Manulife Investment Management Institutional Privacy Policy
Privacy policy and data protection
Manulife Investment Management and its subsidiaries and affiliates are committed to privacy and data protection. This Privacy Policy applies to personal data Manulife Investment Management collects from you through this website, the Manulife Investment Management institutional website dashboard (“the Dashboard”), and describes how we use and protect your personal data.
You agree 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. You can download a printable copy of this Privacy Policy here.
Manulife Financial Corporation (“Manulife”) complies with data protection regulations in jurisdictions where we do business. For further reference on Manulife's data protection policy, please read the "Global Privacy Policy."
Cookie Policy
This section of the Global Privacy Policy explains how and why cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies”) may be stored on and accessed from your device when you use or visit Manulife Investment Management’s websites or any website that posts a link to this Policy (individually a “Website,” or collectively, the “Websites”). Manulife Investment Management's websites and online services use Cookies. Cookies are small files that are stored on the end user's device and contain 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 to and hinder functionality of parts of the website.
We may also use cookies generally for, but are not limited to:
- To Store Your Preferences and Settings. Settings that enable our Websites to operate correctly or that maintain your preferences over time may be stored on your device. We may save preferences, such as device (e.g., computer, laptop, or mobile device) language, browser, and multimedia player settings, so those do not have to be reset each time you return to the Websites. If you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device. Cookies can also help you fill out forms on our Websites.
- For Sign-in and Authentication. When you sign into one of our Websites using your account, we may store a unique ID, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the Website without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the Websites.
- For Security. We use cookies to enable and support our security features, to detect fraud and abuse of or other malicious activity on our Websites and violations of our Global Legal Terms.
- For Storing Information You Provide to a Website. When you provide personal information to our Websites, we may store the information in a cookie.
- For Social Media Use. Some of our Websites may include social media cookies, including without limitation, sharing service offering pages from our Websites using our sharing links and enabling users who are logged in to the social media service to share content via that service.
- To Provide Feedback. We use cookies to enable you to provide feedback on our Websites.
- For Interest-Based Advertising. We may use cookies to provide you with target advertising based upon your interests or places you have visited or specific websites and services you have viewed. You can opt out of receiving interest-based advertising as described in the “How can you control cookies?” section of this Privacy Policy.”
- For Showing Advertising. We may use cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen so you do not see the same one repeatedly.
- For Analytics Use. We also use cookies to provide and improve our Websites and your experience. We use cookies to ensure even performance of our Websites and to gather usage and performance data. We use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our products. This includes cookies from us and from third-party analytics providers. We also use cookies to understand, improve, and research how you use and interact with our Websites.
- Performance. We use cookies to ensure optimal performance of our Websites.
- Advertising: Advertising cookies allow us (or third parties providing a service to us) 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
Manulife Investment Management takes reasonable steps to secure its systems and to maintain the confidentiality, integrity, and availability of its data. Nonetheless, 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.
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, 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.
Links to other sites
The website may contain links to third party websites and services that are not operated by us. When you click these links, you are navigating away from the website. A link to a third party website or digital service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third party website or digital service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.
International Transfers and Local Privacy Requirements
As we operate globally, the personal information that we collect and process is retained and stored by us and our service providers in respective local jurisdictions and may also be maintained, processed, and stored in other jurisdictions that may have different data protection laws than those in your country of residence. If your personal information is transferred in these ways, please note that we comply with applicable legal requirements governing the transfer of information across borders. To the extent provided by applicable law and subject to exemptions thereunder, you have the right to request access to and rectification or erasure of personal data; to obtain restriction of the processing of personal data; to object to the processing of personal data (including direct marketing); and to data portability. If we have collected personal data with your consent, please note that you have the right to withdraw this consent at any time, subject to applicable law and exemptions thereunder.
Information for Residents of the European Economic Area (the "EEA”), the United Kingdom (“U.K.”) and Switzerland:
Transfers of data to a country outside of the EEA, U.K. and Switzerland
We may share your information with Manulife affiliated companies in other countries. To the extent that your information is shared outside the EEA, U.K. or Switzerland, 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 or the U.K..
- We may enter into a specific contract with the recipient of your personal data which has been approved by the European Commission or the U.K. which gives the personal data the same protection it has in the EEA, Switzerland, or the United Kingdom.
The main countries to which your information may be transferred are:
- Canada
- Hong Kong
- Singapore
- United Kingdom
- United States
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 the EU General Data Protection Regulation (EU GDPR) and the U.K. GDPR/2018 Data Protection Act, 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. You also 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:
UK Data Protection Officer
Manulife Investment Management (Europe) Ltd
1 London Wall London EC2Y 5EA
dpo_europe@manulifeam.com
T: 020 7256 3500
Ireland and EU Data Protection Officer
Manulife Investment Management (Ireland) Limited
Second Floor, 5 Earlsfort Terrace, Dublin 2, D02 CK83, Ireland.
Information for residents from Asia:
Institutional customer services in Asia may be offered by one or more Manulife Investment Management affiliates as listed below by jurisdiction in alphabetical order. Requests for access to or correction of personal data or for information regarding the policies and practices and kinds of personal data held by the following Manulife Investment Management affiliates should be addressed to the Data Protection Officers / Privacy Officers at the respective addresses provided here.
Manulife Overseas Investment Fund Management (Shanghai) Limited Company
Room 1501, 15/F, Building A, Hongjin Tower, No. 396 Wuchang Road
Hongkou District, Shanghai, China
Manulife Investment Management (Hong Kong) Ltd
23/F., Manulife Tower, One Bay East,
83 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong
PT Manulife Aset Managjemen Indonesia
Sampoerna Strategic Square South Tower
31st Floor Jl. Jenderal Sudirman Kav. 45-46, Jakarta 12930, Indonesia
Manulife Investment Management (Japan) Ltd
Marunouchi Trust Tower N Building 15th Floor,
1-8-1 Marunouchi, Chiyoda-ku, Tokyo 100-0005, Japan
Manulife Investment Management (M) Berhad
13th Floor, Menara Manulife, 6 Jalan Gelenggang,
Damansara Heights, 50490 Kuala Lumpur, Malaysia
Manulife Investment Management and Trust Corporation
10th Floor NEX Tower
6786 Ayala Avenue
Makati City, Philippines
Manulife Investment Management (Singapore) Pte Ltd
8 Cross Street
#16-01 Manulife Tower
Singapore 048424
Manulife Investment Management (Taiwan) Co., Ltd
3rd Floor, No. 97, Songren Road, Taipei City 110, Taiwan
Manulife Investment Fund Management (Vietnam) Co., Ltd
4th floor, Manulife Plaza, 75 Hoang Van Thai, Tan Phu Ward,
District 7, Ho Chi Minh City, Vietnam
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
We may update this Privacy Policy from time to time without prior or concurrent notice to you. Changes will be effective immediately but will not apply retroactively. You are responsible for periodically checking this Privacy Policy for changes. If we make changes to this Privacy Policy that materially affect your rights, we will use commercially reasonable efforts to provide additional notice to you, such as by email or through the website and/or Dashboard.
Effective date: August 1, 2024.
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197 Clarendon Street, Boston, MA 02116