1. Introduction and Acceptance

Welcome to InsurVault 保富 (hereinafter referred to as "the Platform" or "we"). The Platform is operated by InsurData Systems Limited. By registering, logging in, or using the Platform, you acknowledge that you have read, understood, and agreed to be bound by these Terms of Service and the Privacy Policy set out below.

2. Nature of Service and Non-Advisory Disclaimer

• Technology Service Provider: InsurVault 保富 is a digital policy management tool. We are NOT a licensed insurance intermediary, insurance company, or financial advisor.
• No Financial Advice: All data visualizations, protection gap analyses, and responses from the "Claims Assistant" provided by the Platform are based on pure mathematical and statistical calculations derived from the data you input. Such content is for reference only and DOES NOT constitute any form of insurance advice, financial planning opinion, or offer to purchase.
• Final Guidance: All policy terms and claims conditions are subject to the official documents and final guidelines issued by the insurance companies.
• Decision Responsibility: You should consult a licensed professional before purchasing or cancelling any insurance product.

3. Account Registration and Family Management

• Age Restriction: Users registering for an independent Master Account must be at least 18 years of age.
• Use by Minors (Parental Responsibility): Individuals under the age of 18 ("Minor Users") must use the Service as a "Sub-account" through the Master Account of their parent or legal guardian ("Master Account Holder").
• As the Master Account Holder, you agree to assume full joint and several legal liability for all actions, data entries, and operations of all Sub-accounts under your account.
• Any operation by a Sub-account on the Platform shall be deemed in law as an operation authorized by you.
• Account Security & Phishing Awareness: You are responsible for safeguarding your login credentials and device security. InsurVault 保富 will never ask for your password via email or unsolicited phone calls. You agree that InsurVault 保富 is NOT liable for any loss or damage arising from: (a) your failure to comply with this security obligation; (b) your device being infected by malware, keyloggers, or viruses; (c) your voluntary disclosure of credentials to third parties due to phishing attacks, social engineering, or fraudulent websites impersonating InsurVault 保富.

4. Data Accuracy and User Responsibility

• Disclaimer on User-Inputted Data: The Platform serves solely as a recording tool. All insurance policy data (including sum assured, expiry dates, and policy details) relies on manual input by you or persons authorized by you.
• Verification Responsibility: InsurVault 保富 does not and cannot verify the authenticity or accuracy of the data you input. The Platform shall not be liable for any policy lapse, rejected claims, or financial loss resulting from data entry errors (e.g., incorrect policy numbers, typos in expiry dates).

5. Feature-Specific Terms

6. Subscription, Fees, and Refunds

Certain features require a paid subscription. Unless otherwise required by law, all subscription fees paid are non-refundable.

If you downgrade your account from a Paid Version to a Free Version, fees for the paid period will not be refunded, and relevant advanced features will expire at the end of the current subscription period.

Price Adjustments: InsurVault reserves the right to adjust pricing for the Service or any components thereof in any manner and at any time as we may determine in our sole and absolute discretion. Any price changes will take effect following notice to you (e.g., via email or in-app notification). The new price will apply starting from your next billing cycle. If you do not agree to the price change, your sole remedy is to cancel your subscription before the price change takes effect. Continued use of the Service after the price change takes effect constitutes your agreement to pay the modified amount.

6A. Disclaimer of Warranties

The Service is provided on an "AS IS" and "AS AVAILABLE" basis. InsurVault 保富 expressly disclaims all warranties of any kind, whether express or implied, including but not limited to the implied warranties of merchantability, fitness for a particular purpose, and non-infringement. We do NOT warrant that: (a) the Service will meet your specific requirements; (b) the Service will be uninterrupted, timely, secure, or error-free; (c) the quality of any information obtained by you through the Service will meet your expectations.

7. Limitation of Liability

To the fullest extent permitted by law, InsurVault 保富 shall NOT be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including but not limited to damages for loss of profits, goodwill, use, data, or other intangible losses, resulting from: (a) the use or the inability to use the Service; (b) unauthorized access to or alteration of your transmissions or data; (c) any hacking, cyber-attacks, distributed denial-of-service (DDoS) attacks, or other security breaches, provided that InsurVault has implemented reasonable industry-standard security measures; (d) statements or conduct of any third party on the Service.

8. Force Majeure

InsurVault 保富 shall NOT be liable for any delay or failure to perform resulting from causes outside its reasonable control, including, but not limited to, acts of God, war, terrorism, riots, embargos, acts of civil or military authorities, fire, floods, accidents, strikes, or shortages of transportation facilities, fuel, energy, labor or materials, telecommunications or internet service provider failures, or failure of third-party hosting services (e.g., cloud infrastructure outages).

To the fullest extent permitted by law, the cumulative liability of InsurVault 保富 to you for any direct, indirect, incidental, or consequential losses arising from the use of the Service shall be limited to the subscription fee paid by you to the Platform in the month preceding the claim or HKD 500.00 (whichever is higher).

9. Modification of Terms

We reserve the right to modify these Terms at any time. We will post the most current version of these Terms on the Platform. If a revision is material, we may notify you. It is your responsibility to review these Terms periodically. Your continued use of the Service after any such changes constitutes your acceptance of the new Terms. If you do not agree to any of these terms or any future Terms of Service, do not use or access (or continue to access) the Service.

10. Governing Law and Language

These Terms shall be governed by the laws of the Hong Kong Special Administrative Region.

Prevailing Language: This Agreement is drafted in both English and Chinese. In the event of any discrepancy or inconsistency between the two versions, the English version shall prevail.

1. Data Collection Categories

• Personal Data: Including but not limited to name, contact details, date of birth (for age verification).
• Policy Data: Insurance company names, policy numbers, sum assured, premiums, beneficiaries, etc., entered by you.
• Minor's Data: We collect data on minors solely through the Master Account Holder (Parent/Guardian). Entry of such data by the Master Account Holder constitutes the exercise of guardianship rights and consent for us to process such data.
• Biometric Data (NOT Collected): When you use biometric authentication (e.g., Face ID or Touch ID) to log into the App, your biometric features are processed exclusively locally on your mobile device (e.g., via Apple's Secure Enclave). The Platform DOES NOT collect, store, transmit, or have access to any of your biometric data. We are not liable for any losses arising from the compromise, misuse, or malfunction of the biometric authentication system on your device.

2. Data Storage and Cross-Border Transfer

• Storage Location: Our servers and databases are hosted in Singapore.
• Legal Protection Statement: You understand and agree that to provide the Service, your data will be encrypted and transferred to secure servers located in Singapore. We have confirmed that the current Personal Data Protection Act (PDPA) of Singapore provides protection that is substantially similar to or commensurate with the standard of the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong. We commit to adopting strict encryption technologies to protect your data at rest.

3. Data Usage and Non-Sale Commitment

• Core Usage: To provide policy management, expiry reminders, protection gap analysis, and family sharing services.
• No Sale Commitment: We will NEVER sell your personally identifiable information (PII) to insurance companies, brokerage firms, or advertisers.
• Anonymized Data: We reserve the right to use fully anonymized (de-identified) data for big data statistics and to improve system algorithms.
• User-Initiated Sharing: The Platform provides features to generate policy reports (PDFs) and advisor collaboration links. We will NEVER proactively transmit your data to any third party (including insurance advisors). All data sharing actions (such as sending reports via email or messaging apps) must be explicitly directed and manually triggered by you within the App.

4. User Rights and Data Deletion

• Access and Correction: You have the right to access and correct your personal and policy data stored on the Platform at any time.
• Account Deletion & Anonymization: You have the right to request the deletion of your account at any time within the App's settings or send an email to [email protected] from the email address registered to your account with the subject line "Account Deletion Request". We will process your request and delete your data within 3-5 business days. Once deletion is confirmed, we will remove your Personally Identifiable Information (PII) from our active servers. For internal analytics and system improvement purposes, certain policy data will be fully anonymized (rendered untraceable to you) and retained. Please note that due to regular system backup mechanisms, residual encrypted data may take up to 90 days to be completely purged from all backup archives.

5. Contact Us

If you have any inquiries regarding these Terms or the Privacy Policy, please contact InsurData Systems Limited at [email protected]