It also explains certain legal rights you have in connection with your personal information which is handled by Charles Monat. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by Charles Monat, if any.
1. Who at Charles Monat is responsible for my personal information?
Charles Monat is one of the most trusted international life insurance brokers, offering bespoke advisory and brokerage services. The particular Charles Monat company who is responsible for the handling of your personal information in connection with the services provided by Charles Monat will vary depending on geographical location, and can include:
Charles Monat Associates AG, Fraumünsterstrasse 27, 8001 Zürich, Switzerland (Company No. CHE-469.487.855), in respect of services provided by Charles Monat in or from Switzerland;
Charles Monat Associates Limited, 12/F, St. George’s Building, 2 Ice House Street, Hong Kong (BR No. 06596473) in respect of services provided by Charles Monat in or from Hong Kong;
Charles Monat Associates Pte Ltd, 80 Raffles Place #26-01/02 and 06, UOB Plaza 1, Singapore 048624 (Company No. 200405282G) in respect of services provided by Charles Monat in or from Singapore;
Charles Monat Associates LLC, 701 Brickell Avenue, Ste. #1550, Miami, Florida 33131, USA (Company No. 1023238), if services are provided by Charles Monat in or from the USA;.
Charles Monat Agency Limited, 12/F, St. George’s Building, 2 Ice House Street, Hong Kong (BR No. 516122) in respect of agency services provided by Charles Monat in or from Hong Kong;
Charles Monat Associates Limited, Unit 37-2 Level 37, Q Sentral No. 2A, Jalan Stesen, Kuala Lumpur Sentral, Kuala Lumpur 50470, Malaysia (Company No. LL15206) in respect of services provided by Charles Monat in or from Malaysia;
Charles Monat Associates Limited, Office 603, Level 6, Gate District 5, DIFC, P.O. Box 507269, Dubai (Company No. 3197), in respect of services provided by Charles Monat in or from the Dubai International Financial Centre.
Furthermore, some of the personal data can also be processed at the holding entities in the Charles Monat group, being Charles Monat Limited (12/F, St. George’s Building, 2 Ice House Street, Hong Kong, BR No. 55184) and Monat Global Wealth Pte. Ltd. (80 Raffles Place #26-01/02 and 06, UOB Plaza 1, Singapore 048624, Company No. 201711561D), the registered address of Charles Monat Associates LLC (191 Union Street, Holden, MA 01520, USA), the registered address of Charles Monat Associates Limited Malaysia (Brumby Centre, Lot 42, Jalan Muhibbah, 87000 Labuan F.T., Malaysia) or the co-office of Charles Monat Associates Limited Malaysia (Suite 4-5-2, Unit 4-5, Level 4, Shoplots, Labuan Times Square, Labuan F.T., Malaysia).
2. How does Charles Monat obtain my personal information?
Except where you approach Charles Monat directly, your basic personal information such as your name and contact details was provided to Charles Monat by third parties who have obtained your consent for the provision of your basic personal information to Charles Monat and have referred you to Charles Monat (e.g. your bank or your financial advisor).
Charles Monat will then collect additional personal information directly from you, and also from a variety of sources who have obtained your consent, such as the doctor who conducts your medical examination, credit reference agencies, publicly accessible registers and databases, your bank, your employer, etc.
Charles Monat may also collect, use and disclose personal data without consent if permitted or required by the applicable laws (such as when the processing of your personal data is necessary for the performance of a contract). It is not mandatory for you to provide all of the personal information Charles Monat asks you to provide, but if you refuse to provide your personal information, your refusal may restrict the availability of insurance that can be placed through the services provided by Charles Monat, or otherwise adversely affect the ability of Charles Monat to provide its services in a timely and satisfactory manner.
3. What personal information about me does Charles Monat collect?
Charles Monat collects such personal information relating to you which are necessary in order to provide the services which you request, services which you did not personally request but are to be arranged for your benefit upon your instruction or for the other purposes mentioned below. The exact nature and amount of information collected will vary depending on your personal circumstances, but will typically include the following categories of personal information:
Your name, address, contact details, gender, date/place of birth, marital status, nationality, country of residence, family composition, dependents, occupation, hobbies, habits, and other like demographic information.
Your identifiers such as bank account numbers, social security number, passport number, etc.
Information about your finances, such as details of your incomes, assets, investments, debts, credit-worthiness, existing insurance arrangements, etc.
Information about your physical and mental health, including your medical history.
Other information which Charles Monat is obliged to obtain or check for legal or regulatory reasons, or Charles Monat needs to obtain in order to enable the insurers to provide you with quotation (which may include personal information of sensitive nature such as any criminal records).
Charles Monat will follow appropriate processes and make reasonable effort to accurately record in its system the personal data provided by you or by any other party validly acting on your behalf. Charles Monat generally relies on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please inform the relevant Charles Monat company if there are changes to your personal data (such as when you have a new email address or telephone number) by contacting us via the contact details provided below and this in a timely, legible and complete manner.
4. Why does Charles Monat collect my personal information?
Charles Monat collects, processes, modifies, retains and discloses your personal information primarily to provide the services which you request, or services which you did not personally request but is to be arranged for your benefit upon your instruction.
Other related purposes for which Charles Monat collects, processes, and retains your personal information are as follows:
Complying with legal and regulatory requirements imposed on Charles Monat in connection with services provided by Charles Monat (such as the Anti-Money Laundering rules and other due diligence requirements, in the context of claims).
Improving or developing the services Charles Monat provides, including the use of our website.
Enabling us to assess your requirements, enabling insurers to provide quotations and to administer insurance policies in accordance with your requirements (including periodic assessment of your profile and portfolio, specific advice and the handling of any claim that might be made under an insurance policy).
Enabling other third parties who are involved in services provided by Charles Monat or provide other services that augment the services provided by Charles Monat (e.g. other intermediaries, medical practitioners, premium finance providers, IT support providers, etc.) to perform their relevant tasks.
Additionally, Charles Monat may also use your personal information to create aggregated and anonymized statistics to analyse, for example, the market trend for insurance-related products and services. The outcome of such analysis will be used to improve the products and services Charles Monat offers, and may also be shared with third parties. However, under no circumstance will any specific personal information relating to you or any information from which you could be identified be included in such analysis. Charles Monat does not make decisions based solely on automated processing, including profiling. Charles Monat will not use your personal information for marketing purposes. The purposes listed in the above clauses may continue to apply even in situations where your relationship with Charles Monat has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Charles Monat will never use your personal information for any purpose other than as described above without your prior written approval (except where permitted or authorised by law).
Charles Monat doesn’t make decisions based solely on automated processing, including profiling.
5. Does Charles Monat share my personal information with third parties?
Charles Monat may share your personal information with the following third parties:
- Other members of the Charles Monat companies that are directly or indirectly involved in the delivery of services provided by the relevant Charles Monat entity, including those that support the IT systems and operational processes that underpin the services provided by Charles Monat. Please note that in order to provide you with a seamless service, different offices of Charles Monat may access your personal information regardless of the country in which you have engaged Charles Monat, but if you engage Charles Monat in Switzerland, Charles Monat’s Miami office will not access your personal information unless you wish to be serviced by Charles Monat’s Miami office and have instructed us to this effect.
- Those who are not affiliated with Charles Monat, but nevertheless interact with Charles Monat to facilitate the services provided by Charles Monat or provide other services that augment the services provided by Charles Monat, such as insurers, IT-providers, storage or telecommunications providers, other intermediaries, medical practitioners, third parties (e.g. banks) that have referred you to Charles Monat, premium finance provider (which could be different from your own bank), those who provide support services to Charles Monat, and your professional advisors. These third party service providers who may also share data within their group companies & third parties like reinsurer & other service providers. These third-party service providers have access to personal information needed to perform their functions but may not use it for other purposes. Further, they must process that information in accordance with this Policy and as permitted by applicable data protection law.
- Those with whom Charles Monat is, for legal and regulatory reasons, obliged to share your personal information, including government agencies, regulatory and law enforcement bodies, tax and monetary authorities, and operators of fraud database. Please note that where Charles Monat is legally obliged to share your personal information with such third parties, Charles Monat may be forbidden from advising you of that fact that your personal information was disclosed to or requested by such third parties. In particular, please note that if you are a US citizen or US resident, Charles Monat and/or your insurer may be required to share your personal information with the US authorities under the US Foreign Account Tax Compliance Act.
In all other cases, Charles Monat will not share your personal information with other third parties without your prior written approval and where any other third party requests access to your personal information, Charles Monat will not comply with such request without your prior written approval, unless Charles Monat is legally compelled to do so (e.g. by a court order) or allowed to do so by law.
If Charles Monat is involved in a merger, acquisition or sale of all or a portion of its assets, your personal data may be transferred to the acquiring person or entity and you will be notified via email and/or a prominent notice on our website of any change in ownership or use of your personal data, as well as any choices you may have regarding your personal data.
Some of such third parties may be located outside the country of incorporation of the relevant Charles Monat company (see below).
Whenever Charles Monat transfers your personal information to third parties, appropriate steps and safeguards will be taken.
6. Does Charles Monat transfer my personal information overseas?
Due to the international nature of the services Charles Monat provides and the way in which Charles Monat operates, you agree that Charles Monat needs to transfer your personal information across international borders to a destination where the law governing the protection of your personal information may not be equivalent to the law that applies in your country of residence or the country in which the collection of your personal information takes place. Where this is the case, Charles Monat have put in place appropriate measures with the recipient to protect your personal information in accordance with this policy. Specifically, you agree that your personal information may be transferred or accessed across international borders by Charles Monat as follows:
If you engage Charles Monat outside Switzerland, Charles Monat will provide services to you from its offices in Hong Kong, Singapore, Malaysia, Dubai International Financial Centre, Miami, Labuan and Zurich, as appropriate, using IT systems that are hosted and maintained by Charles Monat companies in Hong Kong and Singapore. Your personal information held on Charles Monat’s IT systems will be accessible by an external service provider in Singapore (who supports the maintenance of Charles Monat’s IT systems). Therefore, your personal information could be: (a) transferred to Hong Kong, Labuan, Singapore, Switzerland and USA; and (b) accessed from Singapore.
If you engage Charles Monat in Switzerland, Charles Monat will provide services to you from its offices in Hong Kong, Singapore, and Zurich, as appropriate, using IT systems that are hosted and maintained by Charles Monat companies in Hong Kong and Singapore. Your personal information held on Charles Monat’s IT systems will be accessible by an external service provider in Singapore (who supports the maintenance of Charles Monat’s IT systems). Therefore, your personal information could be: (a) transferred to Hong Kong, Singapore and Switzerland; and (b) accessed from Singapore. Please note that you have the option to receive your services from Charles Monat’s Miami office, but unless you specifically request, Charles Monat will not involve its Miami office in providing its services to you (which will result in your personal information being transferred to USA).
Regardless of the country in which you engage Charles Monat, it may be necessary for Charles Monat to share your personal information with recipients other than other Charles Monat companies who are based overseas. This will typically be the case where Charles Monat approaches an insurer that operates internationally to arrange insurance for you. The location of such insurer will vary depending on the particular markets and insurers used. Please note that if you wish to obtain a policy issued by a US-based insurer, your personal information will need to be transferred to the USA regardless of the country in which you have engaged Charles Monat.
Whenever Charles Monat transfers your personal information across international borders, appropriate steps and safeguards that are within Charles Monat’s control will be taken to ensure that such transfer complies with the applicable legal requirements.
7. Is my personal information secure?
Charles Monat treats information security seriously. The secrecy and confidentiality of your personal information under Charles Monat’s control will be protected in accordance with strict standards set by information security framework which applies to all members of the Charles Monat companies and is enforced by a dedicated team of experienced experts. Encryption, anti-malware, firewalls, restriction of access to files/premises/IT systems, back-up/disaster recovery system, careful selection of personnel as well as relevant third party service providers, internal policies, processes and procedures to restrict access to systems and personal data on a need-to-know basis and other technical and organizational measures as appropriate will be used to prevent and detect unauthorized or accidental access, loss, collection, copying, modification, disclosure, destruction, damage, or other like incident that might affect your personal information, regardless of whether your personal data is held physically or electronically.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, Charles Monat strives to protect the security of your information and are constantly reviewing and enhancing our information security measures.
8. Retention of my personal information
Charles Monat shall cease to retain the documents containing personal data or remove the means by which the personal data can be associated with particular individuals as soon as it is reasonable to assume that (a) the purpose for which the personal data was collected is no longer being served by retention of the personal data; and (b) retention is no longer necessary for legal or business purposes depending on the applicable laws.
9. Your rights
A. Right of access, right to rectification and right to erasure
You have the right to access your personal information held by Charles Monat, and to ask Charles Monat to correct where it is inaccurate or out-of-date or delete your personal information in cases where no other legal restrictions exist.
Note that Charles Monat might not be required to give you access to or correct or delete your personal data following the applicable laws. If Charles Monat is unable to provide you with any personal data or to make a correction or deletion requested by you, Charles Monat shall generally inform you of the reasons why it is unable to do so (except where it is not required to do so under the applicable laws).
Please note that depending on the request that is being made, Charles Monat will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves.
B. Withdrawal of consent
You may at any time withdraw any consent given or deemed to have been given in respect of the collection, use or disclosure by Charles Monat. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Charles Monat will notify you of the consequences of it acceding to the same, including any legal consequences which may affect your rights and liabilities to Charles Monat.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
C. Right to restriction of processing
You have the right to obtain from Charles Monat restriction of processing following the applicable laws e.g. whilst complaints are solved.
D. Right to object
You have the right to object at any time to the processing of your personal data in line with the applicable laws. Charles Monat shall in that case no longer process your personal data unless it has legitimate grounds to do so following the applicable laws.
E. Data portability
You have the right to have your personal data transmitted to you or another data controller in a commonly used machine-readable format.
Charles Monat will respond to requests or questions as soon as reasonably possible and as required by the applicable law. Please be aware that exercising some of these rights may mean that Charles Monat will be unable to provide its services to you because it concerns information that is essential to Charles Monat being able to do so.
The information shall be provided free of charge, unless the requests are manifestly unfounded or excessive and provided the applicable law allows it.
For the protection of your personal data, Charles Monat will need to verify your identity before processing your request. Charles Monat will verify your identity by, for example, asking to look at relevant identification documents. If Charles Monat is unable to verify your identity, you will not be provided access to your personal data.
Our website might include links to other websites whose privacy practices may differ from those of Charles Monat. If you submit information to any of those sites, your information is governed by their privacy policies.
You always have the right to lodge a complaint with the relevant supervisory authority.