Privacy Policy

Privacy Policy

1. Policy Background 

Liberty International Insurance Limited (UBI 03967394) (Liberty) is a company incorporated in Hong Kong and is part of the Liberty Mutual Group headquartered in the United States. Liberty provides a wide range of retail, commercial and specialist general insurance services in Hong Kong and is authorised by the Insurance Authority to conduct general insurance business in Hong Kong.

We are committed to protecting the privacy of your personal data. This Privacy Policy explains the main ways Liberty protects your privacy and how Liberty complies with the Data Protection Principles, which form part of the Personal Data (Privacy) Ordinance (Cap. 486).

This Privacy Policy applies to any personal data you provide to Liberty directly and any personal data Liberty collects about you from other sources such as intermediaries or brokers.

Key Terms

For the purposes of this Privacy Policy, personal data is information or opinion that allows others to identify you. It includes your name, date of birth, gender, contact details, health information and financial information.

2. Why Liberty collects personal data 

Liberty collects your personal data:

  • to administer our client relationship with you (as an insured, broker, or intermediary) including assisting you with any information or queries you may have about a Liberty product or service;
  • if you are a prospective employee of Liberty; or
  • to provide you with the products and services Liberty offers. This may include offering policies of insurance, risk management and claims handling. Liberty may use your personal data to check whether you are eligible for a product or service, provide you with a product or service or help manage the product or service. This can occur in the context of issuing insurance quotes and policies of insurance, underwriting policies of insurance and managing claims and complaints.

Liberty also collects your personal data to:

  • develop and identify products and services that may interest you, by conducting product and service research and sharing your information with Liberty’s related entities for them to be able to offer you products and services;
  • establish and administer alliances and other arrangements with third parties (discussed below) in relation to the promotion, administration and use of Liberty’s respective products and services;
  • track your use of our websites, products and services to enhance user experience;
  • conduct marketing activities and events; and
  • facilitate events, meetings and activities when you visit any of our office locations.

We may also use your information in the course of performing business activities including reporting and analytics. This may include the use (either in an identified or de-identified form via aggregation) of your personal data for product and service data analysis, data trend analysis and the development of business strategy.

3. What type of personal data Liberty collects 

The personal data Liberty collects about you will depend on the nature of our relationship with you and can include:

  • your name, date of birth, gender, mailing address, telephone number and e-mail address;
  • identification information such as your passport details or driver licence;
  • bank and payment details; and
  • if relevant, information about your job such as job title, employment history and professional accreditations.

Applying for a specific product or service, or making a claim, may also require us to collect additional personal data about you (where relevant to that product or service), including:

  • your insurance history; and
  • your financial information such as bank account details, billing information or insurance payment arrangements to collect premiums or to pay claims.

When you make a claim with Liberty, we may collect personal data that is more sensitive in nature. For example, in relation to the purchase of, or making a claim under a casualty insurance policy, this may include any information about your membership of professional associations, health information, religious beliefs, criminal record, financial details and identification documents, where this is relevant. More specifically, when you take out a policy or make a claim with Liberty, we may collect the following information to the extent it is relevant to that policy or claim:

  • details about your criminal convictions and any related information;
  • details about your physical and mental health, including medical reports, x-rays and blood tests; and
  • information which may reveal personal data that is sensitive, such as when you take out a policy or where you specify certain medical treatments.

If you do not provide us with the personal data we request (or our third parties request on our behalf) we may not be able to provide you with the appropriate type or level of products or services.

4. How Liberty collects personal data

Liberty mostly collects personal data directly from you in the course of providing our products or services and undertaking business operations (for example, underwriting, claims processing, etc) in relation to you or those you represent (for example, if a broker is acting as your agent).

In some cases, we may collect your personal data indirectly from a third party. For example, an insured's representative (such as a broker) may tell us about other persons wanting the benefit of Liberty’s services or the relevant product. Another example might be the personal data of a director, officer, professional or other staff member being provided to us by an insured company. In limited circumstances, we might also collect information about you for a claim made by you from a private investigator or through publicly available sources.

Liberty may also collect your personal data through our own representatives or third parties such as loss adjusters, lawyers, insurers, health care workers, or witnesses to a claim.

If you are a third party making a claim against one of our insureds (for example, an individual or entity holding an insurance policy with us), we may collect your personal data directly from you when you are making a claim or complaint, or when you contact us by email, telephone or any other written and verbal communications. We may also collect your personal data from our insured, and any third parties involved in the insurance policy or the claim you are making.

5. Disclosing your personal data 

Within Hong Kong

Liberty will disclose your personal data to third parties within Hong Kong in the normal business of conducting insurance operations, such as providing you with an insurance quote, processing, servicing, administering your insurance policy and claims, our business administration and when permitted or required by law.

For example, in providing our services to you we may provide information to:

  • other insurers;
  • reinsurers (which provide insurance to Liberty itself or to other insurance providers);
  • insurance intermediaries (e.g. insurance and reinsurance brokers, agents, appointed representatives and distributors);
  • governmental authorities, industry bodies or as required by a statutory or regulatory authority;
  • providers of analytics and fraud detection services;
  • Liberty’s own advisers or external third party service providers including loss; and adjusters, lawyers, private investigators, auditors, accountants and similar third party service providers that facilitate the handling of a claim.

Liberty limits our use and disclosure of your personal data to the purposes for which you have been notified (or consented to, as the case may be) including in the Privacy Policy. However, there may be circumstances in which Liberty uses or discloses your personal data for a secondary purpose if:

  • it is reasonably necessary to do so. For example, Liberty may disclose your personal data to an outsourced service provider in carrying out our business activities such as auditing; or
  • the secondary purpose is ‘related’ to the primary purpose of collection. This situation may arise if an external third party is engaged for the purposes of acting on our behalf in respect of a claim or complaint filed against us.

The limitations to the use or disclosure of your personal data do not apply to direct marketing (refer to Section 10 below).

Outside of Hong Kong (i.e. transborder disclosure)

For the purposes noted above, Liberty may also transfer your personal data overseas (i.e. outside Hong Kong) if it is reasonably necessary in order to provide you with our products or services or to process claims or otherwise conduct our business.

For example, depending on the product or service you have, we may transfer your personal data to overseas insurers, reinsurers, Liberty Mutual Group entities and other third party providers (or provide them with access to it). Liberty may also store your information with overseas third party cloud or other types of networked or electronic storage providers. The overseas Liberty Mutual Group entities and third parties referred to above may be located in countries outside Hong Kong, including:

  • the United States;
  • Canada;
  • China;
  • the United Kingdom;
  • European Union;
  • India;
  • Australia;
  • Malaysia; and
  • Singapore.

By engaging Liberty for the purposes of taking out a policy, accessing any of Liberty’s products or services, making a claim and/or providing your personal data to us, absent any written indication to the contrary (by you to us), you consent to all reasonably necessary cross-border transfers of and access to your personal data as noted in this Privacy Policy.

6. Automated Decision-Making

Automated decision-making (ADM) refers to making a decision (or omitting to make a decision), or doing a thing (or omitting to do a thing) where it is substantially and directly assisted by a computer program using personal data, which could reasonably be expected to significantly affect your rights or interests.

An example of ADM includes where an insurance claim is automatically rejected based on predefined criteria using your personal data.

Currently, ADM is not solely used to make a decision or do a thing by Liberty.

Liberty may use AI-enabled tools (including those that are internally developed) to assist our staff with internal operations such as document review and information retrieval. These tools help improve efficiency and accuracy and are used under strict privacy controls – they do not make decisions independently. Personal data processed by these tools is handled in accordance with the Data Protection Principles.

In all business functions, including Underwriting, Operations, HR, Marketing and Claims operations, decisions are either made manually or involve human oversight in the final decision-making process. As such, these processes are not considered ADM.

We regularly review our use of ADM to ensure transparency and fairness. If you would like more information about ADM, please contact the Privacy Officer (contact details can be found at section 14 of this Privacy Policy).

7. What Liberty expects of you (when providing another’s personal data to us)

When you provide Liberty with personal data about other individuals, we rely on you to undertake certain actions and confirm that you have performed those actions. We expect you to:

  • have made them aware that you will be providing their information to Liberty (and confirmed that they agree to this);
  • provide them with a copy of (or details of where they can find) this Privacy Policy;
  • explain the purposes for which Liberty will use their personal data and that the types of third parties Liberty may disclose it to is set out in the Privacy Policy; and
  • explain how they can access or correct their information and that how they may make a complaint by reference to this Privacy Policy.

When obtaining another individual’s agreement to share their personal data with Liberty, this can be given to you expressly or impliedly but must be clearly intended to be given. If you have not done any of the above actions, you must tell us before you provide us with the relevant personal data.

If Liberty gives you any personal data about another person (including if you are acting as a representative) you must only use it for the agreed express purposes and in accordance with this Privacy Policy.

8. Security of your personal data 

Liberty holds personal data in both electronic and hard copy formats and takes reasonable steps to protect your personal data from misuse, interference, loss, unauthorized access, modification and disclosure. We take reasonable steps to maintain up to date computer and network security and impose clear privacy restrictions on all third parties who will handle your personal data.

Liberty will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy. Where your personal data held by us is no longer needed for any purpose then, subject to any legal requirements to hold it, we will take steps to securely destroy your personal data.

9. Accuracy of an access to your personal data 

You may access or seek correction of the personal data Liberty holds about you. Liberty will, on your request, provide you with access to your personal data that we hold unless there is a legal exception preventing us from providing you with access to that data. For example, where giving access would have an unreasonable impact on the privacy of another individual, Liberty will not provide you with access to that personal data.

If Liberty does not provide you with access, we will provide you with reasons for the refusal and inform you of any legal exceptions relied upon where we are not able to provide this information to you. Liberty may recover from you its reasonable costs for retrieving and supplying your personal data to you that you have requested access to.

If you would like to access or correct your personal data, please contact Liberty’s Privacy Officer (details at section 14).

Your request to access, correct or update your personal data will be dealt with as soon as reasonably practicable, and we will respond to you no later than 21 days from your original request.

10. Direct Marketing

Subject to Liberty having obtained the relevant consent from you, we may use your personal data for direct marketing carried out by Liberty and its related entities for marketing and promotion of insurance or financial or investment related products and services offered or arranged by Liberty or Liberty’s related entities or Liberty’s respective business partners:-

For such purposes, your personal data held by a Liberty may be provided to other Liberty’s related entities and/or their respective business partners for use for direct marketing subject to your consent. Liberty or Liberty’s related entities or their respective business partners may also conduct such direct marketing via or jointly with third party services providers including social medial platforms, which may involve sharing personal data Liberty or Liberty’s related entities or their respective business partners hold about you with them.

You can always opt-out free-of-charge by following the opt-out instructions contained in the relevant communications or completing and returning the opt-out reply at https://www.libertyinsurance.com.hk/sites/libertyhk/files/documents/Opt_Out_Form/Opt_Out_Form.pdf to Liberty’s Privacy Officer if you no longer wish any of your personal data to be used in and/or be transferred for any of the described direct marketing purposes.

11. Making a complaint 

If you wish to make a complaint about how we are handling your personal data or you have any query regarding how your personal data is collected, used or disclosed or any other query relating to the Privacy Policy, please contact Liberty’s Privacy Officer:

Mail: Privacy Officer

Suites 2601-04 & 2607-16, 26/F, 1111 King’s Road, Taikoo Shing, Hong Kong 

By email: Privacy.Officer.AP@libertyglobalgroup.com

Liberty will respond to your query or complaint as soon as possible and will try to resolve any complaint within 21 business days. If this is not possible, we will contact you within that time to inform you that further time is required to assess the resolution of your complaint.

12. Cookie

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities.

13. Statistics & Logs

By using our Sites, the Company can log general statistical information of our visitors through the use of tools such as Google Analytics. This record of your visit includes information such as domain name, IP address, browser type and configuration, geo-location, language settings, operation system, previous sites visited, and duration of page visits.

Google Analytics may set cookies and process data (including IP addresses) which may be transferred to the United States.

If you want to prevent the data from being used by Google Analytics, you can use the “Google Analytics opt-out browser add-on”. For details, refer to https://tools.google.com/dlpage/gaoptout/.

You can manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect your user experience on our website.

14. Contacting Liberty Hong Kong

If you wish to gain access to or correct your personal data held by Liberty Hong Kong, make a complaint in relation to your personal data or if you have any query relating to this Privacy Policy, please contact Liberty’s Privacy Officer on:

Email: Privacy.Officer.AP@libertyglobalgroup.com

Mail: Suites 2601-04 & 2607-16, 26/F, 1111 King’s Road, Taikoo Shing, Hong Kong

Website: https://www.libertyinternational.com/hk

15. Updating this Privacy Policy 

Liberty may update this Privacy Policy from time to time, and in any event at least biannually, to reflect our current practices and changes in law, regulation and/or industry standards. The updated Privacy Policy will replace the version on our Site.

This Privacy Policy was last updated on 1 April 2026.

16. Publication

This Privacy Policy is to be published on the Liberty Hong Kong website.

In the event of any discrepancy or inconsistencies between the English and Chinese versions of this Privacy Policy, the English version shall prevail.