Ginsmall.com is wholly operated and owned by the RSL Consultancy Limited (hereinafter called “RSL”, “we”, “us”, “our”). All insurance is arranged by RSL. RSL respects personal data privacy and is committed to fully implementing and complying with the requirements under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). We will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.
This Privacy Statement (“Statement”) explains our information processing practices. It applies to any personal data you provide to RSL and, subject to local law, any personal information we collect from other sources.
1. What type of information does RSL collect?
We collect personal data to offer and administer our services and products. These include insurance broking, claims management, risk management consulting, employee benefits program administration and other forms of insurance services.
We may collect data such as your name, contact details, date of birth, gender, marital status, financial details, employment details and benefit coverage. We may also collect sensitive data about you such as criminal convictions or health data in relation to life, health, professional liability and workers compensation insurance or employee benefit programs.
When you request services, we ask that you provide accurate and necessary data that enables us to respond to your request. In doing so, you consent to our collection, use, storage and disclosure of this data to appropriate third parties for the purposes described in this Statement.
2. Purpose of Collection / How does RSL use your Personal Data?
The purposes for which we collect your personal data, which may be used, stored, held, processed, transferred, disclosed or shared by RSL, are as follows:
- provide information and services as requested by you;
- determine eligibility and process applications for products and services;
- provide information and services as requested by clients;
- understand and assess clients’ ongoing needs and offer products and services to meet those needs;
- carry out client communication, service, billing and administration;
- administer claims;
- conduct data analysis;
- obtain and update credit information with appropriate third parties, such as credit reporting agencies, where transactions are made on credit;
- execute monitoring and training;
- develop new services;
- market products and services (subject to appropriate consent); and
- conduct processing necessary to fulfill other contractual obligations for the individual.
With your consent (which includes an indication of no objection), we may also use your personal information for additional purposes. It is up to you whether you provide your personal data to us. However, if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or to process your request.
3. Use and Provision of Personal Data in Direct Marketing
From time to time, your personal data provided to us including name, contact details and demographic data, may be used, provided, disclosed and transferred by us to our affiliated businesses and third party service providers acting on RSL’s behalf including but not limited to mailing house, telemarketing and direct sales agents and call centres (within or outside Hong Kong) for the purpose of direct marketing in relation to insurance and risks management services via different communication channels including fax, direct mail, email, SMS and telemarketing.
4. Opt-out of Personal Data for Direct Marketing
You may at any time inform RSL whether you object to the intended use by RSL for direct marketing by writing to RSL at Room 2002-03, 20/F, Easey Commercial Building, 253-261 Hennessy Road, Wan Chai, Hong Kong or e-mail to [email protected]
5. Legal Requirements and Business Transfers
We may disclose personal data (i) if we are required to do so by law or legal process, (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that RSL is subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.
6. Statistics on visitors to our website
When you use this website, RSL will record anonymous statistics about your visit and do not collect any information which identifies your personal identity until you in fact decide to buy any of our products. Our service providers make a record of your visit that includes but not limited to IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited, and time/duration and the pages visited.
7. Third parties
RSL may engage with third parties to provide us with certain analytical services to better understand our visitors, who may use various third party technologies to collect and store anonymous information when you visit our website, and this may include using cookies, google analysis and similar mechanisms to collect information when you click on or move your cursor over their buttons. We may have access to this information to permit us to identify other websites that you have visited that are also associated with that third party.
8. Links to third party
This website may contain links to third party websites. RSL does not provide your personal data to these third party websites. However, RSL has no control over these third party websites. You should review the privacy policies applicable to these third party websites to understand the ways in which these third parties may collect and deal with your personal information.
RSL applies strict measures to safeguard the confidentiality of personal data. We limit access to your personal data to people working for us on a business need to know basis who shall ensure that your personal data are protected against unauthorized or accidental access, processing, erasure, loss or use.
10. Data Access and Correction
Under the PDPO, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request the Company to inform you of the type of personal data held by it. Requests for access and correction or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:
Chief Compliance Officer
RSL Consultancy Limited
Room 2002-03, 20/F, Easey Commercial Building, 253-261 Hennessy Road, Wan Chai, Hong Kong
A reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests.