WHO WE ARE

We are the operations of Pacific Life Re International Limited which are based in Asia (including Southeast Asia, China, Taiwan, and Japan). References to “we”, “our” and “us” in this Privacy Notice include the Asian operations of Pacific Life Re International Limited.

WHAT WE DO

We provide reinsurance to the insurance companies who have issued the policies under which you are covered. Reinsurance is insurance for insurers. It allows the insurers to reduce their potential losses by insuring some, or all of the risk related to the underlying policies with its policyholders. Reinsurers may also insure some or all of the risks they take on from insurers. These arrangements are known as retrocession and the companies providing insurance to reinsurers are called retrocessionaires. These arrangements spread risks across a number of companies which helps to ensure that claims can be paid, particularly when major events occur that trigger significant losses or claims.

We reinsure protection products such as life and critical illness policies. 

Policyholders in Korea should refer to the Korea Privacy Notice for specific terms that apply under Korean law.

WHAT DATA WE PROCESS

Data we process may include:

• Your basic personal details such as name and date of birth.
• Data that allows us to underwrite individuals seeking cover, including occupation, medical history, lifestyle characteristics and hobbies or activities that may affect the risk and any other insurance policies or insurance-related services they have applied for or received.
• Data that allows us to manage and administer our reinsurance arrangement with your insurer such as calculating reinsurance balances due and monitoring trends in the business being reinsured.
• Data that allows us to assess claims including, the cause and circumstances of the claim, your medical history, your financial history, and any other insurance claims you have made.
• Some of the personal data we process is sensitive personal data (some or all of which may be applicable depending on where you live) and attracts higher standards of protection. The types of sensitive personal data we may process are (where applicable):
• Data concerning current or former physical or mental health including treatment and care you may have received or need.
• Data about your family history of illness or medical treatment.
• Details of your current and former marital status.
• Details regarding your criminal offences, including alleged offences, criminal proceedings, outcomes, and sentences.
• Details of your religious beliefs or other beliefs of a similar nature.
• Details of your racial or ethnic origin.
• Details of your sex life and sexual orientation.

and only where they are relevant and necessary to achieve the purpose for which we process data. Apart from data concerning your health, the other items of sensitive personal data are only likely to be processed incidentally.

WHY DO WE NEED IT?

There are several legal bases for processing data depending on where you live. We rely on the following:

1.     Consent: You provided consent to your insurer allowing them to disclose your personal data to us.

2.     The processing is reasonably necessary to conclude or perform a contract or transaction. We need to be able to process personal data to provide the reinsurance services covered in the reinsurance contract between us and the insurer of the policy you are covered by.

3.     The processing is necessary for our legitimate interests. The processing of personal data is necessary for us to provide reinsurance services to insurers and is therefore in our legitimate interests.

4.     The processing is necessary for compliance with a legal obligation to which we are subject. We are subject to legal and regulatory requirements relating to our business as a reinsurer and may need to process personal data for those purposes.

5.     A transfer is necessary or the conclusion or performance of a contract between the data user and a third party which is in the interests of the data subject.

Once we have entered into a reinsurance agreement with your reinsurer, we need to use your personal information for the purposes described in this privacy notice in order to perform our obligations under the reinsurance agreement with your insurer. This is in your interests as reinsurance allows your insurer to spread the risk of any potential losses.

HOW DO WE COLLECT IT?

We receive personal data about individuals insured under policies from the insurers whose business we reinsure. We do not collect data from individuals directly.

We may generate new personal data, for example, when seeking opinions from our company medical officers on claims we assess.

WHAT DO WE USE IT FOR?

We use your data to:

• Provide reinsurance cover. This may be for a group of policies or for specific individuals and includes underwriting, pricing, estimating future claims and claims assessment.
• ·Perform reinsurance arrangements. New and existing reinsurance arrangements must be implemented, administered, and managed.
• Procure retrocession cover. We may seek retrocession cover for all or part of the business we reinsure. Our retrocessionaires may need data to assess the risk they are being asked to cover.
• Establish, exercise, or defend our legal rights in connection with reinsurance or retrocession agreements. This applies when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
• Detect and prevent fraud and financial crime.
• Screen certain personal data we receive about individuals against lists published by governments and international organisations relating to sanctions, embargoes, and politically exposed persons.
• Manage our business. This includes financial reporting, compliance with legal and regulatory requirements, and research and statistical analysis to support and improve our reinsurance services and those of our affiliates. This ensures that our processes, procedures, and systems are as efficient as possible and enhance the service we provide.

Wherever possible and proportionate, we anonymise or pseudonymise data to carry out these purposes. Pseudonymisation is a recognised data minimisation technique that enables our employees and agents to use data about individuals without being able to personally identity the individuals concerned.

We do not use policyholder information to contact policyholders or allow any other person to do so on our behalf.

HOW DO WE SECURE IT?

We have in place physical, electronic, and procedural safeguards to protect personal data that we hold against unauthorised disclosure or unlawful processing. Safeguards include; only holding personal data on secure servers, the use of encryption, firewalls and access controls and the separation of duties within our organisation. When processing personal data, we seek to use only anonymised or pseudonymised data where knowledge of the individual’s identity is not necessary.

HOW LONG DO WE RETAIN IT?

We retain personal data for as long as is necessary to carry out the purpose for which we collected it and any other permissible purposes. We have a retention policy in place which governs retention and destruction of data and is designed to ensure that personal data is kept only for so long as we may be required to keep it in order to manage our business and for a reasonable period thereafter. We will keep personal data relating to individuals for a reasonable period beyond the date when we no longer reinsure the risk or are potentially liable to pay claims, whichever is later.

When we delete personal data in connection with a policy, it may persist on backup or archive media for legal, tax or business continuity purposes. 

WHO DO WE SHARE IT WITH?

We will only share your data where it is lawful and necessary to enable us to provide reinsurance services.

We may disclose personal data to:

• Third-party service providers. We share data with third parties to allow us to provide the reinsurance services, for example, our company medical officers who provide expert medical opinion to help us to assess claims. These third parties are authorised to use personal data only as necessary to provide these services.
• Other companies within the Pacific Life Group. We may disclose personal data to our affiliated companies to enable us to provide reinsurance services and for IT services such as the hosting of applications and systems that are used to process reinsurance data.
• Comply with legal obligations or proceedings. We may need to disclose personal data when we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims or to meet our legal and regulatory obligations.
• Retrocessionaires. In some cases, we share personal data with retrocessionaires who provide us with retrocession services. These companies will process personal data in accordance with the terms of their own privacy policies.

INTERNATIONAL TRANSFERS

We may transfer personal data to third parties or affiliates located in countries outside the country of origin for the purposes described in this Privacy Notice. We ensure that any transfer we make complies with relevant law.

WHAT ARE MY RIGHTS?

Right of access:  You have the right to know if we are processing your personal data and to receive a copy of that personal data. We will always try to provide your data in the format you request, and we will not normally make any charge.

Right of rectification: If any of the data we hold abut you is inaccurate or out of date, you can ask us to correct or update it.

Right to be forgotten: You can ask us to delete any data that we are no longer legally entitled to retain.

Right to object to or restrict processing: You can ask us to stop processing your personal data but only if we are processing it on the basis of “legitimate interest” and if we cannot demonstrate that our reasons for processing override your rights. You can also restrict our processing activities under certain circumstances.

Right to withdraw consent: You have the right to withdraw consent at any time on providing us with reasonable notice. Please note that if you exercise any of these rights, it may prevent us from continuing to provide reinsurance cover in respect of your policy.

Right to complain: In the first instance, you should contact us if you are dissatisfied with our handling of your data or if you believe we have breached our data protection obligations. You may have the right to complain to your local data protection authority if you remain unsatisfied after contacting us.

To exercise any of these rights, please use the appropriate contact information in the “WHO CAN I CONTACT” section below.

WHO CAN I CONTACT?

The Data Protection Officer, Pacific Life Re

Email: dpo@pacificlifere.com

CHANGES TO THIS PRIVACY NOTICE

We will keep this Privacy Notice under regular review and reserve the right to change it from time to time. It was last updated on 3 December 2025