Privacy Statement

We collect information from you in a number of ways when you request or use our products or services. For example, you might provide us with information:

• at application or claim time;
• when you subscribe to any AIA newsletter;
• when you participate in AIA Vitality, surveys, competitions or promotions; or
• when you contact us (over the phone, through email, social media or letter), or visit our website.

We generally record inbound and outbound telephone calls for operational purposes such as complaint handling and reporting, quality assurance, and staff training.

The information we collect from you may include your name and contact details (e.g. email address, phone number and address), social media profile, identifying information (e.g. date of birth, driver’s licence, passport, birth certificate), residency, AIA Vitality membership and other details such as gender and marital status, financial information (e.g. income, superannuation, tax), lifestyle and health/medical information, family and beneficiary information, and insurance claims information.

When you use our website, mobile applications (including AIA Vitality) or contact us through social media, we may collect information about your location or activity including your IP address, telephone number, whether you’ve accessed third party sites and fitness device data. Some of this website information is collected using cookies, which will not personally identify you but do identify your browser. You can set your browser to refuse cookies but this may mean you won’t be able to take full advantage of our website. For further information about cookies, please refer to our Cookie Policy.

We also use systems provided by third parties to monitor search behaviour, measure traffic flows and or help us advertise our products. These systems include Google Analytics, Google Ads, Adobe Experience Cloud and Hotjar.

Information regarding your usage of our website is collected to help us improve and offer the services you need each time you visit and to improve our services generally. We may also use this information to improve our advertising and marketing of related products and services.

Our website may contain links to non-AIA websites. Whilst such links are provided for your convenience, you should be aware that the privacy practices and reliability of the information published on the linked websites might not be the same as ours.

Sometimes we collect personal information about you from other people or organisations, rather than directly from you. This may include sensitive information such as health or financial information, where reasonably required for our purposes (see ‘How We Use Information’ section). We do this where you have provided consent or where this is permitted or required by law. You usually provide this consent when you complete our application and claim forms for our products and services (including AIA Vitality). Please take the time to read these carefully.

Third parties we may collect information about you from include:

• We may collect information relevant to your cover from your adviser, ASB Insurance Manager, agent, broker, insurance agent or administrator;
• We may collect information relevant to your cover from other insurers including where you have relevant insurance cover with more than one provider;
• We may collect information relevant to your cover from a family member, or the owner or administrator of the insurance policy that you are a beneficiary of;
• We may collect medical and health information from Health Providers, including doctors, specialists, dentists, counsellors, psychologists, therapists, laboratories, hospitals, and diagnostic facilities you have consulted with where this is necessary for the purposes of assessing your application for insurance or any claim, and including any non-disclosure assessment;
• We may collect Accident Compensation Corporation claims and related medical and health information;
• We may collect employment details from your current and former employer, including where you have, or your employer is considering, group insurance cover provided by your employer;
• We may collect financial information from banks (personal or business accounts), accountants, financial advisers, credit reporting and fraud protection agencies;
• Where AIA is the underwriter of your ASB Bank Limited (“ASB”) insurance product, we may collect personal information about you (including health information) from ASB. This may be done for the purposes of underwriting, administering, and managing your insurance policy, including assessing claims or handling complaints, or for compliance, audit or reporting purposes;
• We may collect travel and visa information, criminal records income, subsidy and benefit information, birth, death, marriage, and passport information, and/or tax information from government departments such as Immigration New Zealand, NZ Police, Ministry of Social Development, Ministry of Business, Innovation & Employment, Department of Internal Affairs and Inland Revenue Department;
• We may collect information about you that is publicly available or where you have provided third parties with your consent to share information about you with us, for example from public registers or social media.

If you don’t provide us with your personal information when requested, or you withdraw your consent for us to collect personal information from other parties, or you provide us with incomplete information during the course of our relationship with you, we may no longer be able to provide you with certain products or services, such as insurance cover or assessment of your claim.

AIA (and any authorised third parties in accordance with this Privacy Statement, including members of the AIA Group) may collect, use (which includes holding and storing) and disclose your personal information to provide you with insurance related products and services, including to:

• establish your identity and the identity of others specified on a policy;
• assess and respond to your requests, applications, instructions, feedback or complaints;
• conduct underwriting or for actuarial or reinsurance purposes;
• provide you or the owner or administrator of a policy you are, or are intended to be, a beneficiary of with quotes, and set up your premiums;
• administer and manage our products and services, including AIA Vitality;
• calculate commission payments to advisers;
• assess insurance claims and whether you have met your duty of disclosure at application time;
• manage our relationship and communicate with you, including to tell you about new or existing products or services that we think may be of interest to you (you may opt out of this);
• ensure that the products you have and services you receive are meeting your needs and are improved where necessary;
• assess complaints about the products you use or services you receive;
• cancel, transfer or change your insurance policies or any products you use or services you receive; or
• comply with our legal, and ethical obligations, such as sanctions checking or anti-money laundering and countering financing of terrorism laws
• comply with contract obligations such as audit and reporting obligations.

We may also use your personal information to:

• conduct customer analysis and research, to ensure that the products and services we offer are the best they can be;
• price and design our products and services;
• improve customer experience (including on our websites and applications) and train our staff;
• contact you following the lapse or cancellation of your policy, or where a quote or application is not proceeded with, for marketing or survey purposes;
• conduct special offers or campaigns (you can opt out of this);
• assist with statistical or actuarial research undertaken by AIA, the financial services industry or our regulators;
• data match, or for internal business and administrative purposes;
• investigate or analyse incidents;
• develop and test products, services and systems;
• monitor and protect our brand and our (and our business partners’) lawful interests.
• manage and monitor our risks, including identifying, investigating and preventing any illegal or improper activity.

Please note that you can opt out of some of the uses above.

Improvements in technology enable organisations, like us, to collect and use your personal information to get a more integrated view of customers and provide better products and services. In order to do this, we (or third parties we contract) may conduct ‘data matching’ by combining your information with information available from a wide variety of external sources, including census or Statistics New Zealand data. We (or third parties we contract) are then able to analyse the data in order to gain useful insights which can assist us to meet the purposes set out above. We may also use artificial intelligence (AI) technology to support and enhance our business functions and improve our products and services (see 'How we use Artificial Intelligence' below).

We may also collect, use and disclose your personal information for other purposes as permitted by law or where you consent and we take steps in addition to this Privacy Statement to ensure you are aware of the additional purposes.

By providing your email address and/or mobile phone number, you consent to us sending you information connected with the above collection and use purposes via email or text message. We may also send you newsletters or other information we think you may be interested in and which may market and promote our products and services, or the products and services of other parties we think you may be interested in, including, if you are a member of AIA Vitality, products and services of our AIA Vitality partners in accordance with the procedures described under the heading "Collection and Disclosure – AIA Vitality Partners” below. The messages you receive from us will have instructions for how you can remove yourself from our mailing list.

Some uses of your personal information may involve the transfer of that information outside New Zealand, to be held and used by members of the AIA Group, our related companies and business partners (refer below).

AIA, and the AIA Group, may disclose personal information to third parties in New Zealand or overseas where this is necessary to provide insurance products and services including AIA Vitality, operate our business, or where required by law.

We will disclose your personal information with your consent (which may be provided at application or claims time), where permitted or authorised by law, or where another lawful basis under privacy law applies.

Where we provide your personal information to a third party as described below (and except where they may only use your information for the purposes of providing services to us and not for their own purposes), the third party may collect, use and disclose your personal information in accordance with their own privacy policy and terms of use. These may be different to that set out in this document and, if the third party is located outside New Zealand, are likely to be governed by the laws of that jurisdiction.

Where we disclose your personal information to third parties located outside of New Zealand, we take reasonable steps to ensure that your information is protected and handled in a manner consistent with New Zealand privacy laws.

We recommend that you carefully read and familiarise yourself with such privacy terms of any third party with whom we are required to share your personal information. If you would like information about our providers or other third parties applicable to your circumstances, see the ’Contact Us’ section below.

Like most insurers, AIA uses reinsurance to help manage risk and ensure we can continue to meet our commitments to customers and regulators.

We may share your personal information (including health information) with the reinsurer relevant to your policy, to the extent reasonably necessary for reinsurance purposes. If we do not share this information, we may not be able to provide insurance cover, maintain your cover, or assess or pay claims.

Our reinsurers may indirectly collect, use and disclose your personal information (including health information) where necessary to conduct their reinsurance business. For example, where Swiss Re Life & Health Australia Limited, New Zealand Branch is our reinsurer for your insurance product, Swiss Re will handle your information in accordance with its privacy policy available at Privacy Policy | Swiss Re. Rights of access to and correction of personal information held by Swiss Re is also set out in their privacy policy.

If you would like to understand more about our reinsurers, or to access or correct your information held by a reinsurer, you will need to contact us in the first instance (see ‘Contact Us’ section below). We can identify the reinsurer(s) relevant to your cover and assist you in liaising with them.

Where AIA is the underwriter for your ASB insurance product, we may share medical information relating to your application with your ASB Insurance Manager for the purposes of providing you with advice about the underwriting of your application.

We may share your personal information with ASB Bank including claim outcomes, information about the status of your policy, premium or payment information. ASB will use this information in accordance with its privacy statement and applicable privacy laws, including to manage its relationship with you, assist you to manage your policies or, where relevant, manage the risk of fraud. Further information about how your personal information is handled by ASB is set out in ASB’s Privacy Statement at Privacy | ASB.

In some circumstances, we may also need to share your personal information with other third parties to provide our services to you, manage our business, or meet legal requirements. These third parties may include:

• those authorised by you (which may include disclosure to service providers, medical professionals, agents, advisers, brokers, other insurers, banks and other financial institutions, credit reporting and fraud prevention agencies, government or law enforcement agencies, employers (whether current or not) or family members);
• persons acting on your behalf, for example your attorney;
• other individuals named on a policy, for example, policy owners or a payer;
• our business partners in co-branded products, programmes, activities or business initiatives, in accordance with the specific terms and disclosures that apply (including but not limited to AIA Vitality programme partners and Discovery Holdings Limited who owns the AIA Vitality Programme and licenses it to AIA). You can access the privacy policy of Discovery Holdings Limited at Terms & Conditions - Discovery
• if required by our contractors (for the purposes of the services they provide), so that we can complete a transaction on your behalf or provide you with a service that you have requested or otherwise in connection with the operation of AIA's business or provision of services to you;
• other companies that help gather your information or communicate with you, such as research companies and ratings agencies, in order to enhance the services we provide to you;
• other insurance companies, banks, parties involved in arrangements that provide funding to us and other financial institutions, for example, so we can process a claim for mistaken payment or transfer a policy;
• your current employer, former employers, group scheme policy owners, or other individuals or organisations involved in administering a group scheme;
• if required by law;
• if necessary to prevent a threat to health, security or safety;
• if it is (or was) the purpose of collecting the information;
• if necessary to facilitate the sale, disposal, assignment or transfer of AIA or any of its assets or subsidiaries or related companies;
• if necessary to market, review or improve our services or facilities or those of our business partners;
• if necessary for third parties to offer you products and services that may be of interest to you and to optimise the advertisements on our websites; or
• if necessary for a function of AIA, such as for legal or auditing purposes.

In relation to any personal data collected by us whilst providing any services in respect of our mandatory provident fund master trust schemes, such personal data would only be transferred to the above parties for the purpose of providing any mandatory provident fund related services.

We are always looking for ways we can use technology to improve our products and services, and your customer experience. The capabilities of AI are developing rapidly and we are adopting the use of AI to enhance our internal operations and improve our products and services. For example, we may use AI-powered software to help us assess your information (including health information) to process applications and claims, draft documents, and generate insights based on data we hold. We may also use AI-enabled 'chatbots' to provide you with responses to queries you have.

We are committed to using AI responsibly and transparently. When using AI tools:

• We maintain internal controls to limit and monitor the use of AI tools on customer information.
• We maintain appropriate data security safeguards to ensure your personal information remains in a secure environment and is not used or disclosed to train AI models.
• Wherever practicable, we will tell you when you are interacting with an AI-powered function.

We store your information here in New Zealand or overseas with Group members and our trusted data storage providers.

AIA will take all reasonable steps to protect personal information from misuse, loss and unauthorised access, modification or disclosure. We have a range of physical and technology policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.

Communications over the internet, such as emails, are not secure, unless they have been encrypted. When we send personal information overseas (as explained above), or use trusted third parties to handle or store personal information, we contractually require our business partners to ensure that appropriate information handling and security arrangements are in place. We may, and we may allow third parties to, monitor our network for security and information assurance purposes.

Wherever your information is, we take all reasonable steps to ensure that it is safe.

Specifically for our AIA Vitality Members (including former and potential AIA Vitality members), we collect and use your personal information to administer the AIA Vitality Programme. This may include the following purposes (without limitation):

• managing your membership, including assessing, processing and administering your AIA Vitality application, registration, activation and ongoing membership;
• communicating with you, anyone acting on your behalf, your financial adviser, ASB Insurance Manager, and/or the policy owner of your policy regarding your AIA Vitality membership;
• providing products, services and benefits related to your AIA Vitality membership;
• collecting results / recording and assessing your health and wellbeing activities, gym visits, appointments, tests and assessments you choose to participate in, including comparing results over time, to update or allocate points to your AIA Vitality membership status;
• assessing your entitlement to any discounts available to you under insurance products linked to your AIA Vitality membership (or entitlement thereto);
• sending you marketing communications for non-financial products and services that are outside the AIA Vitality Programme (such as offers from our AIA Vitality Partners), where permitted by law (you can opt out of the communications at any time; and
• conducting research, analysis and programme development relevant to your engagement in the AIA Vitality Programme, improvements to products and services offered by us or AIA Vitality Partners, and for facilitating your use of our website.

AIA will take reasonable steps to ensure that personal information held by us is accurate, up to date and complete.

You may obtain confirmation as to whether or not personal information is held about you from us. You may also request access to, or a copy of, the information and/or request that corrections or changes are made to it. In accordance with our obligations under the Privacy Act, within 20 working days of receiving a request we will a) decide whether the request is to be granted and, if so, in what manner and for what charge (if any); and b) give or post a notice of the decision on the request to you.

AIA will disclose personal information to the relevant individual about whom the information relates where it can be readily retrieved, unless there is good reason (in accordance with the Privacy Act) for not doing so, including where such a disclosure would breach someone else’s rights to privacy and/or the law.