Sun Life Philippines’ Online Privacy Statement
Your privacy is important to us. We want you to understand how we safeguard your personal information and what types of information we receive and collect when you visit our websites.
Personal information and online security
When you visit a Sun Life website, you are anonymous unless you choose to identify yourself. You are not required to provide personal information to use our websites, unless a feature requires it. For example, if you have a policy or contract with us and wish to access your account online, you will need to provide identifying information. In these cases, we have physical, electronic and procedural safeguards in place to help protect your online personal information from unauthorized use or improper access. These safeguards may include:
Passwords and personal identification numbers (PINs): Clients can access their account information online only after providing identifying information and a password or PIN. This information is unique to you, and is an important first step in protecting your information online.
128-bit encryption: Sun Life Financial uses a Secure Sockets Layer (SSL) protocol to protect personal information transmitted to us electronically. SSL transmitted information is encrypted, or scrambled, to prevent unauthorized reading of the electronic communication.
Although we have physical, electronic and procedural safeguards that we believe are adequate to protect personal information, any such systems may be subject to human and operational error. In particular, because the Internet is an open system, we cannot and do not guarantee that personal information entered by you online will not be misappropriated, intercepted, modified, deleted or used by others.
Online data collection tools: Improving and evaluating website functionality and effectiveness
Sun Life, like many organizations, sometimes gathers data, such as your IP address, regarding how visitors explore our websites - information about the number of new and repeat visitors, where on the website a visitor explores, how long they visit, where they are geographically located and similar details. We may also track how many users visit advertisements promoting our products and services that appear on other company websites. All such information is collected in an unidentifiable form and is used to improve our websites' performance and functionality, create a better experience for our visitors, measure the response to web marketing campaigns and provide you with more relevant content based on your possible interests in Sun Life content, products and services.
What are cookies and web beacons?
A cookie is a small piece of information that a website sends to your computer where it is stored on your hard drive. The next time you visit our website, we may use the information stored on your cookie to make your visit easier. A cookie does not tell us your identity unless you have chosen to provide it to us. Cookies cannot access other information or files from your computer. There are 2 types of cookies - session cookies and permanent or persistent cookies.
A session cookie (sometimes called a "transient" cookie) is erased when you close your Internet browser and leave our website. In the United Kingdom, only session cookies are used.
A "permanent" cookie is a file that remains on your computer when you close your Internet browser. A permanent cookie can be read only by the website that created the cookie when you revisit that site. Permanent cookies are not used in all of our jurisdictions.
Cookies can identify a visitor only if the visitor has used a website's login feature. If you ask us to save your access ID to be used the next time you visit our website, we will use a permanent cookie to store your access ID in an encrypted format on your computer so that the next time you visit the website you will be recognized when you sign in. In this way, the website can recall your preferences and provide a more customized experience.
Permanent cookies have expiry dates and are automatically deleted from your computer after their expiry date. You can also clear your stored cookies via your browser preferences on your computer. However, unless you have settings that disallow cookies, the next time you visit our website, a new cookie will be added. You can set your website browser to notify you when you receive a cookie so that you can decide whether to accept or reject it. Since the procedure for altering preferences varies by browser you should check the "Help" menu of your browser to learn how to alter your cookie preferences. Please note, however, that rejecting cookies while visiting a Sun Life website may result in certain parts of the website not functioning correctly or as efficiently as if cookies were allowed.
The permanent cookies that may be placed on your computer by the Google Display Network relating to web marketing campaigns are used to increase the relevance of display ads you may see when you visit other websites that are serviced by the Google Display Network. To opt out of these cookies, select the opt out button on the Google Privacy Centre page.
Web beacons are a collective term used to refer to "pixel tags", "web beacons" or "clear GIF images" embedded in a web page and usually invisible to the user. Web beacons are used for many of the same purposes as cookies, allowing Sun Life or its agents on behalf of Sun Life to compile aggregate statistics about website usage patterns, such as how many times a link or an area on a website is clicked. All the information collected by any of these online tracking tools is non-personal and is not used in connection with any other information that could identify you personally unless you have entered your access ID and password or provided it to us through your permanent cookie.
We may share the site visit information obtained using cookies, web beacons and other similar technologies with Google Analytics or other agents to analyze online activity on our websites or in reaction to our online advertisements.
At this time, SLF U.S. does not alter its behaviour or change its services upon receiving Do Not Track requests, as described in California Assembly Bill 370.
Links to websites outside of Sun Life
To provide website visitors with more information that may be helpful to them, some of our websites contain links to other websites that are not affiliated with or maintained by Sun Life. We do not monitor the privacy practices of these third-party sites, and do not have authority over them. As a result, we do not assume any responsibility for the data collection policies and procedures of these sites.
Collection of personal information from children
Sun Life websites are not directed at children. Our member company websites do not knowingly collect information from children under the age of 18.
Please be aware that we may update and modify this online privacy statement at any time. Please review this section each time you access and/or use our websites.
Sun Life is committed to protecting the privacy of all personal information provided to us. Using this information properly is at the root of our success; it provides us with insight to deliver the right products and services to you at the right time and in the right way. We have a long history of protecting personal information.
Our privacy commitment applies to all of our wholly owned subsidiaries and branch operations worldwide.
Our privacy commitment is about more than complying with applicable country privacy laws; it is about doing the right thing for the millions of people whose lives we touch every day through the use of their personal information, however collected or received by us. The following principles reflect our commitment to safeguarding personal information in our care:
- We keep your personal information and the business you do with us in strict confidence.
- We collect, use or disclose personal information from you only to provide you with financial and insurance products and services to help you meet your lifetime needs.
- We obtain personal information about you lawfully and fairly.
- We do not disclose personal information without your permission except where permitted or required by law or competent authority. But we may share personal information with our agents, service providers or, where permitted by law, our affiliates in connection with providing, administering and servicing our products and services on our behalf.
- Where we choose to have certain services, such as data processing, provided by third party agents or service providers on our behalf, we do so in accordance with applicable law. In some cases, we may transfer your personal information to our employees, service providers or agents located in countries other than where the information was provided.
- We are responsible for all personal information in our possession, including information transferred to third parties performing services on our behalf. All such persons, wherever they are located, are required by us to protect the confidentiality of your personal information in a manner consistent with our privacy policies and practices.
- We maintain appropriate procedures to ensure that personal information in our possession is accurate and, where necessary, kept up to date. To the extent required by applicable law, you may seek a correction of your personal information if you believe that the information we have is not accurate.
- We try to respond to requests for access to - or correction of - personal information as soon as reasonably possible. In circumstances where the law does not entitle you to access, we will explain why access is denied.
- We maintain technical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. We limit access to those who have a business need to know.
Sun Life Financial has physical, electronic and procedural safeguards to help protect personal information provided through online transactions and activities. Read more about the methods we use to help protect your information online.
Local privacy policies and codes
We are an international provider of financial products and services, operating in many countries around the world. In some countries in which we do business, this privacy commitment is supplemented by more detailed privacy policies or codes specific to the requirements of those countries. When you access or link to a local Sun Life website, read the privacy statement found on the local website to determine any local policies or codes that apply to your information in that region.
Our Chief Privacy Officer for the enterprise is located at our corporate head office in Toronto, Canada, and we have privacy officers in each region where we do business. If you have any questions, concerns or complaints about protection of your personal information at Sun Life, contact a local privacy officer in your region:
Sun Life may update or modify this privacy commitment from time to time.
Philippine privacy statement
Sun Life recognizes and values your data privacy rights. We seek to uphold them in accordance with the law.
In this Statement…
Personal data refers to any information that identifies you as a person. As defined by the Philippine Data Privacy Act of 2012, this may be “sensitive personal information.”
Data privacy refers to the necessity to preserve and protect any personal data collected by an organization from being accessed by a third party.
Sun Life refers to the Sun Life group of companies in the Philippines, including:
- Sun Life of Canada (Philippines), Inc., which offers life insurance products
- Sun Life Asset Management Company, Inc., which manages and distributes the Sun Life Prosperity Funds; and
- Sun Life Financial Plans, Inc., which administers the company's education and pension plans.
YOUR DATA PRIVACY RIGHTS
Your data privacy rights are protected by the Philippine Data Privacy Act of 2012. This law states that you have the right to:
- Be informed. You must be advised if your personal data will be or has been processed. This includes the existence of automated decision-making and profiling in select transactions.
- Access. You have the right to reasonable access, upon written request, the contents of your personal data that were processed and the manner by which these were processed; the sources from which these were obtained; the recipients and reasons for disclosure, if any; date when your information was last modified; and information on automated processes where your information will be made as the sole basis for any decision that may significantly affect you.
- Rectify incorrect data. You have the right to correct any error in your personal data and, if warranted, request immediate rectification.
- Erase or block. You have, based on reasonable grounds, the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from Sun Life's filing system, without prejudice to Sun Life continuing to process personal data for commercial, operational, legal and regulatory purposes.
- Secure data portability. Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of it from Sun Life for your further use.
- Be compensated for damages. You shall be compensated for any damage sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms.
- File a complaint. You may file a complaint or exercise your rights above by reaching out to our Data Protection Officer in the contact details provided below.
WHAT PERSONAL DATA WE COLLECT
At Sun Life, we ask you for your personal data when you:
- Apply for an insurance policy
- Invest in any of our mutual funds
- Use our websites, applications or facilities
- Pay your premiums
- File for claims
- Take part in research or surveys
- Join our events
- Become our partner, vendor, supplier, employee or contractor
The personal data we collect from you may include the following:
- Name, age, sex, civil status, date and place of birth, nationality and/or citizenship, address, and contact details
- Employment or business information, and source of funds/property, wealth, and income
- Medical information
- Financial position and objectives, income, and investible assets
- Payment card number or bank account details
- Government-issued identification numbers [e.g., Passport, Tax Identification Number (TIN), Social Security System (SSS) or Government Service Insurance System GSIS) Numbers]
- Beneficiaries’ information
- Other information that you have directly provided us
We may also ask for personal data from other sources whom you have permitted to share your information with us. These sources may include your financial advisor, other insurers, reinsurers or distribution partners, the Medical Information Database, credit bureaus or aggregation agencies, government and other regulatory bodies, and other third parties.
There may be cases where third parties send us personal information even without us requesting. In such cases, we will determine if we can legally keep the information and use it for the declared purpose.
WHERE WE USE YOUR PERSONAL DATA
We process your personal data based on your consent, legitimate business interest, and lawful processing. We use it only for:
- Processing and underwriting (both medical and financial) applications for financial and insurance products and services;
- Providing, administering, and servicing our products and services to help you meet your needs, including for purposes of improving/upgrading our systems and business processes or appointing third party vendors;
- Assessing your suitability for products and services, including conducting data analytics, market research, and surveys to offer you better products and services;
- Settling claims under your insurance or investment plan with any person or organization, who has relevant information about you, which includes institutions, investigative agencies, insurers, and reinsurers;
- Complying with applicable laws, regulations, directives, issuances by, or agreements and obligations of Sun Life to any competent authority, regulator, supervisory body, enforcement agency, exchange, court, quasi-judicial body, or tribunal;
- Identifying, investigating, and preventing financial crimes, including fraud, bribery, money laundering and terrorist financing, including but not limited to submitting reports to the Anti-Money Laundering Commission (AMLC) and other regulators;
- Enhancing risk assessment and preventing fraud, including but not limited to uploading medical information in the Medical Information Database, in line with the Insurance Commission's (IC) Circular Letter No. 2016-54;
- Enforcing and/or defending the rights of Sun Life before any agency, court, tribunal, quasi-judicial body;
- Recognizing other lawful or legitimate commercial or business purposes necessary for the performance of, or in relation to, a contract or service in which you are part of
- When necessary or desirable in the context of an employer-employee relationship; and
- Enabling Sun Life to manage its businesses and ensuring that we are able to identify, measure, manage, and mitigate any risk that may come up.
We may use your information for other purposes necessary to provide insurance, investment, and other incidental services in line with your transactions.
When using your data, we may utilize manual and/or technology-enabled data processing systems to help us serve you, including underwriting, profiling, orphan policy handling, finance-related functions, letter preparation and printing, email and call validation, and other processes.
Meanwhile, partnerships and corporate entities that Sun Life works with are expected to:
- Advise concerned people of the purpose/s of collecting personal data, including other relevant information and disclosure of the said data to Sun Life
- Inform them of their data privacy rights; and
- Obtain the necessary consent and authority to disclose personal data of its directors, officers, employees, members, and other representatives to Sun Life, as mandated by the Data Privacy Act of 2012, its Implementing Rules and Regulations, and other applicable laws and regulations.
HOW WE PROTECT YOUR PERSONAL DATA
Sun Life keeps your personal data in paper-based files and electronic records. While the processing of your personal data exposes you to financial, legal, regulatory, or reputational risks that may result from its unauthorized processing or disclosure, Sun Life is committed to protecting your privacy by:
- Maintaining physical, technical, and organizational safeguards to protect your personal data against loss, theft, unauthorized access, disclosure, copying, use, or modification
- Using a secured server behind a firewall, encryption, and other secured controls
- Limiting access on a need-to-know basis.
Sun Life takes responsibility for all your personal data in our possession. This includes information transferred to third parties who perform services on our behalf, whom we require to strictly adhere to our privacy policies and practices.
PERSONAL DATA SHARING AND DISCLOSURE
We may disclose and share your personal data based on your consent, legitimate business interest, and lawful processing, to the following parties:
- Any member of the Sun Life Group here and abroad, its directors, officers, employees, duly authorized representatives, related companies, affiliates, financial advisors, and mutual fund representatives;
- Third party service providers and vendors including encoding, printing and courier services; credit card processors; IT software providers; hosting vendors; partner doctors, hospitals and medical facilities; and customer support providers who are obliged to keep your personal data confidential. They will have access to your personal data only as necessary to perform their requested function on your behalf, and only if their security and privacy standards are acceptable to Sun Life;
- Business partners who help us market and distribute our products and services;
- The Medical Information Database administered by the Philippine Life Insurance Association (PLIA) and accessible to life insurance companies, for purposes allowed under Insurance Commission (IC) Circular Letter No. 2016-54, loan database administered by the Credit Information Corporation and other databases administered by similar agencies;
- Any authority, regulator, supervisory, enforcement agency, exchange, court, quasi-judicial body or tribunal;
- Reinsurers and professional advisers including accounting, tax, financial or legal counsel; or
- Anyone we consider necessary for purposes of providing you products and services and other lawful purposes mentioned above.
PERSONAL DATA RETENTION
Your personal data will be retained by Sun Life throughout the duration of your plan, investment, or account and/or until the expiration of the retention limit set by Sun Life standards, industry standards, laws and regulations. This period will be counted from account closure and will be set until destruction, disposal or anonymization of records, unless withdrawn in writing or withheld due to changes in the information supplied by the Company.
HOW TO CONTACT US
Address: Sun Life of Canada (Philippines), Inc.
2nd Floor, Sun Life Centre, 5th Avenue corner Rizal Drive
Bonifacio Global City, Taguig City 1634
Client Care Hotline: 8849-9888
Toll-free number via a PLDT line: 1-800-10-SUNLIFE (1-800-10-7865433)
Email address: firstname.lastname@example.org
Business hours: 8 AM to 7 PM, Mondays to Fridays
Sun Life offers products and services that can help you achieve lifetime financial security and live a healthier life. If you wish to receive marketing or promotional information, please feel free to send us an email or call us.
If you have questions about this Privacy Statement, our data processing activities or your dealings with this web site, you can contact the Data Privacy Officer by telephone at (632) 8849-9558 or send us an email at email@example.com. You may also email us at firstname.lastname@example.org, or call our Client Care, SUNLINK, at telephone no. 8849-9888. If you are calling from the province, you may call us using our toll-free at 1-800-10-SUNLIFE (1-800-10-7865433) from any PLDT line. Our business hours are from 8:00 AM to 7:00 PM, Mondays to Fridays.