWD around seven working days to update your opt-out status in the Programme. For the avoidance of doubt, your opt-out from the Updates in the Programme will not affect your consent for direct marketing previously provided to FWD under other circumstances.
  6. Access to and Correction of Personal Data
  7. Under the Personal Data (Privacy) Ordinance, you have the right to request access to your personal data and request correction of any of your personal data which is incorrect. FWD has the right to charge you a reasonable fee for processing and complying with your data access request. For any requests for access to or correction of your personal data in the Programme, please make your request in writing to FWD MAX Data Protection Officer:
    FWD Life Insurance Company (Bermuda) Limited
    8th Floor, FWD Financial Centre
    308 Des Voeux Road Central
    Hong Kong
  8. Retention and Management of Personal Data
  9. With its best endeavours, FWD will ensure that your personal data will be stored and managed in a manner to protect it from potential inappropriate usage, unauthorised access, modification or disclosure. It is the practice of FWD to achieve appropriate levels of security by restricting physical access to data, providing secure storage facilities and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data and personal data is only transmitted by secure means.
  10. FWD will take practicable means to ensure that no personal data is kept for longer than necessary. All personally identifiable data will be eliminated or deleted from the Programme within 30 days once an account termination request is received from you.
  11. FWD will eliminate or delete any personally identifiable information that is unable to help in optimising the Programme, with regard to the servicing and rewarding of current members and future members in their pursuit of a fulfilling lifestyle, as applicable laws permit.
  12. Depersonalised data will be maintained by FWD to better serve current members and future members. Such data will be used for relevant processing in terms of service recovery, audit, security, etc.
  13. Accuracy of Personal Data
  14. FWD will take practicable means to ensure the accuracy of all personal data collected and processed in the Programme, and if such personal data is transferred to third parties, it will notify that third party of any correction to be made. Appropriate procedures are implemented so that all personal data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used.
  15. Use of Cookies and Third Party Links
  16. The Programme’s website (“Website”) may include hyperlinks to third party websites. FWD has no control over the content, accuracy, opinion expressed, and other links provided at these third party websites or how these third party websites deal with your personal data. You should visit these third party websites for details of their privacy policies in relation to their handling of your personal data.
  17. FWD may use "cookies" to improve its internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by the Website. Cookies enable the Website to remember you and your preferences when you visit the Website and enable FWD to tailor the Website to your needs. The information collected by cookies is anonymous visitor’s personalised settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser.
  18. Changes to Privacy Statement
  19. FWD reserves the right, at any time and without notice, to add to, change, update or modify this Privacy Statement.
  20. Enquiries or Complaint Handling
  21. For any enquiries or complaint relating to your personal data handling, please email: FWD’s corresponding personnel will consider and process your enquiries or complaint within seven working days. FWD pledges to use its best endeavours to resolve any complaint to your satisfaction.
  22. In case of discrepancies between the English and Chinese versions of this Privacy Statement, the English version shall apply and prevail.