Pru Life UK Privacy Notice

• Personal contact information: personal and contact details, such as title, full name, contact details (e.g. email address, phone number, residential address) and contact details history;

• Identity information: proof of identity, e.g. ID card/passport, your picture/image/video via our CCTV in our premises;

• Age and gender: your date of birth, gender and/or age;

• Your nationality (if relevant to the product or service);

• Stakeholders information: details of fund investors, beneficiaries, such as joint policy holders and minor beneficiaries of our products or services;

• Family and dependent information: family members, your marital status, family, lifestyle or social circumstances, e.g. the number of dependents you have or if you are a widow/widower (if relevant to the product or service);

• Correspondence information: records of your contact with us such as via the phone number of our customer service centre and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address, and MAC address;

• Product information: products and services, you hold with us, as well as those you have been interested in and have held and the associated payment methods used;

• Usage and claims information: the usage of our products and services, any claims and whether those claims were paid out or not (and details related to this);

• Analytics information: analysis of data relating to marketing made to you, including history of communications and whether you open them or click on links;

• Marketing information: information about your use of products or services held with our Marketing Partners, such as insurance policies, mortgage, savings or financial services and products;

• Third party claims information: information we obtained from third parties, including information about insurance risk, pricing, claims history, instances of suspect fraud and usage history;

• Third party insurance information: information we obtained from third parties including but not limited to insurance policy information (if you consented);

• Credit information: personal information which we obtain from credit reference agencies and fraud prevention agencies, including public (for example, defaults) and shared credit history, financial situation and financial history;

• Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud;

• Criminal records information, including alleged offences;

• Health information: information about your health or if you are a vulnerable customer if you are applying for medical or life insurance or during the claim process;

• Property information: information about your property, such as location, value, number of rooms, property type and building work you’ve had done (if relevant to the product or service);

• Financial details about you, such as your salary and details of other income, details of your savings, details of your expenditure, bank or other financial accounts, and payment method(s);

• Details about all your existing borrowings and loans (if relevant to the product or service);

• Information about your employment status (if relevant to the product or service);

• Information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application;

• Your residency and/or citizenship status;

• Information we buy or rent from third parties, including demographic information, details of outstanding finance, marketing lists, publicly available information, and information to help improve the relevance of our products and services;

• Travel details if you purchase travel insurance from us;

• Vehicle details if you purchase general vehicle insurance from us;

• Profiling information: insights about you and our customers gained from analysis or profiling of customers;

• Third party transactions information; such as where a person other than the account holder uses the service, information about that person and the transaction; and

• Tax information (if relevant to the product or service). For example, for investment accounts.

We’ll collect personal information from the following general sources:

• from you directly, and any information from family members, associates or beneficiaries of products and services;

• information generated about you when you use our products and services;

• when you submit an application or registration form, or any other forms relating to any products and services offered and/or distributed by us;

• when a policyholder takes up an insurance policy for your benefit or appoints you as the life assured / insured members;

• when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

• when you interact with our customer service officers, representatives, agents or appointed service providers (for example, via telephone calls, letters, face-to-face meetings, social media platforms, surveys, workshops and/or e-mails);

• when you use our electronic services, or interact with us via mobile services, social media accounts, digital platforms, any of our websites or web services;

• when you request us to contact you (whether pursuant to a request for more information, complaints, or any other purposes);

• when you respond to our promotions, lucky draws, contests, events, initiatives, surveys organised by Prudential, its Business Partners, representatives or service providers and/or any other request for personal data;

• from a broker or other intermediary (for example, distributors, Business Partners) who we work with to provide products or services or quote to you;

• Prudential Group if you already have a product or services with them, have applied for one or have held one previously or for any other lawful purposes;

• cookies, location services, IP addresses when you visit our website or mobile app;

• questionnaire and contact details when you attend investor conferences, roadshows or when you update contact us form on our website;

• from other sources such as fraud prevention agencies, credit reference agencies, other lenders, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies;

• we buy or rent information about you or customers generally from third parties including demographic information, vehicle details, claims history, fraud information, marketing lists, publicly available information and other information to help improve our products and services or our business.

• when your images are captured by us via CCTV cameras while you are within any of our premises, or via photographs or videos taken by us, our representatives or our agents when you attend our events;

• when we receive references from our Business Partners or third parties (for example, where you have been referred by them);

• when we receive information from third parties about you when you make payment through (including but not limited to) physical and digital payment kiosks;

• when we seek information from third parties about you in connection with the products and services you have applied for, including but not limited to, from other insurers, insurance associations, healthcare institutions, clinics, investigators, ex-employer and the relevant authorities;

• when you submit your personal data to us for any other reason;

• when you consent to us seeking information from third parties (including but not limited to other insurers, financial institutions and banks) about you in connection with any fact-finding exercise; and/or

• other publicly available sources where relevant and appropriate.

This Cookie Policy describes how we use cookies and other similar technologies such as pixels, web beacons, scripts, and tags in connection with our website and our products/services.  

We use cookies for various purposes, including to distinguish you from other users of our website and to gain insight on your interaction with content on our website. This helps us to provide you with a good experience when you use our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser.

We may use both first- and third-party cookies:

• First party cookies are cookies placed by us directly when you visit our website and use our services.

• Third party cookies are cookies set by third parties (e.g. analytics providers, advertisers and business partners).
  
  

Cookies are broadly categorized as follows:

• Strictly necessary cookies: These are cookies that are essential to the functioning and the operation of our website / provision of our services. They include, for example, cookies that enable you to log into our secure website;

• Analytical/performance cookies: These allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily;

• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region); and

• Marketing cookies: These cookies are used to learn more about your interaction with content on our website to deliver relevant advertising to you. These cookies remember what you have looked at on our website and we may share this information with our Business Partners.

This section identifies the personal information we collect from you and the purposes of processing. It also identifies the legal basis under which we process your personal information (where applicable under data protection laws). To the extent the data protection laws in your jurisdiction do not recognize legitimate interest or another legal basis specified in the table below for a particular purpose, you consent to our processing of your personal information by consenting and acknowledging this Privacy Notice.

Who we share your personal information with and why

We’ll share your personal information within the Prudential Group and with our Business Partners, for any of the purposes set out in this Part D. If you have a joint policy or investment, the other person may receive your personal information too.

We may process your personal information in a country other than the one you are resident in. Our servers are located in the Philippines, Singapore and Hong Kong. We also have support, engineering and other teams who may support provision of products/services to you, including from the Philippines, Malaysia, India, and Singapore.  

To the extent we transfer your personal data, we will use appropriate safeguards and comply with applicable data protection laws to ensure the transfer is done lawfully. Details of the safeguards we use are available on request. By acknowledging this Privacy Notice and using our products/services, you consent to the cross-border transfer of your information to any country where we have databases or affiliates, including those set out in this section.

We work with many external parties in order to provide you with a seamless experience in relation to any products and/or services you have purchased from us. In the ordinary course of business, we may be required to disclose personal data to such external parties and these external parties may be located overseas.

We only disclose your personal data, where appropriate and necessary, for one or more of the above-mentioned Purposes or as permitted by law. The external parties we may disclose your personal data to include, but are not limited to, the following:

• within the Prudential Group and distribution partners / brokers / business partners / applicable group policyowners to facilitate the conduct of our business, carrying out our business activities and servicing you in relation to the products and services offered to you where appropriate and relevant;

• our third-party service providers, sub-contractors of third-party service providers, contractors and vendors – which could include accountants, auditors, lawyers, IT service providers, business consultants, claim investigators, event managers, debt collection service providers, other such third-party service providers and sub-contractors of such third-party service providers which may assist us in carrying out our business activities. All third-party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Purposes;

• medical institutions, clinics, financial institutions, credit card companies, credit reference agencies, industry bodies, other insurance and re-insurance companies – to facilitate the processing of your applications, claims or any other insurance-related information or procedures;

• public and governmental authorities, including regulatory authorities and law enforcement agencies – to comply with legal process, to respond to requests from such parties, to detect and prevent fraud, and to protect our business operations;

• your family, relatives, appointed executors, appointed trustees, appointed administrators, and their professional advisers – in connection with your will(s) or the administration of your estate;

• any business partner, investor, assignee or transferee (actual or prospective) – to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Prudential Group;

• any social media and/or advertising platform providers such as Google and Facebook if you have consented to receiving marketing, advertising and promotional information; and

• any other party whom you authorize us to disclose your personal data to.
  
  

ACCURACY AND PROTECTION OF PERSONAL DATA

We will take reasonable efforts to ensure that any personal data we have about you is accurate and complete. However, this means that you must also ensure the accuracy of the personal data provided by you and update us of any changes to the personal data that you had initially provided to us in a timely fashion.

We will also take reasonable efforts to protect the personal data in our possession by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or any similar risks.

THIRD-PARTY SITES

Our website may contain links to other websites operated by third parties, which may be co-branded with our logo or trademark, even though they are not operated or maintained by us. We are not responsible for the privacy practices of such third parties that are linked to our website. Once you have left our website, we strongly encourage you to refer to the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

SECURITY

We implement and update technical and physical security measures to safeguard your personal information against loss, misuse or unauthorized access on an ongoing basis. Our protective measures include firewalls, data encryption, access controls, among others. However, please be aware that transmitting information over the Internet is not completely secure, and no data storage system can be guaranteed to be entirely safe. While we strive to protect your personal information, we cannot guarantee the security of data transmitted to our sites; any transmission is at your own risk. We encourage you to recognize the important role you play in maintaining the security and confidentiality of your personal information.

RETENTION

We do not keep your data for longer than is necessary to fulfil the Purposes above.

Your personal information will be stored either for as long as you (or your joint policyholder) are our customer, or longer if required by law or as is otherwise necessary for us to fulfil the Purposes above.

For certain products, we may use approved credit reference agencies, tracing companies, financial crime prevention agencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering. This may include checks on your current or previous addresses. Results of these may be recorded for future reference.

These checks may also be carried out for a fund investor, joint policy holder or person(s) that you provide personal information on. Should we ever lose contact with you, we may use these agencies to verify your contact information to help us get back in touch.

Any transfer of your personal information will always be done securely.

We, our Business Partners, and our Marketing Partners may use your personal information to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling).

To the extent that we conduct such automated decision-making activity, we’ll provide you with further information at the appropriate time.

For certain products or services, we’ll need to process your sensitive personal information, such as information relating to health, genetics, biometric identifiers etc. To the extent that we need your explicit consent to process this kind of personal information in the manner described in Parts C, D, E and F, we will provide details of this at the point of collection and seek your consent.

When it comes to how we / your representative (where applicable) uses your personal data, you may have the right to:

• Right to Access: request a copy of your personal data (we have the right to charge a reasonable fee to complete this request) from us/your PLUK representative.

• Right to Correction: request that we/your PLUK representative correct anything that’s wrong or complete any incomplete or out-of-date personal data.

• Right to Complain: complain to a data protection authority or another independent regulator about how your data is being used.

• Right to Erasure: request for erasure of the personal data we hold about you. We may need to retain personal information if there are valid grounds under data protection laws for us to do so.

• Right to Withdraw Consent: To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. If you withdraw your consent to any or all use of your personal data, depending on the nature of the request, we may not be in a position to continue administering any existing contractual relationships with you, which result in certain legal consequences. This may be disadvantageous to you, as you may lose valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

• Right to Portability: request a copy of your personal information in a structured, commonly used and machine-readable format and for us to transfer that personal information to another party.

• Right to Objection: object to our processing of your personal information. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us.

• Right to Restriction of Processing: require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
  
  

You can exercise these rights by contacting us – see Contact Us section.

If you give us personal information about another person (or persons), we will take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

• our processing of their personal information and sensitive personal information (as we’ve explained in Parts A - H above);

• you are getting any information protection notices on their behalf; and

• this includes minor’s information when you are purchasing an insurance or other products on their behalf as parents or legal guardians.
  
  

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us at the email address below before sending us anything.

We, our Business Partners, and our Marketing Partners may send you information by post about our and the Prudential Group’s products and services and carefully selected third parties, after having obtained your consent (if required by law) or if permitted by law.

Additionally, from time to time, we PLUK, Prudential Corporation Asia, and the Prudential Group would like to contact you by electronic means with details about products, services and any special offers. We will only do this if you have consented to us contacting you by electronic means.

You may opt out of receiving marketing-related communications from us, Prudential Corporation Asia, Prudential Group companies, our Business Partners and/or our Marketing Partners at any time by contacting us - see Contact Us section.

And if you change your mind, and/or you would like to opt-out of receiving non-electronic direct marketing, it’s easy to let us know through the following channels:

• If you do not wish to receive marketing materials from your PLUK representative, please write to your PLUK representative at their usual contact address.

• If you do not wish to receive marketing materials from PLUK, please use the Update of Contact Information Form or Pruaccess.
  
  

Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our products/services, such as transactional messages about your policy or our relationship with you.

For any further queries, please write to us at the address below or email us.

ADVERTISING

We may partner with third party partners (e.g. Facebook and Google) to display advertisements to you on websites you visit. These third-party partners use cookies and other technologies to gather information about your activities on our sites well as other sites you visit in order to serve you advertising based upon your browsing history and interests. We also use third-party solutions carry out advertising campaigns and send messages to consumers.

CONTACT US

If want to exercise your rights in Part H or if you require any other information about any other part of this notice, you can contact us in several different ways.

We may monitor or record calls or any other communication we have with you. This might be for training, for security, or to help us check for quality.

 For customers, contact us at:

9F Uptown Place Tower 1, 1 East 11th Drive, Uptown Bonifacio, 1634 Taguig City, Metro Manila, Philippines

Via telephone:

(+632) 8887 LIFE (8887 5433) for Metro Manila

1 800 10 PRULINK (1 800 10 7785465) via PLDT landline for domestic toll-free.

If you wish to contact PLUK about a Data Protection concern, please write to The Data Privacy Officer at:
dpo@prulifeuk.com.ph

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Notice, the English version shall prevail.

TERMS USED

Prudential Corporation Asia means Prudential Corporation Asia Limited.

The Prudential Group means Prudential Plc, Prudential Holdings Limited and any other affiliates of Prudential plc. Prudential Plc is not affiliated in any manner with Prudential Financial, Inc. a company with principal place of business is in United States of America or with the Prudential Assurance Company, a subsidiary of M&G Plc, a company incorporated in United Kingdom.

Business Partners means our service providers, accountants, distributor, auditors, IT service and platform providers, intermediaries, reinsurers, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, and our legal advisers.

Marketing Partners means our service providers, intermediaries, pension trustees (and other stakeholders), scheme advisors, introducers and selected third party financial and insurance product providers.

We are a company called Pru Life U.K. We offer insurance, which is an agreement where we promise to help our customers by giving them money if something bad happens to them, like getting sick or getting into an accident.  Our customers can include children like you. Your parents or your school can get insurance for you so that we can help in case you get sick or get into an accident.

What you’re reading now is called a privacy notice. It’s a document that tells you how we will use information about you.

So that we can offer you insurance, we need to know some things about you, such as your name, your birthday, whether you are healthy, and whether you are a boy or a girl. These are called personal information, or information that can be used to recognize someone.

We need to ask for information about you because we need to get to know our customers first and make sure that they are healthy before we can offer them insurance.

We use your information because your parents or an adult taking care of you gave your information and let us use it to see if we can offer you insurance. 

We know how important your personal information is. This is why we make sure that all of us at Pru Life U.K. follow rules to keep your information safe. If the information you shared with us is used for things that aren’t allowed, we will tell you about it and we will do our best to help stop other people from using your information.

1. Anytime we need to use your information, we will let you know and we will tell you how we will use it.

2. If we have your information, we will let you see it if you want. 

3. If you see that the information we have about you isn’t right, you can let us know so that we can correct it for you.  

4.We will stop using your information if you no longer want us to use it, unless we need it to do our job.

5. In case we don’t use your information properly and something bad happens to you as a result, we may even pay you for the trouble.

If you want to know more about these things, you or your parents can write to us at dpo@prulifeuk.com.ph or call us at (+632) 8887 LIFE (8887 5433) for Metro Manila and 1 800 10 PRULINK (1 800 10 7785465) using a PLDT landline.

In case we make any changes to this notice, we will let you or your parents know.