Privacy Policy for Agents and Brokers

We, Prudential Life Assurance (Thailand) Public Company Limited (hereinafter referred to as “we”, “us”, “our” or “ours”, depending on the context) take the privacy and protection of your Personal Data (as defined below) seriously.

So, we’ve set out the below information about our processing of your Personal Data, what rights you have, and how you can get in touch if you want to know more.

When we say “Personal Data”, we mean any information relating to an individual, which enables the identification of such individual, whether directly or indirectly, as defined in the applicable data protection legislation and also as listed below. We collect Personal Data from you that is necessary for us to conduct our business operation with you as a part of it, to comply with statutory or contractual requirements or any other pertinent purposes in the course of our corporate activities and business operation. Unfortunately, if you’re unable to provide certain Personal Data which is necessary for us to perform necessary tasks or obligations to you or as required by law, we will not be able to enter into a contract with you or perform our contractual obligations.

We may change this Privacy Policy from time to time by updating our Privacy Policy page on our website. We encourage you to check our Privacy Policy from time to time on our website, as the version of our Privacy Policy which is displayed on our website takes precedence over all previous versions of our Privacy Policy. We will notify you of any changes to this Privacy Policy and obtain your consent, to the extent applicable and if required.

This Privacy Policy describes how we collect, use, and/or disclose Personal Data of the individuals performing work for us in the capacity of our agents, our brokers and/or other relevant individuals with whom we interact or we collect personal data via our agents or brokers and whose personal data we handle in the course of our businesses operation (together, “you”, “your” or “yours”, depending on the context).

Please read this Privacy Policy carefully to understand why and how we collect, use and/or disclose your Personal Data.

Part A – Personal Data we process

Personal and contact details: such as title, name, surname, maiden name, previous name, contact details (e.g. phone no., e-mail, and social media account identification), contact details history, date of birth, gender, age, nationality, citizenship, marital status, residency, family status, the number of dependents you have, signature, house registration address, contact address, working address, province, postal codes, country of birth, photo, skill and abilities, and voice or video record;
Government issued identification: such as national identification card, passport, household registration, tax identification and documents, other government-issued identification (e.g. green card identification), visa, work permit, and certificate of name change;
Financial details: such as bank account information, disbursement and payment information;
Employment/work details: such as educational history, work experience, and previous workplace;
Information about the performance of your duties and relationship with us: such as position, department, structure, branch, brokerage license information, agent license information, code name, referral code, status, staff ID, up-line, bank partner ID, insurance information (in case you apply for our insurance product) (e.g., policy number, coverage expected, coverage amount and period, product choice, premium payment, payment channel, proof of payment), monthly sales, sale incentive, training information, e-learning information, assessment of seller performance, rewards, blacklisting information, complaint, reporting information, suspicious transactions, investigation information, wrongful act, amount damaged, consequences for seller, power of attorney information from the application form;
Technical information: such as information required to access company systems and applications such electronic content and metadata produced by you using our systems, details such as your mobile phone location data, IP address and MAC address, browser and device information, log-in credentials, online usage, logs, Cookie ID, website visit data, and information collected through other technologies; and
Sensitive data: such as your religion and blood types (contained in national identification card or otherwise), health data, disability, criminal records, political status.

Part B - Personal Data of other persons

We may also collect Personal Data as specified in the above of other persons such as details of your family member, spouse, dependents, witness, and other person referred by you or other person in the course of your performance of duties and our relationship with agents and brokers.

If you provide Personal Data of others to us, you represent and warrant that you have the authority to do so by

1) informing such other person about this Privacy Policy;

2) obtaining consents where applicable or rely on other legal basis necessary to permit us to use such Personal Data in accordance to this Privacy Policy; and

3) undertaking to verify the accuracy and completeness of Personal Data provided by you and to update us of any change to the Personal Data provided.

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.

Part C - Where we get your Personal Data

We’ll collect Personal Data from the following general sources:

from you directly and other communications with us;
from our brokers or agents if you are a family member, reference person, recruiter, agent executives, and agents who wish to move under newly established GA, shareholders, directors;
Prudential Group companies; and
from other sources such as through our bank partners, service providers, your fellow agents or brokers, vendors, our Business Partners, affiliates, financial institutions, public/private sources (for example, telephone directory, social media, internet, news articles, databases), Fraud Prevention Agencies, other organizations to assist in prevention and detection of crime, police and law enforcement agencies, government authorities, courts and other third parties we work with to provide products and services or quote to you or to help improve our products and services or our business; and
from other sources such as publicly available sources, police and law enforcement agencies, government authorities, courts and other third parties.

Part D – Cookie Policy

Our Site uses cookies, beacon and similar technologies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you use the Site and also allows us to improve our Site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is stored on your computer's hard drive. When Cookies information directly or indirectly identifies an individual, whether alone or coupled with other information, we will treat such information as Personal Data under this Privacy Policy. 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.

If you decide not to have your personal data processed by us for advertising purposes via cookies (and similar technologies), this does not mean that we will not show you advertisements. It simply means these advertisements will not be personalized for you using first-party or third party cookies, web beacons or similar technologies.

We use the following types of cookies:

Strictly necessary cookies.These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into our secure Site;
Analytical/performance cookies.These allow us to recognize and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily; and
Functionality cookies.These are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

By continuing to use the Site, you accept to the use of cookies as outlined above.

Part E - How we use your Personal Data and why

We collect, use, and/or disclose your Personal Data on the legal basis of (1) contractual basis, for our initiation or fulfilment of a contractual performance with you or requested by you prior to engaging into a contractual performance with us; (2) legal obligation, for fulfilment of our legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and those of third parties, proportionate to your interest and fundamental rights and freedoms to the protection of your Personal Data; (4) public interest, for the performance of task carried out in the public interest or for exercising of official authorities or duties; (5) vital interest, for the prevention or suppression of danger to a person's life, body, or health; and/or (6) consent.

We will use the Personal Data you provide to us, together with other information, for the following purposes:

Identity verification: to conduct your identity verification when you apply to become our agent or broker, or when concluding agreements and transactions with you, to verify your login credentials, or to fulfil your request;
Performance of your duties as an agent or broker: to recruit you as an agent, to apply/register for, verify, or distribute agent license for you, to verify your brokerage licenses, to facilitate examination relating to agent and brokerage licenses, to revoke agent licenses, to execute agency or brokerage contract, to provide training for the license application or renewal, to provide training about our product and services, to facilitate the sales of our sales of products or services, to underwrite and issue insurance policy for the customers which comes through you, to reimburse expenses to you, to monitor your status and performance of duties, to provide feedbacks, and to report sales efficiency or monthly report;
Provision of incentives and benefits: for recognition/ motivation, to administer incentive contract, to provide commission, bonus, or sales incentives, to provide gifts, to quote and offer insurance product at special rate (as a benefit), to apply for VISA as a reward;
Complaint handling: to receive and analyze complaints or misconduct, plan investigation, impose disciplinary measures and blacklisting;
Business communications: to carry out communication with you in the course of your performance of duties and about our business, such as, responding to inquiries or requests;
Other internal business administration: to retain and update your information on record, to manage our infrastructure, work force and business operations (e.g., shifting positions or branch), auditing, finance, taxation accounting, billing and collections, business continuity and reporting, to perform our functions related to our businesses, to run random checking for recruitment or training process whether the procedure is followed;
Improve our general business operations, product and services: to provide campaign incentive, to design and develop insurance, financial and related products and services, to carry out surveys, data analytics, and market research including analysis of customer, to conduct internal analysis for improvement, to conduct research and statistical analysis (including use of new technologies), to assess and manage risks, to calculate commissions and service fees to you and our Business Partners;
Fraud Detection: to check your provided data against databases, to conduct due diligence, and/or any other form of background checks or screening or risk identification on you (including checking public/private information or government law enforcement agency), to carry out other security risk checks, to prevent fraud, money laundering, financing of terrorism, and crime;
Complying with any regulatory or other legal requirements: to comply with our legal obligations, rights or duties and/or legal proceeding under the applicable laws (e.g. those in relation to insurance, anti-money laundering, financing of terrorism and sanction screening), and laws outside your country of residence, to respond to investigation requests from public and governmental authorities, including for the benefit of supervision and promotion of insurance business according to the law on Insurance Commission and the law on life insurance. For more information on the Office of Insurance Commission’s privacy notice, which can be viewed at the website https://www.oic.or.th;
Corporate transactions: to transfer your Personal Data to one or more third parties, including companies, affiliates and subsidiaries, as part of the transaction in the event of merger such as, in sale, transfer, merger, reorganization or similar event;
Dispute handling: to solve disputes, to enforce our contracts, to establish, exercise or defense of legal claims and legal rights;
IT Management: to manage our internal and external IT operations, troubleshooting and communication system including IT security, IT security audit, and IT recordkeeping, to set system access authority, and to comply with our internal policies and procedures relating to IT; and
Protection of our interests and emergencies: to protect the health and safety of you and others, to allow and restrict access to our premises, to safeguard IT infrastructure, office equipment and other property.

Part F – Use of your sensitive Personal Data

We will only collect, use, or disclose sensitive Personal Data on the basis of your explicit consent, except for establishment, defense, compliance or exercise of legal claims, for satisfying legal obligations in relation to substantial public interest or where it is information that is disclosed to the public with the explicit consent from you or where otherwise as permitted by law. Where consent is required, we will separately ask for your consent via the appropriate methods.

For our business operation, we will need to process your sensitive Personal Data as described above, to the extent that we need your explicit consent to process this category of Personal Data, we will provide details of this at the point of collection and seek your consent.

Part G – Who we share your personal data with and why

We’ll share your Personal Data with Prudential Group companies, to our Business Partners, third party service providers, and governmental authorities. We are committed to protecting your privacy by restricting the access to your Personal Data on a need-to-know basis.

We may also make your Personal Data available to the following third parties, located both inside and outside of Thailand, who collect, use and/or disclose Personal Data for the purposes set forth under this Privacy Policy. For more information, you can visit their privacy policies to learn more about how they collect, use and/or disclose your Personal Data:

Our Business Partners

We may disclose your Personal Data to the Business Partners as defined below for the purposes as listed in Part E.

Governmental Authorities and Third Parties involved in Court Action

We may also disclose your Personal Data to governmental, regulatory or other public authorities in Thailand and overseas as applicable (including, but not limited to the Office of Insurance Commission, Revenue Department, Anti-Money Laundering Office, Securities and Exchange Commission, Legal Execution Department, National Police Bureau, National Anti-Corruption Commission, Personal Data Protection Committee, and/or any other law enforcement authorities, and courts); and third-party participants in legal procedures or other third party if we believe to be necessary or appropriate to comply with our legal obligations, defend legal rights or positions of us or otherwise the rights of any third party or individuals’ personal safety, and allow us to pursue available remedies or limit our damages.

Assignee of Rights and/or Obligations

In a normal course of business, we may disclose your Personal Data to third parties as our assignee, in the event of any reorganization, merger, amalgamation, business transfer, whether in whole or in part, sale, purchase, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock or similar transaction. We take reasonable steps to ensure that such third party will comply with this Privacy Policy to respect your Personal Data.

Other Third Parties

We may share your Personal Data with beneficiaries, industry associations (such as Thai Life Assurance Association), or for the protection of your own interest in case of emergency.

Part H – International transfer of Personal Data

We may transfer your Personal data to third parties, such as Prudential Group companies, service providers, and governmental or public authorities located in other countries (including, but not limited to Singapore, Hong Kong, India, United States, United Kingdom, Australia, Germany, Japan, Indonesia, the Netherlands, Malaysia) in order to carry out the purposes specified above. Where there is such a transfer, it will be done based on your consent or other bases in compliance with the applicable laws.

To the extent we transfer your Personal Data to a country with a level of data protection standards not equivalent to Thailand, we will ensure that an adequate degree of protection is afforded to the transferred Personal Data, or the transfer is otherwise permitted in accordance with the applicable data protection law.

We will use appropriate safeguards and comply with the laws of the country to which your Personal Data is transferred. Details of the safeguards we use are available on request.

Part I – We keep your Personal Data for a set amount of time

Your Personal Data will be stored for the period necessary to allow us to fulfil, satisfy or achieve the purposes specified in Part E above except where a longer retention period is required or permitted by law or as long as you are our agent or broker and for a period of ten years after the end of your relationship with us, or longer if required by law or to satisfy the purposes specified in Part E above, or to be in line with our internal policies on data retention. However, the retention period for Personal Data will be in accordance with our internal policy and procedure. There may be specific circumstances where it is necessary for us to retain your Personal Data for longer (such as when a dispute arises).

Part J – Minor, Incompetent person, and quasi-incompetent person

As required by law in certain cases, we cannot collect, use, and/or disclose the Personal Data of minors, quasi-incompetent persons, and incompetent persons in absence of their parental or legal guardian consents, unless otherwise permitted by law. We do not intend to collect Personal Data of minors, quasi-incompetent persons, or incompetent persons. Where we learn that we have unintentionally collected Personal Data from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent persons and incompetent persons without consent of their legal guardians, we will delete it immediately or process only if we can rely on other legal bases apart from consent.

Part K – You’re in control

Subject to the provisions of data protection law, you may have a number of rights regarding the collection, use, disclosure and/or transfer of your Personal Data, including:

Access: you can request a copy of your Personal Data (we have the right to charge a reasonable fee to complete this request where permitted by law);
Rectify: you can request that we correct anything that’s wrong, or complete any incomplete Personal Data;
Lodge a complaint: you can complain to a data protection authority or the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law where applicable. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance.
Deletion: you can ask us to delete your Personal Data if it is no longer needed for the purposes set out in this Privacy Policy or if there is no other legal basis for the processing;
Objection: you can object to the use of your Personal Data for direct marketing (including related profiling) or other processing based on legitimate interests;
Data Portability: you can request that provide a copy of your Personal Data in a structured and commonly used format in certain circumstances;
Restriction: you can limit how we use your Personal Data in certain circumstances; and
Withdraw Consent: you have the right to withdraw your consents you have given for the processing of your Personal Data any time.

The withdrawal of consent will not affect the lawfulness of the collection, use and/or disclosure of your personal data and sensitive data based on your consent before it was withdrawn. If you do not provide (or withdraw) your consent which is necessary, we may not be able to enter into a contract with you, perform our contractual obligations, carry out activities relating to your role as agent or broker or comply with the laws to which we and/or you are obligated.

Your request for exercising any of the above rights may be limited by the laws. There may be certain cases where we can reasonably and lawfully decline your request, for example, due to our legal obligation or court order.

If you want to exercise your rights, or would like an explanation about these rights, we’ve explained how you can get in touch in the Contact us section. We will consider your request and inform you of our response within 30 days from the date we receive your request, unless we require additional time to process your request as permitted by law and in which case we will inform you of required extended period.

If you do need to speak to us, the data controller of your Personal Data is Prudential Life Assurance (Thailand) Public Company Limited. 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.

Contact us

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

Write to us at:
Agency Operation & Licensing 29^th Floor

Or directly contact us at our headquarter at:
Prudential Life Assurance (Thailand) Public Company Limited
944 Mitrtown Office Tower, 10th, 29th – 31st Floor
Rama 4 Road, Wangmai, Pathumwan,
Bangkok, 10330

Email us at:
hotline@prudential.co.th

The Prudential Group means affiliates of Prudential UK (including Prudential International Assurance plc, Prudential plc, Prudential Services Limited, PGDS (UK ONE) Limited, Prudential Global Services Private Limited, Prudential Corporation Asia Limited, M&G Investments Group and Prudential Corporate Pensions Trustee Limited, Prudential Services Asia Sdn. Bhd., Pulse Ecosystem Pte. Ltd., Prudential Services Singapore Pte. Ltd., Africa Prudential plc.).

Business Partners means the following:

business partners: e.g., our bank and other partners, other agents, asset management companies;
service providers: e.g., service providers who provide administrative, telecommunications, computer, information technology, data processing and storage, customer satisfaction analysis, payment, printing and logistics, redemption, call center service, emergency service, support and hosting service, training service, claim facilitation, IT service and platform service, data management service, data storage and cloud service, smart underwriting provider, advertising, marketing and market research and analysis service, or other services to us to enable us to operate our business, including other third-party vendors, suppliers and other outsourced service providers that assist us in carrying out business activities;
others: e.g., professional advisors who may have access to your Personal Data, including medical professionals, accountants, actuaries, auditors, lawyers, legal advisors, and other outside professional advisors, insurance intermediaries, reinsurers, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, insurers, trustees, medical bill review companies, claims investigations companies, credit card companies, banks and financial institutions who administer our accounts, researchers, third party administrators, credit reference agencies, travel agencies, financial crime prevention agencies, debt collection agencies.