Commonwealth Broker Limited respects and is committed to protecting the privacy of users and you. Please read this Privacy Policy, which explains how we collect, use, process and share your personal data.

1. Definitions

In this Privacy Policy:

"Commonwealth Broker Limited", "CWB" and "we" mean Commonwealth Broker Limited.

"Platform" means the website, mobile applications and/or social media platforms operated by us, including but not limited to Facebook, WeChat and WhatsApp.

"you" or "user" means any person who browses and uses our Platform.

2. Acceptance of this Privacy Policy

Browsing and using our Platform constitutes your agreement to the terms set out in this Privacy Policy.

3. Collection of Personal Data

We collect your personal data through the following means, including but not limited to:

• When you register on our Platform (including registering or logging in through a single sign-on (SSO) service) and provide personal data;
• When you use our Platform, including browsing and using our website, social media platforms and mobile applications;
• When you use our services, including chatbots and customer service;
• When you subscribe to receive our latest news, we will ask you to provide your email address and/or mobile telephone number;
• When you register an account for our services, we may ask you to provide your name, email address, telephone number and/or mobile telephone number;
• When you register an account for our services and/or log in through a third-party social media platform login function (for example, the Google or Facebook login function), we may collect your email address and/or basic profile information (profile photograph and full name), as well as any other information that you expressly consent to our collecting;
• When you request a quotation for certain products, we may ask you to provide information such as your age and income so that we can provide an accurate quotation;
• When you contact us for support, provide us with feedback, take part in a voluntary survey, subscribe to marketing information, participate in our activities, take part in product research or training, or otherwise interact or communicate with us, we may ask you to provide your name, email address and/or telephone number and any other personal data that you choose to share;
• When you use an application form on our services to apply for a product or service, we will collect information including but not limited to contact details, identification information and financial information;
• When we conduct a "Know Your Client" process to comply with applicable regulatory requirements, we may collect your personal data to verify your identity and assess potential risks relating to financial information. This process is necessary to comply with applicable anti-money laundering laws and regulations and to prevent fraud. We will process the personal data collected in accordance with applicable data protection laws.
• When you wish to add a child or family member to your application for a product or service, we may collect that family member's name and date of birth so that we can process the relevant application;
• When you participate in activities on our Platform, we may ask you to provide your name, email address, the product applied for, the application reference number and/or the application date; and
• When you request access to your credit information, we may ask you to provide personal data such as your name, mobile telephone number and identity document information, including your identity document number and other details stated on the identity document, as well as an identity document photograph, selfie photograph and/or facial recognition data, for identity verification and electronic Know Your Client (eKYC) purposes.

The personal data we collect includes but is not limited to your name, email address, telephone number, date of birth, gender, nationality, address, medical and health records, financial circumstances, your financial details including details relating to payment methods such as credit card and bank account details (when purchasing products), any information you enter in the forms on the Platform, your savings objectives, residential status, income, details of the product you are seeking (for example, loan amount), passport number, copies of your Hong Kong Identity Card or other identity documents and details (where required for purchasing products and/or providing your credit report or score), educational background, employment status, details of your employer or company, beneficiary details such as joint policyholders and minor beneficiaries (where required for purchasing products), family members (where required for purchasing products or using services), details of your property (where required for purchasing home insurance), travel details (where required for purchasing travel insurance), any information relating to the foregoing, and other information relating to our products and services. If you provide personal data on behalf of another person, you confirm that you are that person's parent or guardian, or that you have obtained that person's consent to provide his or her personal data to us for the purposes set out in this Privacy Policy.

The provision of personal data is voluntary. However, if you fail to provide the personal data requested, we may be unable to process your request or enquiry, or unable to provide products and services to you.

In addition, when you use our services, we may automatically collect certain information about how you access and interact with our services. When combined with your other information, such information may constitute personal data. We use automated technologies, such as "Cookies", web beacons and similar technologies, to help us provide you with the best possible service. When you access our services, our servers will record or track information sent from your browser. This may include, without limitation, the following information: characteristics of the device or equipment you use, such as the operating system, hardware version, device settings, software and device identifiers; device location, including specific geographic location identified through GPS signals or other means; connection data, such as the name of your mobile data operator, ISP or other service provider, browser type and IP address; the website from which you access our services; website pages previously viewed; details of the products and services you view on our services; data, tools and content you use on our services; time spent on our services; links you click on our services; quotations requested through our services; transactions conducted on our services and details of any payment made by you (including bank account and credit card details and identifiers for any other account); and any information relating to the foregoing.

We use Cookies to: provide you with a more personalised experience on our services; enable us to remember you when you next browse our services; allow you to access quotations you have previously saved and understand your browsing habits on our services; the more we understand which products interest you, the better we can provide you with tailored solutions, advertising suitable for your needs and other marketing information; and obtain information about the number of visitors to our services and the pages they have viewed.

In most cases, Cookies are deleted when you close your browser (these are known as temporary Cookies). However, permanent cookies will remain on your device until you delete them or they expire. By using the services, you agree to our use of Cookies. Use of this information will not disclose any of your personal data, and we will not otherwise collect, process or use any of your personal data for this purpose.

You may change your computer browser settings to block or delete Cookies. If you choose to block or delete the cookies of the services, you may be unable to access certain products or services, and the operation of the services on your system may be affected (for example, banner advertisements may not be displayed properly). If you have registered an account with us, disabling Cookies may mean that you need to enter your password more frequently while using our services.

4. Retention of Personal Data

We will not retain your personal data for longer than is necessary to fulfil the purposes for which it was collected (or any directly related purpose), and will comply with mandatory legal, regulatory and supervisory retention requirements.

When we no longer require your personal data or when your account is terminated, we will delete the data from our systems or anonymise it so that you can no longer be identified, unless we are required by law to retain it.

5. Purposes of Collection and Use of Personal Data

We may use your personal data for the following purposes:

• To provide products and services to you;
• To improve the products and services on our Platform;
• To communicate with you and provide customer service to you;
• To process your enquiries and requests;
• To conduct surveys and data analysis;
• To comply with legal or other legal and/or regulatory requirements, including any external or internal investigation;
• To enforce our contracts or other lawful rights and remedies;
• With your consent, to send you direct marketing offers and/or introductions to third-party products and services;
• For any other purpose related to the foregoing purposes and any purpose stated at the time of collecting personal data.

6. Sharing of Your Personal Data

We may disclose your personal data to the following persons for the purposes set out above:

• Our employees and directors;
• Our advisers and other service providers, such as information technology and analytics service providers, data management providers, business advisers, legal service providers and marketing service providers;
• Any legal, regulatory, governmental or law enforcement authority to which we are required, or which we consider appropriate, to make disclosure;
• Our digital media advertising partners, with whom we share anonymised data;
• Other third parties (with your prior consent), including insurance companies and insurance intermediaries.

7. Security of Your Personal Data

We may store your personal data in Hong Kong or overseas, including by using cloud storage services.

We will use all reasonable and practicable efforts to ensure that any personal data held by us is stored in a secure and reliable location and is accessible only by authorised personnel or authorised third-party service providers.

8. External Links

For the best service to our users, our Platform may contain links to websites not operated by CWB. If you visit those websites, you should review their privacy and/or other statements. CWB is not responsible for the policies and practices of other companies, and any information you submit to those companies will be subject to their privacy policies.

9. Access to and Correction of Personal Data

You have the right to:

Request that we provide a copy of your personal data, unless we are exempt from complying with a data access request;

• After we have complied with your data access request, if you consider that your personal data is inaccurate, request that we make the necessary correction;
• If we consider that the personal data is accurate, that the relevant request relates only to an expression of opinion, or that the proposed correction is inaccurate, we may refuse the data correction request.
• We reserve the right to charge a reasonable fee for processing or correcting any data access request.

If you wish to obtain, amend or delete your personal data from our Platform, or if you have any question or comment about our Privacy Policy, you may contact us by email: cs@commonwealthbroker.com.hk

10. Updates to the Privacy Policy

We reserve the right to amend or update this Privacy Policy from time to time without prior notice. If we make changes to the Privacy Policy, we will publish the updated Privacy Policy on our Platform. We encourage you to review our Privacy Policy regularly on our website.

Last updated: October 19, 2026