Privacy Notice
This Privacy Notice (sometimes called Privacy Policy) outlines our commitment to collect, process and use your personal data in accordance with applicable laws and regulations on data privacy including the Philippine Data Privacy Act of 2012 (“DPA”) and its implementing rules and regulations (IRR). In processing personal data, we seek to adhere the general privacy principles of transparency, legitimate purpose and proportionality and such relevant principles as required by law.
We recommend that you read and understand this policy to be informed of the Company’s principles and practices in collecting, processing, sharing, and disposing of your personal data.
Who are we?
FWD Philippines is the first life insurance company licensed by the Insurance Commission of the Philippines under the New Insurance Code. FWD Philippines launched its commercial operations in September 2014. FWD Philippines maintains its strong financial position as Top 2 and Top 4 in terms of Paid-Up Capital and New Business Annual Premium Equivalent, respectively.
FWD Philippines offers life insurance plans, investment-linked plans, and health insurance plans.
Our head office is located at 19th floor, W Fifth Avenue Building, 5th Ave cor. 32nd Street, Bonifacio Global City, Fort Bonifacio, 1634, Taguig, Metro Manila
Collection of personal data
FWD Philippines collects personal information about you from variety of sources, including:
Information we directly collect from you when you apply for our products and services such as your:
Name, birthdate, age, gender, nationality
Contact information (email address, telephone number, mobile phone number)
Home or Business Address and mailing address
Specimen signatures
Government ID details
Occupation, financial information, and sources of income
Card or Bank details (if selected for your payment methods)
Health declaration, height, weight, and other underwriting information requirements
You may also be asked to provide some personal information about your dependents, beneficiaries, authorized representatives, and others. By providing their personal information, you confirm that you have properly obtained their consent.
We may collect these information through:
Our distribution partners or agents who meet with you to discuss and offer you FWD products and services; and
The documents and forms you submit to us as part of your application, underwriting or claims requirements.
Information we collect about you when you call us, visit our websites, use our mobile applications or services or view our online advertisements.
Information that we collect from third-parties including, but not limited to, affiliates, partners, contracted service providers, and medical/financial/insurance institutions necessary to process your insurance application and provide you the needed services.
Information that we collect about you from other sources, such as commercially or publicly available sources, government agencies and medical information sharing facilities.
Purpose of collection
FWD only collects the personal data needed to effectively serve you and carry out its business operations such as:
to process your transactions with the Company (e.g. insurance applications, policy issuance and delivery, claims adjudication, premium payments or refunds);
to maintain and administer your account with the Company;
to respond to your queries or requests and investigate complaints;
to send your statements, billings, notices, and other documents necessary for your continued use of our products and services;
to comply with domestic and/or foreign laws and regulations, directives or guidelines issued by competent authority, regulatory or supervisory body, court, and enforcement agencies applicable to FWD Philippines or companies of the FWD Group of Companies (or the “FWD Group”);
to conduct data analytics, profiling, historical and scientific research that will then be used to: (a) develop, enhance and offer you financial services and products that the Company thinks will be suitable for your needs; (b) to improve our customer service and experience; (c) to improve our internal systems and processes; (d) in actuarial assumptions for a more effective pricing; (e) in internal and external management reporting; and (f) to develop business strategies and attain business-related company goals;
to enter into reinsurance transactions, as may be applicable;
to help the Company in risk management, identity verification, and protection against fraud;
to comply with policies and procedures applicable within the FWD Group; and,
to perform activities necessarily arising from and/or related to (1) to (9) above.
Sharing of personal data
FWD Philippines reports to FWD Group located in Hong Kong, which also owns and manages data processing systems, applications, and databases. For purposes of managing your account and complying with relevant domestic or foreign laws and regulations, directives or guidelines applicable to FWD Philippines or the FWD Group, we may be required to share your information to the FWD Group. Some of the data processing systems, applications, and databases are also owned and managed by FWD Group. FWD Group follows and implements stringent data protection regulations in Hong Kong.
FWD Philippines may also engage third-party service providers and partners whose jurisdiction, in some instances, may be located outside the Philippines. We restrict the transfer of your personal data outside the Philippines unless such transfer is crucial or required by relevant laws. As necessary, your personal information may be processed, shared, stored, used, and be subject to the laws of these foreign jurisdictions.
In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may be asked to disclose or transfer your personal and/or sensitive data.
We may disclose and share your personal information to the following:
Relevant regulatory bodies and/or government authorities such as, but not limited to, Insurance Commission, National Privacy Commission, Bureau of Internal Revenue, and Anti-Money Laundering Council;
Third-party service providers who may perform FWD business operations on our behalf (outsourced processes);
Reinsurance partners;
Physicians, hospitals, clinics, medical practitioners, laboratories, specialists, claim investigation companies, administrators, external counsels, accountants, external auditors or other professional advisors engaged by the Company;
Distributors, intermediaries, agents, or contractors that provide services in relation to FWD’s businesses; and
Persons or companies to whom FWD or the FWD Group have to make disclosure under any law, rules, regulations, codes of practice or guidelines (whether applicable in or outside Philippines).
FWD ensures the personal and/or sensitive personal information being shared to the above listed recipients are not excessive in relation to the declared and intended purpose or processing.
Rest assured that, in sharing your personal data as may be necessary in the foregoing transactions, FWD Philippines will ensure that your rights as a data subject are protected and respected by obtaining your consent and abiding by the requirements and procedures imposed by the DPA, its IRR and other relevant rules and regulations. We maintain mechanisms designed to ensure that any processing of personal and/or sensitive data by third-party service providers, bank partners and FWD Group and affiliates, are consistent with this Privacy Notice and the relevant laws, and protects the confidentiality, availability, and integrity of your personal data. We institute contractual provisions and risk assessments with our third-party providers to ensure adequate protection of your personal and sensitive data is in place. They are not allowed to process or use your personal data outside the processing activities we instructed them to perform.
Storage, Retention and Disposal
Any relevant personal and/or sensitive data collected during the life of your insurance policies and other transactions with the Company will become part of your records and will be retained in accordance with the relevant laws. FWD Philippines will retain your personal data for as long as necessary to fulfill the purposes of your transactions with the Company, unless a longer period is allowed or required by law. After expiry of the retention period, we will securely destroy your personal information in accordance with our Data Retention and Disposal Policy, such as shredding the physical records, deletion or anonymization of electronic data, and through such other means that would prevent further processing, unauthorized access or disclosure to any other party.
In some instances (e.g. data analytics, research, historical and statistical analysis, management reporting), we will anonymize your information so that it can no longer be associated with you and we will retain your anonymized information as long as may be necessary therefor.
Security of information
FWD Philippines follows strict security procedures to ensure that your personal data is not modified, damaged or disclosed to a third party without your permission and to prevent unauthorized access. We have established and implemented various protection measures to secure your personal information, among others (but not limited to):
Management of Human Resources (confidentiality contractual obligations, conduct of internal trainings and awareness campaigns, certification and memberships in professional organizations)
Conduct of privacy impact assessments (periodically and for every change in our processing)
Physical security (locked cabinets, restricted access to information processing facilities, clean desk policies)
Network and Computer Securities (firewall, encryption, logical access controls, data loss prevention, malware management, log monitoring)
Onsite and offsite backup of your personal data and the processing systems
Vulnerability assessment and penetration testing for systems
Third Party Risk Management (due diligence, contract, access management, audit)
Unless shared to our outsourced business processors, FWD Group and affiliates, distributors and authorized representative of FWD Philippines as stated above, all of the information we collect or record is restricted to our offices. Only persons who need the information to fulfill their duties under contract are granted access to personal data.
Rights of data subject
As a data subject, you may have the following rights granted to you by the Data Privacy Act, its Implementing Rules and Regulations and other related issuances:
Right to be informed on the processing of your personal data
Right to object the processing or sharing of your personal data
Right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying or requesting deletion of the data
Right to request a copy of the personal data we have collected about you
Right to make changes with regard any of your personal data
Right to suspend, withdraw or order the blocking, removal or destruction of your personal data from our system
Right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal data, considering any violation of your rights and freedoms as a data subject
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal and/or sensitive information. We will make reasonable attempts to promptly investigate, comply with or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else.
We reserve the right to charge an appropriate fee (if any fee may be charged to us by third parties) for complying with your request where allowed by applicable law, and/or to deny your requests where, in our discretion, they may be unfounded, excessive or otherwise unacceptable under relevant laws.
Website, online platforms, mobile applications
When you visit or use our Company website, online platforms and mobile applications (collectively called as “digital assets”), you are anonymous unless you choose to identify yourself. You are not required to provide personal information to use our platforms, unless necessary, such as accessing your online account, contacting us, providing feedback, and updating your account information.
We have physical, organizational, and technical security in place that we consider sufficient to help protect your online personal data from unauthorized use or improper access. This however does not guarantee that the information you entered in our digital assets will not be intercepted, misappropriated or used by others (e.g. hacking).
Protect your personal information
We encourage you to be extra cautious with your personal information by ensuring that your account details, PINs, username, and password are not disclosed to other people. Consider using difficult passwords and to change them regularly as well as keep yourself updated with new mobile applications and notices from FWD Philippines.
Use of cookies and Web Analytics
Your web browser may automatically send us personal data, which may include IP address and location, or non-personal data which may include pages you visited, the operating system you use, the name and version of your web browser.
FWD may use “cookies” to improve our online service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by our digital assets. Cookies enable FWD’s digital assets to remember you and your preferences which enable us to tailor the relevant digital assets according to your needs. The information collected by the cookies is anonymous based on visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. No customer personal data is stored in cookies. You can however disable cookies by changing the settings of your web browser.
FWD’s 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.
Changes to our privacy notice
This notice, and any updates, amendments or supplements thereto is available on our website at www.fwd.com.ph. This policy was last modified on 18 March 2019.
Contact us
We are constantly improving our digital assets, customer touchpoints, and other channels where you can easily opt-out from processing of your personal data. Nevertheless, you may reach out to our Data Protection Officer to opt out from these processing activities, such as opting out from direct marketing. FWD will no longer approach you for promotions or products that may be suited to your insurance needs and personal profile. However, this will not affect our ability to provide quality service in relation to your existing FWD policies.
Report any data breach
If you have privacy concerns, have knowledge of improper handling or processing of your personal information which we are in our custody or your rights as a data subject have been violated, please contact our Data Protection Officer using the information provided below:
Data Protection Officer
FWD Life Insurance Corporation
19F W Fifth Building
5th Ave. cor. 32nd St., BGC,
1634 Taguig City, Metro Manila
Email: dataprotection.ph@fwd.com
