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 "Statement of Corporate Privacy Principles."
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· 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 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.
· 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.
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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:
o In order to provide you with our services and products and seek payment for such services and products.
o To keep our records updated, to ascertain how our clients use our services and products and to develop our services and products.
o To administer and protect our business and our website, including our administration and IT services, network security and to prevent fraud.
o 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;
· 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
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:
· Hong Kong
· 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.
UK Data Protection Officer
Manulife Investment Management (Europe) Ltd
1 London Wall London EC2Y 5EA
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 of Singapore:
Your privacy is very important to Manulife Investment Management (Singapore) Pte. Ltd. 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 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
Information for Residents of Hong Kong SAR:
Your privacy is important to Manulife Investment Management (Hong Kong) Limited. We have procedures governing how we may use information you provide or that we obtain from this website that constitutes personal data.
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.
Please address 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 to:
Data Protection Officer
Manulife Investment Management (Hong Kong) Limited
10/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.