Legal

Chubb Privacy Policy

How Chubb collects, uses, stores and protects personal information when you interact with VitalCall and other Chubb websites and services.

Last updated: February 2020

Website Privacy Notice

Chubb Limited and its subsidiaries and affiliates (collectively, "Chubb"), are committed to protecting the privacy of visitors to our websites ("Websites") and users of our mobile applications ("Apps"). It is important that our users understand how we collect, use and disclose Personal Information. This Privacy Notice ("Notice") is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Websites and Apps.

References to "our", "us", "we" or "Chubb" within this Notice are to Chubb Limited and its operating companies, as applicable. Chubb processes Personal Information in accordance with applicable privacy and data protection laws in each jurisdiction in which it operates, including Australia, New Zealand, China (mainland), Macau SAR, Singapore, Hong Kong SAR, and India.

What Personal Information does Chubb collect?

"Personal Information" is information through which a natural person is identifiable or may be identified, either directly or indirectly. This may include your name, physical address, the company for whom you work, phone number, email address, details of the preferences you express to us, your comments and questions, and technical information from the devices you use to access our website or product you are registering (e.g. a device identifier) or the person/company that installed or maintains it.

Chubb collects, uses and processes your Personal Information when you submit a form or request, or register a product with us in order to provide you with further information about Chubb's services or products.

Sensitive Personal Information. In certain jurisdictions, additional categories of personal information are classified as "sensitive" and subject to stricter protections. We will only process sensitive personal information where we have obtained your separate consent (or where another lawful basis applies), and we will inform you of the necessity of processing and the impact on your rights before doing so.

The collection of Personal Information will be transparent to you, and you will have the opportunity to decide whether or not to provide it. However, if you choose not to provide any of the Personal Information requested, Chubb may be unable to provide you with the information, services or products that you have requested.

Chubb may also collect certain Personal Information through your use of our Websites or Apps, such as device identifiers, IP address, and log files.

Why does Chubb collect your Personal Information?

  • To provide you with requested information, and respond to your questions β€” including directing you to the appropriate Chubb website. Justification: legitimate interest.
  • To process and deliver your order for our products and/or services. Justification: performance of a contract.
  • Respond to your enquiry request or further process your submitted form. Justification: legitimate interest.
  • Analyse your behaviour on our Website and Apps, in order to improve our products, services, Websites and Apps. Justification: legitimate interest; consent where required by law.
  • Respond to a legitimate legal request from law enforcement authorities or other government regulators. Justification: compliance with legal obligations.
  • Conduct investigations to ensure compliance with, and comply with, legal obligations. Justification: compliance with legal obligations.

The lawful basis applied to each processing activity will depend on the applicable law in your jurisdiction.

Where is Personal Information stored?

Because Chubb is a global company with locations in many different countries, your Personal Information may be transferred to, stored at and/or accessed from countries other than your own. The countries to which your Personal Information may be transferred include the United States, the member states of the European Union, the United Kingdom, Switzerland, Canada, Australia, New Zealand, China (mainland), Hong Kong SAR, Macau SAR, Singapore, India, Thailand, and the United Arab Emirates.

We will only transfer your Personal Information in accordance with applicable law in your jurisdiction, using appropriate safeguards such as standard contractual clauses, governmental security assessments, professional certification, or consent.

Does Chubb use your Personal Information to contact you?

Where you have provided your consent or where otherwise permitted by applicable law, Chubb may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you would prefer not to receive such communications, please use the "unsubscribe" link within any communications sent, or let us know by sending an email to Global_privacy@chubbfs.com.

Does Chubb share the information it collects with third parties?

Chubb may share your Personal Information with its affiliated companies and subsidiaries within the Chubb group. Your Personal Information may also be shared with the parent company of Chubb, APi Group.

Chubb may share Personal Information with third parties for the following purposes:

  • to comply with Chubb's legal obligations, including complying with tax and regulatory obligations and responding to a legitimate legal request from law enforcement;
  • to investigate suspected or actual illegal activity;
  • to prevent physical harm or financial loss;
  • to conduct web analytics on user interactions with our Website and Apps; or
  • to support the sale or transfer of all or a portion of our business or assets.

We require any third-party service providers that we use to respect the security of Personal Information that they process on our behalf, and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

How does Chubb secure Personal Information?

Chubb is committed to ensuring the security and integrity of Personal Information. Chubb has adopted appropriate physical, technical, and administrative procedures to safeguard your Personal Information. However, due to the inherent nature of the Internet, we cannot guarantee that your transmission of Personal Information to us is completely secure. In the event of a data breach we will notify the relevant regulatory authority and/or affected individuals as required by applicable law.

How long do we keep your Personal Information?

We will only retain your Personal Information for as long as it is reasonably necessary for the purposes for which it was collected and to the extent permitted by applicable laws, including for satisfying any relevant legal, regulatory, tax, accounting or reporting requirements.

Your Rights

The specific rights available to you depend on the privacy law applicable in your jurisdiction. They may include:

  • Access β€” request a copy of the Personal Information we hold about you.
  • Correction / Rectification β€” have incomplete or inaccurate Personal Information corrected.
  • Deletion β€” request that we delete Personal Information no longer needed for the purpose for which it was collected, subject to any legal retention obligations.
  • Objection β€” object to processing of your Personal Information based on legitimate interests.
  • Restriction of Processing β€” restrict our processing in certain circumstances.
  • Consent Withdrawal β€” withdraw your consent at any time where consent is the lawful basis for processing.
  • Portability β€” receive Personal Information in a structured, electronic format.
  • Automated Decision-Making β€” refuse automated decision-making that has a significant impact on you and request a human review.
  • Nomination β€” nominate another individual to exercise your privacy rights in the event of your death or incapacity (India).

To exercise any of these rights, contact us by email at Global_privacy@chubbfs.com. We may require you to verify your identity before we can act on your request.

Complaints to Regulatory Authorities

If you are dissatisfied with our response, you may contact the relevant regulatory authority for your jurisdiction, including:

  • Australia: Office of the Australian Information Commissioner (OAIC) β€” www.oaic.gov.au β€” 1300 363 992
  • New Zealand: Office of the Privacy Commissioner β€” www.privacy.org.nz β€” 0800 803 909
  • China: Cyberspace Administration of China (CAC) β€” www.cac.gov.cn
  • Singapore: Personal Data Protection Commission (PDPC) β€” www.pdpc.gov.sg
  • Hong Kong: Office of the Privacy Commissioner for Personal Data (PCPD) β€” www.pcpd.org.hk

Cookies and similar technologies

Chubb may use cookies on this Website. Cookies are small text files sent to and stored on users' computers. We use cookies to allow the Website to recognise repeat users, facilitate users' access to the Website, and compile aggregate data that will allow content improvements. If you do not want cookies to be accessible, you should adjust the settings on your browser. However, denying cookies may prevent you from accessing some content or features.

This Website may also use web beacons, IP addresses and log files to maintain website safety, troubleshoot technical issues and better understand how our Websites are used.

Children

Our Apps and Websites are intended for visitors who are at least 18 years of age, or the age of majority in their jurisdiction of residence. Chubb does not knowingly solicit information from, or market products or services to, children.

Collection, Use and Disclosure of Credit-Related Personal Information

We may provide credit in connection with the supply of our goods and services. For this purpose, we collect credit-related personal information about individuals that apply for credit with us or who provide guarantees in respect of credit provided by us.

The kinds of credit-related personal information Chubb may collect about you include:

  1. your name, personal and work contact details, date of birth and driver's licence number;
  2. information about assets you own and any security held against those assets;
  3. information about court proceedings to which you are or were a party that affect your ability to make payments to us;
  4. information on your credit check report, such as credit providers you have credit with and your payment history;
  5. information about your history of payments, including any defaults;
  6. information about your interactions with our collection agencies;
  7. information provided by your trade referees;
  8. information about any relevant insolvency event; and
  9. confirmation that you are not listed as a denied party by the United States government.

We may disclose your credit-related personal information to credit reporting bodies, our collection agencies and our external solicitors, and to overseas recipients including service providers in India.

Storage and Security of Personal Information

Chubb stores your personal information in a combination of:

  1. hard copy files with restricted physical access; and
  2. electronic files stored on local servers or secure cloud platforms owned by Chubb, its related entities or their contracted service providers.

Chubb takes reasonable security precautions to protect the personally identifiable information that we collect from misuse, interference and loss and from unauthorised access, use, modification and disclosure.

Access to and Correction of Personal Information

You can request to access and/or correct your personal information by contacting us. We may request that you provide evidence of your identity. We will deal with your request as soon as reasonably practicable, generally within 30 days for credit-related personal information.

Privacy Complaints

If you wish to make a complaint about how we have handled your personal information, please contact us using the details below. If your complaint relates to credit-related personal information, within 7 days we will acknowledge your complaint in writing and explain how we will deal with it.

You may also contact:

  1. if you are in Australia, the Commonwealth Privacy Commissioner. If your complaint relates to our handling of your medical information in NSW or VIC you may also complain to the NSW Privacy Commissioner or the Victorian Health Services Commissioner; or
  2. if you are in New Zealand, the Privacy Commissioner or an Ombudsman.

How to Contact Us

If you have any questions about this Privacy Notice or would like to access or correct your personal information or make a privacy complaint, please contact us:

By post in Australia: Privacy Officer Chubb Fire & Security Pty Ltd Locked Bag 2007 North Ryde BC NSW 1670

By post in New Zealand: Data Protection Officer Chubb New Zealand Private Bag 92207, Victoria St West Auckland 1142

By email: Privacy.Officer@chubb.com.au