Privacy Policy

Privacy Policy Statement

  • We, Aviva Life Insurance Company Limited trading as Blue (the “Company”), are committed to respecting and protecting your personal data by observing and complying with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486, laws of Hong Kong) (“PDPO”).

  • We will only collect and use (including disclose and transfer) personal data in accordance with the PDPO and this Privacy Policy.

  • We may amend this Privacy Policy at any time to meet the requirements of the PDPO. The updated version will be available by following the “Privacy Policy” link on our website homepage. You should check the Privacy Policy regularly for changes.

  • In this Privacy Policy, “personal data” has the same meaning defined under the PDPO.

Collection of Personal Data

  • We collect personal data in a number of ways. The most common circumstances in which we collect personal data are when you enquire about products we offer, you apply for an insurance product and make subsequent application in respect of your policy, you change your personal details and you make a claim.

  • The types of personal data we collect from you will depend on the circumstance in which information is required for processing your request. We may collect details including your name, HKID number, date of birth, contact details and other personal data relevant to the application you made.

Purpose of Collection/Use

  • Pursuant to the above, it is voluntary for you to provide your personal data specified at the time of collection and in the ordinary course of our business relationship. However, if you fail to do so, we may not be able to process your application/request due to lack of information.

  • The information collected from you through our website for providing insurance and/or related products and services, the processing of claims under insurance policies issued by the Company, the processing of any and all other requests, enquiries and complaints from you, and/or compliance with any laws, guidelines or requests issued by regulatory or other authorities within or outside of Hong Kong (including but not limited to the implementation of FATCA pursuant to the IGA , the tax information exchange agreement that Hong Kong signed with the U.S. on 25 March 2014, and the provisions issued by the Organization for Economic Co-operation and Development, including the regulatory scheme relating to its Competent Authority Agreement to implement its Common Reporting Standard). In addition, the information collected from you may be used for one or more of the following purposes (“Purposes“):

  • a.

    processing your application and verifying your eligibility for insurance, financial or wealth management products or services;

  • b.

    managing your account with us (including account collection);

  • c.

    assignment processing;

  • e.

    processing of any credit, medical, security and underwriting checks and insurance claims;

  • f.

    processing payment instructions;

  • g.

    statistics and research;

  • h.

    providing you with promotional materials relating to our insurance or financial services or related wealth management products, and those of other entities whose ultimate parent company is Aviva plc (“companies within the Aviva Group”);

  • i.

    marketing the following services/products:
    - reward, loyalty or privileges programmes and related services and products;
    - donations and contributions for charitable and/or non-profit making purposes;

  • j.

    performing policy review and needs analysis;

  • k.

    information intelligence including customer due diligence and anti-money laundering screening,

  • l.

    meeting any disclosure requirements imposed by law or regulatory authorities on the Company or companies within the Aviva Group;

  • m.

    communication with you; and

  • n.

    fulfilling any other purposes directly related to (a) to (m) above.

Transfer of Personal Data

  • The personal data that you have supplied/will supply to us for the Purposes may be transferred within or outside Hong Kong to:

  • a.

    other companies within the Aviva Group;

  • b.

    any companies carrying on insurance and/or reinsurance related business;

  • c.

    any insurance intermediaries who have an agency or brokerage agreement with the Company;

  • d.

    any insurance claim investigators;

  • e.

    loss adjusters;

  • f.

    partnering financial institutions;

  • g.

    third party administrators;

  • h.

    professional advisors;

  • i.

    any associations and federations of the insurance industry that exist from time to time;

  • j.

    any other service providers providing insurance and/or reinsurance related business;

  • k.

    iany agents, affiliates, contractors or third party service providers who provides administrative, telecommunications, computer, payment, printing, redemption or other services to the Company in relation to the operation of the business of the Company;

  • l.

    any agents, affiliates, contractors or third party service providers who provide service / benefit to you on behalf of the Company;

  • m.

    any credit reference agencies;

  • n.

    any debt collection agencies;

  • o.


  • p.

    any persons and corporate entities to whom the Company is obliged to disclose under the requirement of any law relating to the Company or any of its affiliates or business partners;

  • q.

    any governmental and judicial bodies or regulators;

  • r.

    medical bill review companies; and

  • s.

    information intelligence provider(s).

  • The Company may transfer your Personal Data in connection with a transaction with another company which affects the control, governance, structure and/or management of all or a substantial part of its business, or if required to satisfy applicable legal or regulatory requirements

Privacy Policy Statement

  • Please note that we intend to use your name, telephone number, address, e-mail address collected through our website for direct marketing of insurance/financial products and directly related services but would not do so without your consent.

  • We will seek your consent in accordance with the guideline of the PDPO. Alternatively, you may notify us of your intention to withdraw your consent by writing to us at the address below.

Access to Personal Data

  • You have a right under the PDPO to make a data access or correction request concerning your Personal Data held by us. You may make such request by writing to:

  • Att. Contact Centre Manager of Customer Servicing Aviva Life Insurance Company Limited trading as Blue 30/F, One Kowloon, 1 Wang Yuen Street, Kowloon Bay Hong Kong

Personal Data Retention

  • Your personal data will be kept for such period as necessary for the provision of our services and to comply with applicable laws including regulatory requirements. If we no longer need your personal information, we will take all practical steps to erase it.


  • We use Session and Persistent cookies to collect information about how our website is used by you through Third Party Software. About Third Party Software. We use this Software service to improve how our website caters for your needs and to identify any technical problems. Please also refer to our Cookie Policy.

Security Measures

  • We will take all practical steps to ensure that your personal data held by us is protected against unauthorised or accidental access, processing, erasure or other use. Access to your personal data is limited to our authorised staff or agents who will be informed of this Privacy Policy in handling your personal data.

Third Parties Website(s)

  • We will take all practical steps to ensure that your personal data held by us is protected against unauthorised or accidental access, processing, erasure or other use. Access to your personal data is limited to our authorised staff or agents who will be informed of this Privacy Policy in handling your personal data.

Third Party Software

  • We use Third Party Software such as (but not limited to) Analytics Software to collect, analyse and generate reports on your behaviour when you visit our website. None of your personal data is collected by visiting our website, but the Company will access cookies on your device(s) to collect anonymous information and activities data. About our Cookie Policy.

  • Google Analytics is not permitted by the Company to further transfer your anonymous information and activities data to any other party.

  • If you wish to (a) opt-out of our purpose for collecting your anonymous information and activities data or (b) do not wish to trigger any advertising by Google on your device(s), then please follow the instructions on the link to block collection: Analytics opt-out browser add-on.

  • Please note that if you opt out by blocking cookies, this may affect your ability and experience with using our website.

Application of the PDPO

  • Nothing in this statement shall limit your rights under the PDPO.