GLOBAL PRIVACY POLICY

Privacy policy and data protection

You consent to the processing by Manulife Investment Management of the personal data submitted by you through the website and/or created in the course of the business relationship with Manulife Investment Management, and to the transmission of such personal data to other companies within the Manulife Investment Management and/or Manulife Financial corporate umbrella for purposes connected with marketing and customer administration.

Manulife Financial complies with data protection regulations in jurisdictions where we do business. For further reference on Manulife’s Financial's policy, please read the "Statement of Corporate Privacy Principles."

Cookies

Manulife Investment Management's websites and online services use "cookies." A cookie is a small file that is stored on the end user’s device and it contains unique information about a user’s behavior and profile (e.g. items saved in a shopping cart). Manulife Investment Management uses cookies in two ways: (1) it does so to direct users to the correct portion of the website, i.e., to the area most appropriate for their user needs, and/or to the correct language version of their site in the case of sites with multiple languages, (2), cookies are used to gain basic information on users such as whether they are unique or regular users. The former type of cookie will expire after the end of the user's session whereas the latter will remain unless they are deleted by the user. Users may choose to refuse cookies or turn them off through their web browser settings, however, this may prevent access and functionality to parts of the website.

We may also use cookies generally for

  • Analytical purposes: Analytical cookies allow us to recognise, measure and track visitors to our website and compile a record of this usage information. This helps us to improve and develop the way our website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.
  • Usage preferences: Some of the cookies on our website are activated when visitors to our sites make a choice about their usage of the site. Our website then "remembers" the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.

  • Terms and conditions: We use cookies on our website in order to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our website. This helps to improve the user’s experience of the site – for example, it aids in avoiding a situation where a user is asked repeatedly to consent to the same terms. We also track whether a user has seen other similar documents (such as an online survey) before – again, to ensure that a user’s experience of our website is a smooth one.

  • Advertising: Advertising cookies allow us (or third parties) to monitor the behavior of users of our website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner which are based on your experience with our website; or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether the adverts displayed on our website are of interest to users and retain this information to ensure that adverts seen by users of our website over a period of time are appropriate.

How can you control cookies?

You can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. However, you should note that restricting or deleting cookies will also restrict your internet experience and use of website facilities.

To opt out or manage cookies, click on the Cookies Settings link in the cookie banner populated at the bottom of this website. The banner may not be available if you have already set your cookies settings. Delete the “OptanonAlertBoxClosed” cookie and reload the browser tab to see the cookie banner populate again.

To restrict web browser cookies on your browser visit the help function or see useful information on www.aboutcookies.org

 

Security

You acknowledge and confirm that the internet is not a secure medium where privacy can be ensured, and that complete security and confidentiality over the internet is not possible at this time. Your confidential use of the website cannot be guaranteed and you acknowledge that your use of the website (including information you transmit to the website) may be subject to access by, or disclosure to, other persons. Without limiting any other disclaimer herein, Manulife Investment Management shall not be responsible or liable for any harm that you or any other person may suffer in connection with any such breach of confidentiality or security.

User content

You agree that you are solely responsible for your actions, and the content of its transmissions through or posting on the website and that such actions will abide by all applicable laws and regulations in the use of the website. You also agree not to (i) upload or distribute in any way files that contain viruses, corrupted files, or any other similar software or programs that may damage the operation of another's device; (ii) interfere or disrupt networks connected to the website; (iii) use any device, software or routine in an attempt to interfere with the proper functioning of the website or any transactions being offered at the website; and (iv) take any action that imposes an unreasonable or disproportionately large load on the website's infrastructure.

Types of personal data we may collect

As part of our general business activity, we may collect your name, work contact details and details of the position you hold in your professional capacity. We may also collect information about you or individuals you represent, e.g. directors, officers and other key management personnel.

 

Purposes for collecting personal data

We collect and process your personal data for the purposes of logging interactions with clients and potential clients, consultants and other associated persons, and for relationship management and, in particular to:

  • establish your identity and assess applications for our products and services;
  • design and administer our products and services;
  • manage our relationship with you;
  • manage our risks and help identify and investigate illegal activity, such as fraud;
  • contact you, for example if we suspect suspicious activity on your account or need to tell you something important;
  • conduct and improve our businesses and improve the customer experience;
  •  comply with our legal obligations and assist government and law enforcement agencies or regulators; and
  • identify and tell you about other products or services that we think may be of interest to you.

Legal basis for processing personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have explicitly consented to such use. You have the right to withdraw such consent at any time by contacting us through the details set out below.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Those legitimate interests are as follows

  • In order to provide you with our services and products and seek payment for such services and products.
  • To keep our records updated, to ascertain how our clients use our services and products and to develop our services and products.
  • To administer and protect our business and our website, including our administration and IT services, network security and to prevent fraud.
  • To develop our services and grow our business.

Your legal rights

Under certain circumstances and depending on your location, if you are an individual, you may have certain rights under local data protection laws in relation to your personal data. Such rights are dependent on jurisdiction and may include the following:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of your rights set out above:

  • Please contact us using the contact details set out below, dependent upon your location.
  • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
  • We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • Depending on your location, we try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Recipients of personal data

We will not sell your personal data to any third parties. We may share your data with third parties where we have a legitimate interest or legal reason for doing so. These include:

  • service providers, for example custodians, brokers, unit registry services or correspondent banks;
  • those to whom we outsource certain functions, for example, direct marketing, statement production, information technology support;
  • brokers, agents and advisers and persons acting on your behalf, for example a custodian or asset consultant;
  • other financial institutions, for example so that we can process a claim for mistaken payment;
  • auditors;
  • government and law enforcement agencies or regulators; and
  • entities established to help identify illegal activities and prevent fraud.

We will share personal information with our affiliates for certain business purposes, only if the law permits it. Please note that we do NOT give your personal information, without your consent, to any organization outside of our member companies, for the purpose of that organization marketing their own products or services directly to you.

Information for Residents of the European Economic Area (the “EEA”) and Switzerland:

Transfers of data to a country outside of the EEA

We may share your information with Manulife affiliated companies in non-EEA states. To the extent that your information is shared outside the EEA, we ensure that equivalent protections are in place by implementing at least one of the following safeguards:

  • ·Your personal data will be transferred to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We may enter into a specific contract with the recipient of your personal data which has been approved by the European Commission which gives the personal data the same protection it has in Europe

The main countries to which your information may be transferred are:

  • Canada
  • United States
  • Hong Kong 
  • Singapore

How long we hold your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be obtained by contacting us using the contact details set out below.

Right to lodge a complaint

You have the right to lodge a complaint against us. You may do so by contacting us using the details below.

Data Controller and Data Protection Officer

Manulife Investment Management (Europe) Limited, a company incorporated and registered in England and Wales under company number 02831891 and whose registered office is 1 London Wall, London EC2Y 5EA is the Data Controller and is responsible for any data collected as a result of your use of this website.

Under GDPR, you have the right to request access to, rectification or erasure of your personal data that is processed by us. You may also request a restriction to be made on processing of your personal data, object to its processing or request its transfer to another data controller.

Under GDPR, you have the right, at any time, to lodge a complaint with the relevant data protection authority. In the UK, the relevant data protection authority is the Information Commissioner's Office (ICO) ( www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the contact details below in the first instance. Manulife Investment Management (Europe) Limited is registered with the ICO.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions relating to this privacy policy. You may contact us, through the DPO, to request further information, make a complaint or exercise your legal rights (including a data subject access request) in writing or by phone using the contact details below:

FAO Data Protection Officer
Manulife Investment Management (Europe) Ltd
1 London Wall London EC2Y 5EA
dpo_europe@manulifeam.com
T: 020 7256 3500

Information for Residents of Singapore:

Your privacy is very important to Manulife. To the extent any information you provide or which we obtain from this website constitutes personal data, we have set procedures for the use of that information.

You agree that all information and/or particulars sent or submitted by you through the website is non-confidential and non-proprietary unless otherwise expressly indicated by you. You acknowledge that Manulife, its directors, officers, employees, contractors and agents shall not be subject to any confidentiality obligations in respect of any such information and/or particulars and you agree that Manulife, its directors, officers, employees, contractors and agents may, and you hereby authorise each of them to, use and to disclose such information to any person (including without limitation any third party service provider) in connection with Manulife's internal business purposes.

Without prejudice to the generality of the foregoing, you consent to the processing by Manulife of the personal data submitted by you through the website and/or created in the course of the business relationship with Manulife, and to the transmission of such personal data to other companies within the Manulife (by the internet or otherwise) for purposes connected with marketing and customer administration. If you do not wish your information to be used in this way, you should advise Manulife in writing.

If you have any questions on our data protection policies and practices, please write to us at our corporate address:


The Data Protection Officer
Legal & Compliance Department
Manulife Investment Management (Singapore) Pte. Ltd.
8 Cross Street
#16-01 Manulife Tower
Singapore 048424

 

Information for Residents of Hong Kong SAR:

Your privacy is very important to Manulife Investment Management (Hong Kong) Limited. To the extent any information you provide or which we obtain from this website constitutes personal data, we have set procedures for the use of that information. 

Failure to supply such personal data may result in your inability to use or access this website, or parts of this website. 

Please note that if you telephone Manulife Investment Management (Hong Kong) Limited, calls may be monitored or recorded to maintain and improve services. 

You consent to the processing by Manulife Investment Management (Hong Kong) Limited and its affiliates of personal information submitted by you and/or created in the course of the business relationship with Manulife Investment Management (Hong Kong) Limited and to the transmission of this data to other companies with Manulife Investment Management (Hong Kong) Limited and its affiliates or to third party service providers, with whom we have contracted to hold and store data from time to time, for purposes connected with marketing and customer administration. If you do not wish your information to be used in this way, you should advise Manulife Investment Management (Hong Kong) Limited by email or in writing. 

You are entitled under the Personal Data (Privacy) Ordinance of the laws of Hong Kong ("Ordinance") to check whether Manulife Investment Management (Hong Kong) Limited holds personal data about you and request access to such personal data, request Manulife Investment Management (Hong Kong) Limited to correct any personal data relating to you which is inaccurate, and ascertain Manulife Investment Management (Hong Kong) Limited's policies and practices in relation to personal data and be informed of the kind of personal data held by Manulife Investment Management (Hong Kong) Limited. In accordance with the terms of the Ordinance, Manulife Investment Management (Hong Kong) Limited has the right to charge a reasonable fee for processing any data access request. 

All requests for access to or correction of personal data or for information regarding the policies and practices and kinds of data held by Manulife Investment Management (Hong Kong) Limited, should be addressed to: 

Data Protection Officer 
Manulife Investment Management (Hong Kong) Limited 
16/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong

Information for Residents of Taiwan:

Notification Letter of Collection, Processing, Use and International Transmission of Personal Information by Manulife Investment Management (Taiwan) Co., Ltd.

Please read the notification terms and the information as shown below for collection, processing, use and international transmission by Manulife Investment Management (Taiwan) Co., Ltd. (the “Company”) of your Personal Information as defined below.

1. The Purpose of Collecting Personal Information

(1) The Company collects your Personal Information is to perform the businesses listed in the Company’s Business License, including but not limited to the following, security investment trust business, offshore fund related business, discretionary mandate business, security investment consultant business, other investment business or transaction activities permitted by the regulator and the relevant analysis opinion provision or consultant services, which include the execution or implementation of any activities, production supply or service provision under the regulations related to security investment trust and consultant business, offshore fund related business and discretionary mandate business, activities of the Company in handling complaints and disputes, implementation of compliance, AML, risk management and auditing, and any other conducts, business activities, analysis, survey, research and statistical analysis regarding the security investment trust business, offshore fund related business, security investment consultant business and discretionary mandate business etc.

(2) The said purposes also include but not limited to the following:

a.         To execute or implement contracts, complains and disputes, dealing with internal control and audit for the Company, activities for promotion, products or services permitted by laws, evaluation for you or for performance of contracts, and any other legally permitted securities investment trust business, offshore fund related business, discretionary mandate business, security investment consultant business, other investment business or transaction activities permitted by the regulator.

b.         Securities investment trust business and security investment consultant business; management and services of consumers, marketing business and any other registered businesses in service permission or listed in the Articles of Incorporation of the Company, other financial management services, other contracts, similar contracts, legal relationship management matters or business.

c.         For the Company’s internal purposes to use Personal Information, including but not limited to compliance, risk management, anti-money laundering, investigation, research and statistical analysis, in order to improve products, services and customer communications and to enhance the development, delivery and improvement of products, services, contents and advertising.

2. The Classification of the Personal Information

(1) Name, date of birth, national identification card number, passport number, marriage, family, education, occupation, contact details, financial situation, social activities, electronic mail address, and any other information that can be directly or indirectly identifiable to individual personal information, and

(2) Based on the purpose of Anti-money laundering, the following personal data of an individual who: (a) takes part in or has influential impact on the decision-making process, and eventually obtains all or part of the interests of any other person or party, and (b) is a politician, a legal representative of a legal entity or an individual shareholder with directly or indirectly shareholding of more than 25% in a legal entity, when the beneficiaries and their family members or intimate partners are domestic/foreign politicians or legal entities (collectively, “Personal Information”).

3. The Retention Period to Use Personal Information, Areas where Personal Information is Used and Entities to use Personal Information and the Manners

(1) Retention Period: Unless otherwise provided in other agreement, the retention period of your Personal Information will be the period that the Company provides you the service, and 10 years after the specific purpose no longer exists or time period expires as required or permitted by law

(2) Areas where Personal Information is Used: The Republic of China (Taiwan), the locations of hosting computer of Personal Information storage or processing and the relevant network server locations, the locations of the foreign parent company of the Company and their group companies, the locations of other recipients of internationally transmitted Personal Information not subject to restrictions imposed by the Central Government Authorities of the Republic of China (Taiwan), the locations of other parties having outsourcing business with the Company, the operation locations of the institutions having any other business relationship with the Company, and the locations of the following parties who may use the Personal Information.

(3) Entities to use Personal Information:

The Personal Information will be provided to, or be accessible by:

a.         The employees, agents and representatives, who need the information in the performance of their duties for the Company, or service providers who need the information in the performance of their duties for us, and to satisfy their obligations to the Company, or anyone who is otherwise authorized by law.

b.         The Company, the Company’s foreign parent company, the holding company of such parent company and the affiliates of such holding company.

c.         Any third party who is delegated to handle matters by the Company in accordance with Personal Information Protection Act or other arrangements, or who has outsourcing business with the Company and other sub-contracting parties (including any mandated parties or their affiliates).

d.         Any third party having joint marketing or mutual use arrangement of customers data with the Company for cooperative promotion and for soliciting business, or having business arrangement or agreements with the Company (including fund sale agreement and fund master agent agreements), and any party having mergers and acquisitions or spin-off arrangements with the Company permitted by the regulator or any other parties who are the contracting persons of any mergers and acquisitions or spin-off arrangements and their consultants.

e.         The Financial Ombudsman Institution or any other dispute handling competent authority under the consumer dispute handling regulations for needs of such handling process.

f.          In accordance with the laws and legal process, litigation or non-litigation or other way of dispute resolution, the competent authority, government agencies, or the requirements of the third party who claims the infringement of rights which have appropriate proof, the Company needs to disclose your Personal Information.  Based on the requirements of national security, enforcement of law, or other important public interest, after the assessment of necessity and appropriateness, the Company may disclose your information.

(4) The Company will handle your Personal Information by using the automated machine or other non-automated ways.

4. Except otherwise provided in the laws and regulations (including the SITE, SICE related laws and regulations of the Republic of China (Taiwan), you can exercise the following rights in writing:

(1) any inquiry and request for a review of the Personal Information.

(2) any request to make duplications of the Personal Information.
(3) any request to supplement or correct the Personal Information.

(4) any request to discontinue collection, processing or use of Personal Information.

(5) any request to delete the Personal Information.

5. You can choose whether to provide Personal Information or not; however, if you choose not to provide the Personal Information or provide in an incomplete way, based on the purpose of your Personal Information being collected, the Company will not be able to provide you a good and complete service and may further affect to provide the Company’s service/production or affect the right of the contract with the Company.

6. When the purposes mentioned above are disappeared or expired, the Company may not delete the Personal Information, but choose to stop further processing or use instead.  If you deliver the Personal Information of a third party to the Company, you should have ensured that you have obtained the consent from such third party and fulfilled the obligation of disclosure and notification to such third party in accordance with the Personal Information Protection Act of Taiwan.

7. If you have any foreign nationality, the Company may, in accordance with the laws or regulations of any country and the requests of competent authority of such country, and in accordance with the requirements of international transmission-related protocols regulations, submit your Personal Information and relevant beneficiary's account, credit, investment, or other financial information to the competent authority of the country.

8. The Company has the right to amend this Letter, and after any amendments, will be able to advise you orally, in writing, by telephone, SMS, emails, fax, electronic documents or other methods sufficient to inform you (including but not limited to the above method informing you of the link of website to download the complete contents of this Letter) of the amendment key points and any designated website. At that time, please read the contents on the specified website.

Information for Residents of Malaysia:

We have outlined the following Internet Privacy Policy relating to personal information provided through visits to our website. This policy does not apply to websites that may be accessed through links from our website and which are not owned by us or our subsidiaries.
 
This Internet Privacy Policy describes our privacy commitment with respect to information supplied to consumers visiting our website.

1. We collect personal information in order to provide superior service.

The information that Manulife Investment Management (M) Berhad collects from our website visitors is used to provide them with a superior online experience. The personal information you provide is used to assist us with the specific product or service you have chosen. Additionally, we may use this data in aggregated form only (not in any form that personally identifies you) to track use of our tools and features for internal programming and demographic and other research purposes.

Our website may include several forms allowing you to contact us regarding customer service, product information, general information and website feedback. The information you provide in these forms, including but not limited to your name, identification number, address, phone number, email address and account numbers, is used to contact you in order to satisfy your request.
 

2. We may contact you for Manulife Investment Management (M) Berhad marketing purposes.

Many visitors to our site wish to remain apprised of new products and services and opportunities. In that case, you may request to receive email messages from us by so indicating and providing your email address on the forms provided.


3. We employ advanced security safeguards.

Security is our top priority. Manulife Investment Management (M) Berhad will strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
 
The secure area of our website supports the use of Secure Socket Layer (SSL) protocol and 128-bit encryption technology — an industry standard for encryption over the internet to protect data. When you provide any personal data, it will be automatically converted into codes before being securely dispatched over the internet.

 
Our web servers are protected behind "firewalls" and our systems are monitored to prevent any unauthorised access.

4. We educate our employees — and hold them to strict standards of conduct.

At Manulife Investment Management (M) Berhad, our associates are personally responsible for maintaining consumer confidence in the company. We remind associates regularly of their obligations to comply with Manulife Investment Management (M) Berhad's high ethical business practices standards, including maintaining confidentiality of our customers' personal information. Disregard of these obligations can result in disciplinary action.

 
If you have additional questions or concerns about internet privacy, our information practices, secure Web servers or the confidentiality of personal data transmissions over the internet, please contact us.  It is our sincerest hope that all who participate here will do so with complete confidence — and come away from the experience with valuable insight and a renewed commitment to achieving the financial stability they and their loved ones deserve.  

For more information, please see the Manulife IM (Malaysia) Personal Data Protection Notice.

 

Information for Visitors from North America:

For further inquiries about this Privacy Policy, please contact:

Attn: Privacy Officer

Manulife Investment Management

197 Clarendon Street

Boston, MA 02116

 

Effective date: January 24, 2020.