Statement of Personal Data Protection

At Manulife (Singapore) Pte. Ltd. ("Manulife Singapore"), we take the privacy and protection of your personal data seriously.

Manulife Singapore complies with the Singapore Personal Data Protection Act 2012 (the "Act") for the collection, use, and disclosure of your personal data. We will ensure that:

• only fair, proper and legitimate means are used to collect your personal data;
• personal data collected is used in accordance with the purpose for which personal data is collected;
• personal data collected is protected by appropriate safeguards and made available only to authorised persons; and
• you have the right to access and request correction of your personal data.

Please read this Statement of Personal Data Protection (the "Statement") so that you know and understand how Manulife collects, uses, and discloses your personal data.

By interacting with us, submitting information to us, signing up for any product or service offered by us, you agree and consent to Manulife Singapore and its affiliates, as well as our Representatives (the companies and Representatives collectively referred to as "Manulife", "us", "we" or "our") collecting, using, disclosing and sharing your personal data amongst Manulife, and disclosing your personal data to Manulife’s authorised service providers, contractors and business partners in the manner set forth in this Statement, including any future amendments. 

In addition, this Statement will provide you with more information on the bases upon which we collect, use and/or disclose your Personal Data without your consent, where permitted by applicable laws.

This Statement supplements but does not supersede or replace any other consent you may have previously provided to Manulife in respect of your personal data. Your consent are additional to any rights which to any of the Manulife may have at law to collect, use or disclose your personal data.

1. Personal Data Protection Principles

Personal data is defined as data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which an organization has or is likely to have access. Examples of personal data will include your date of birth, health, education and employment information.

In handling your personal data, we abide by the following personal data protection principles:

1.1 Notification of purpose and consent

(a) Unless otherwise required or permitted by law, we will notify you of the purposes for which we intend to collect, use or disclose your personal data. This will occur at or before the time of the collection, use or disclosure. We limit the personal data we collect to that which is necessary for, or related to, these purposes.

(b) Unless otherwise required or permitted by law, we will only collect, use or disclose personal data with your consent.

(c) You may withdraw your consent for us to collect, use and disclose your personal data.

1.2 Access and correction

(a) Upon written request, we will provide you with access to your personal data and information about the ways in which your personal data may have been used or disclosed in the past year, as required or permitted by law.

(b) You may also verify the accuracy and completeness of your personal data, and request for it be amended or deleted, where appropriate. We will respond to these requests in accordance with our personal data practices and policies and in accordance with the law.

1.3 Accuracy

(a) We will take reasonable efforts to keep your personal data accurate and up to date as it is necessary to fulfil the purposes for which the data was collected and used. For this reason, you must also update us of any changes to your personal data as promptly as you can.

1.4 Safeguards

(a) We will take reasonable efforts to protect your personal data with security safeguards that are reasonable and appropriate to the sensitivity of the personal data, in order to protect it from unauthorized access, use, modification, disclosure, or disposal.

(b) We are responsible for personal data in our possession, including information transferred to service providers who perform duties on our behalf. When we share personal data with our service providers, they must protect the shared personal data in ways that are consistent with our privacy policies and practices.

1.5 Retention

(a) Manulife Singapore complies with applicable regulatory requirements with respect to the retention of personal data.

1.6 Accountability

(a) We have designated individuals who are responsible for monitoring our ongoing compliance with the Act. (See Section 9 below.)

(b) We will make information about our personal data protection policies, practices and complaint process available to you through this Statement, and upon request.

2. Notice to You

2.1 Personal data we collect

We may collect the following personal data from you:

(a) General identification and contact information (title, full name, address, email address, telephone number, age, date of birth, gender, marital status, citizenship, nationality, residency status, education etc);

(b) Identification numbers issued by government agencies (NRIC number, passport number, foreign identification number, birth certificate number, etc);

(c) Financial information and account details such as salary and other income, assets, liabilities, spending (expenditures), credit card information (credit card number, name on credit name), bank account information (account number, statement, account details) etc);

(d) Employment information (employment status, name of current and past employer, current and past occupation, annual declared salary etc);

(e) Medical and health information (health status, injury or disability information, medical and procedures performed, smoking status, family medical history, etc);

(f) Information about your investment knowledge and risk tolerance;

(g) Tax information;

(h) Information from cookies, IP address, type of operating system, time and duration of your visit to our Site, internet locations you came from, web pages you visit in our website, browser and device you are using, date, and number of times you visit our website, information you input into our website or similar technologies, in order to enable or enhance the functionality of our website, or to analyse visitor traffic for marketing or other purposes;

(i) images, photographs, videos, CCTV footage, voice recordings and electronic communications;

(j) Information relevant to the provision of financial products (insurance coverage with other insurers, claims experience, employment information, driving or criminal record, travel record, etc); 

(k) Information about family members and other persons who might be designated as beneficiaries or trustees under an insurance plan or trust; and

(l) Information obtained from third party(ies) in instances of suspected fraud, criminal records information, debt and theft information etc.

2.2 Where we collect personal data

We may collect your personal data in the following ways:

(a) when you submit an insurance application form or any other forms relating to any products and services offered and/or distributed by us;

(b) when a policyowner takes up an insurance policy for your benefit or appoint you as the life insured or other roles such as beneficiaries or trustees;

(c) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

(d) when you interact with our Customer Service Officers, Representatives or appointed service providers (telephone calls, letters, social media platforms, surveys, emails etc);

(e) when you use our electronic services, or interact with us via our website or use services on our website;

(f) when you request us to contact you (on your request for more information about product or service, complaints or any other purposes);

(g) when you update the Contact Us form on our website;

(h) when you respond to our promotions, lucky draws, contest, events, initiatives, surveys organised by Manulife Singapore, our Representatives or service providers and/or any other request for personal data;

(i) from a broker or other intermediary (e.g.: distributors, business partners) who we work with to provide products or services or quote to you;

(j) cookies, location services, IP addresses when you visit our website;

(k) when your images are captured by us via CCTV cameras while you are within any of our premises, or via photographs or videos taken by us, our Representatives or service providers when you attend our events;

(l) when we receive information from third party(ies) about you when you make payment;

(m) from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, publicly available directories and information (e.g.: social media, internet, news articles etc), debt recovery and/or other organisation to assist in prevention and detection of crime, police and law enforcement agencies;

(n) when we seek information from third party(ies) about you in connection with the products and services you have applied for; including but not limited to from other insurers, insurance associations, healthcare associations, clinics, investigators, ex-employer and the relevant authorities; or when you submit your personal data to us for any other reason;

(o) other publicly available sources where relevant and appropriate; and/or

(p) when you submit an application to use as a candidate for an employment or Representative position or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, Representative or any other position.

2.3 How we use personal data

The purposes for which personal data of our clients may be collected or used will vary depending on the nature of your relationship with us. For example, we may use your personal data to:

Manulife Singapore contracts with advertising agencies and marketing firms to promote our products and services, including on third-party websites that are not affiliated with us. These contracted service providers may employ interest-based or online behavioural advertising techniques in order to display advertisements that are more likely to be of interest to you.

We use web analytics services to analyse the use of our website. These tools use cookies to collect and generate information about your visits to our website (including your IP address) that is transmitted to their servers in an anonymous form for processing. We study patterns of website activity so we can improve the experience of visitors to our sites.

(a) confirm your identity and uniquely verify your identity;

(b) confirm the accuracy of the information collected;

(c) evaluate, underwrite (including preliminary underwriting) and price your application, and assess the insurance risks we are assuming during any insurance coverage changes or renewals;

(d) determine and verify your ability to afford the financial and insurance products you apply for;

(e) properly administer the products and services we provide, including the investigation, review, assessment and settlement of claims;

(f) communicate with you, especially with respect to your policy, updates and changes;

(g) provide you with ongoing services (including annual review of your plans) and respond to your queries, 

feedback, requests or instructions;

(h) make or obtain payments;

(i) recover any debts owed to us;

(j) detect, investigate and prevent errors, misrepresentations, fraud, or other unlawful or improper activities;

(k) coach employees and monitor for quality assurance;

(l) comply with all legal and regulatory requirements within and outside Singapore including disclosures to judicial, regulatory, government, statutory authorities and industry entities;

(m) resolve complaints, managing and preparing on incidents and handle requests for data access or correction;

(n) conduct compliance monitoring, audit reviews and pre-recruitment checks;

(o) facilitating, conducting interviews with candidates (employment or Representative position) and assessing your suitability for the applied position;

(p) compile statistics to design and improve products and services, or participate in industry exercises and studies;

(q) assist us to understand the current and future needs of our clients, for example, to conduct surveys and other forms of market research and analysis;

(r) use your health and wellness data received from the supporting trackers, including but not limited to Apple HealthKit, Samsung Health, Google Fit, Fitbit framework will be used to help you track your health and wellness activities, provided such data will not be used or shared with third parties for the purposes of serving advertising;

(s) perform any functions and activities related to products or services including but not limited to marketing, audit, reporting, research, analysis, reinsurance, general servicing and maintenance of online and other services;

(t) administering contests, lucky draws and events;

(u) design, promote, improve and further the provision of our financial products, services and promotions;

(v) conduct checks with the National Do Not Call Registry and our internal Do Not Call Registry;

(w) comply with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies (whether within or outside Singapore) that is assumed by or imposed on us or any member of our group of companies by reason of its financial, commercial, business or other activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognised bodies;

(x) for operational purposes, credit assessment, credit scoring models or statistical analysis (including in each case, behaviour analysis and evaluation of the overall relationship with our group of companies which includes using such data to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within our group of companies and/or other use of data and information in accordance with any group¬wide programmes for compliance with extraterritorial enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities), whether on our clients or otherwise;

(y) exercise any rights we may have in connection with the provision of insurance products and financial services to you;

(z) enable an actual or proposed assignee, transferee, participant or sub-participant of our rights or business to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;

(aa) market insurance and other financial products where specifically or deemed consented to or where permissible under applicable laws or regulations;

(bb) for any other purposes specifically provided for in any particular product or service offered by us or permitted or required by law or the relevant authorities;.

(cc) personalize and enhance your experience while you are visiting or using our Websites and Apps and make navigation easier;

(dd) enable you to use our online planning, digital advice, or investment strategy tools;

(ee) allow our web server to determine whether the cookies setting on your web browser has been enabled or disabled so that we will know whether data can be collected from your web browser;

(ff) track your visits to our website and recognize your web browser when you are a repeat visitor so that we can gather statistics on the number of new and repeat visitors and evaluate our website effectiveness;

(gg) deliver targeted advertising of Manulife Singapore products and services on our website; or

(hh) enable contracted third parties to perform services or functions on our behalf. They are required to safeguard the information we share with them and can only use it for our contracted business purposes.

In some circumstances we may anonymize your personal data so that it no longer identifies you, and therefore allowing us to retain and use such anonymized data without restriction, including for data analytics.

2.4 To whom we disclose personal data

Personal data held by us will be kept confidential, but we may disclose or transfer such personal data to the following persons and/or entities (whether within or outside Singapore) for any of the purposes set out in Section 2.3 above:

We will not share your personal information, without your consent, with any organization outside Manulife for the purpose of marketing our products or services to you.

(a) any person in connection with any claims made by or against or otherwise involving our clients in respect of any insurance products and financial services; 

(b) medical institutions, clinics, financial institutions, credit card companies, credit reference agencies (including any debt collection agencies), industry bodies, other insurance and reinsurance companies (including proposed reinsurers) for facilitate the processing of your applications, claims or any other insurance-related information or procedures;

(c) any agent, contractor or third-party service provider who provides administrative, consultative, telecommunications, computer, information technology, payment, data processing or storage, claim investigation, or any member of Manulife group of companies in connection with the operation of our business, including any custodian, administrator, investment manager, investment consultant or distributor;

(d) any financial consultant, bank partner, broker, introducer or other intermediary (including their employees);

(e) employers of our client, your past employer(s) for pre-recruitment checks;

(f) any person which has undertaken to us or any member of Manulife group of companies to keep such personal data confidential;

(g) any member of Manulife group of companies, where such a disclosure is required for the provision of financial products or services to you;

(h) any person to whom we or any member of Manulife group of companies is under an obligation or otherwise required to make disclosure under the requirements of any laws, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to us or any member of Manulife group of companies including but not limited to any local or foreign regulators, governmental bodies, or industry recognized bodies; or

(i) any person to whom we or any member of Manulife group of companies is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies that is assumed by or imposed on us or any member of Manulife group of companies by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognized bodies.

3. Withdrawal of Consent

You may withdraw consent for us to collect, use or disclose your personal data for any purpose (e.g. sending you marketing messages) by contacting us directly or submitting a completed personal details update form which can be downloaded at www.manulife.com.sg. Upon receipt of your notice to withdraw consent, we will inform you of the likely consequences of the consent withdrawal. In some cases, withdrawing your consent may have an impact on our ability to provide financial products and services to you or to process your claims.

This may also be disadvantageous to you, as you may lose valuable benefits from the policy and/or it may not be possible for you to obtain a similar level of protection on the same terms in the future.

4. Transfer of Personal Data Outside of Singapore

We operate our business in Singapore and for contractual, legal or business reasons, we may transfer personal data to any member of Manulife group of companies or service providers located outside Singapore. We will use legally binding instruments and other safeguards to ensure that appropriate levels of protection necessary to maintain the security of your personal data are in place and that any transferred personal data is processed only in accordance with the Act and any other applicable laws and regulations.

5. Personal data of another person

If you give us personal information about another person(s), we will assume that they have appointed and authorised you to act on their behalf.

This includes providing consent to: 

• Our processing of their personal information as mentioned above; and 
• You are receiving our information protection notices on their behalf.

6. Use of Cookies

Cookies are small text files that may be automatically stored on your browser that can be retrieved by our website. Cookies collect and store information about your browsing patterns and information you provide.

We may use cookies to enable or enhance the functionality of our website, or to analyse visitor traffic for marketing or other purposes. We may also use web analytic consultants to research certain usage and activities on our website. Cookies can make our website more useful by storing information about your preferences, thus enabling us to provide a more personalized service to you. 

Most web browsers are initially set to accept cookies. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, by disabling them, you may not be able to use certain functions or enter certain parts of our website. 

By continuing to use our website, you accept the use of cookies as outlined above.

Our web pages may also contain electronic images known as web beacons. Web beacons are sometimes referred to as "clear GIF images", "pixel tags" or "single-pixel GIFs". Web beacons are usually invisible to a user and are used for many of the same purposes as cookies.

7. Changes to this Statement

We reserve the right to modify or change this Statement from time to time on our website. We encourage you to check this Statement periodically to read and understand our latest policy and practices regarding the handling of your personal data.

The date as stated below indicates the last time this Statement was revised.

8. Contact Information

For any complaints, questions, concerns about our personal data protection policies and practices, withdrawal of consent, or to request access to, update or correct the personal data within our possession and control, please contact:

The Data Protection Officer
Manulife (Singapore) Pte. Ltd.
8 Cross Street #15-01 Manulife Tower Singapore 048424
Email: SGP_Data_Protection_Office@manulife.com

You may also direct certain correction requests or withdrawals of marketing consent to our Client Services Officers at 6833 8188 or email to service@manulife.com or visit us at the above address during our normal business hours.

Last revised on 27 September 2023

The following section is applicable to employees of Manulife Bermuda only.

Privacy Notice

Our Privacy Commitment to You.

The Manufacturers Life Insurance Company (Bermuda Branch) (“Manulife Bermuda”) respects your privacy. Your trust is one of our most valuable assets. One way we earn your trust is by properly protecting your personal information.

What Does This Notice Cover?

This Notice is intended for customers, clients, participants, distributors, banks, referral partners, and other business partners of Manulife Bermuda. It briefly describes how we collect, use, share and protect personal information as a data controller for the purposes of providing services to our clients. It also describes the rights of individuals whose data we collect, and how you can contact us with questions about personal information or exercise legal rights that may be available to you.

Who We Are

When we refer to “Manulife Bermuda”, “us”, “our”, or “we” in this Notice, we mean the Manufacturers Life Insurance Company (Bermuda Branch) and its affiliates. Manulife Bermuda has a responsibility to adopt suitable measures and policies to give effect to its obligations and to the rights of individuals as set out in the privacy laws in the various jurisdictions in which we operate and where the individuals reside.

Our Privacy Officer oversees how we collect, use, share, and protect your information. If you have questions about this Notice, your rights, or to wish to make a complaint, please contact:

Manulife Bermuda
Attn: Privacy Officer
O’Hara House, 3rd Floor
3 Bermudiana Road, Tower 2 (North Tower)
Hamilton, Bermuda HM08
Email Address: mlbprivacy@manulife.com

What Personal Information Do We Collect and Why?

The type of information we collect varies and depends on your relationship with us and the contract, agreement, product, or service you have with us.

Collecting personal information about you helps us serve you, communicate with you, provide relevant products and services, and improve the administration of our business.

To collect, use and process your personal information, we rely on one or more of the following lawful bases:

• where we need to perform a contract or agreement you have entered into with us;
• where it is necessary for our legitimate interests (such as the operation of our business and to comply with our legal duties or regulatory obligations such as due diligence and politically exposed person checks necessary to comply with anti‐money laundering laws);
• for the protection of your vital interests (e.g., confirm your identity, prevent fraud, etc.); 
• for the performance of a task carried out in the public interest;
• where it is necessary to respond to an emergency that threatens the life, health or security of an individual or the public; and
• your consent. 

We obtain personal information from you when you submit a formal or informal application, enrollment, or other similar forms, as well as from transactions and other interactions with you. This information includes:

• Personal data: Name, address, email address, telephone number, date of birth, tax identification number and citizenship;
• Financial data: Income, assets, banking information, and investment preferences,
• Health data: Medical, and health-related information and habits;
• Interaction data: Data collected when you visit or use our websites, mobile applications, and social media sites.
• Sensitive Personal Information: The types of data we collect may include data relating to your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health and your sex life or sexual orientation and data relating to criminal convictions or offences. We will obtain your consent before collecting and using this type of data unless we are compelled to do so by a legal or regulatory order. 

Our websites use ‘cookies’ and similar technology. A cookie is a small text file placed on your device when you visit our websites. They help us make the sites work better for you, diagnose technical problems, and for security purposes. We also utilize cookies for certain advertising and marketing purposes and to monitor responses to some of our advertisements and electronic communications. More details about how we use data collected from visitors to our websites and information portals, is available at https://www.manulifebermuda.com/privacy.html.

We may also obtain information from third parties and publicly available sources, such as your insurance agent, broker, financial consultant, employer, consumer reporting agencies, medical providers, data service providers, social media services, business partners, and insurance support agencies.

If you do not provide the personal information we need (or help us keep it up to date when requested), we may not be able to continue to perform all or part of the contract we entered into with you, continue to provide you with our products and services, or be able to comply with our legal and regulatory obligations.

How Do We Use and Share the Personal Information We Have Collected About You?

All financial services companies need to use and share customers' personal information to provide services to them. We use your personal information mainly to communicate with you, complete transactions that you have requested or authorized, administer your policy or account, and to make you aware of additional products and services that we offer.

As permitted or required by law, your personal information may be shared:

• with employees and associates, when their jobs require it, to process and service your contracts, benefits, or accounts;
• with your financial consultant, representative, or firm in order for them to service your policy or account;
• with third parties that perform services on our behalf; 

Note: These third parties are required to have comparable information protection safeguards in place. They are contractually bound to use your information only to perform those services. They are not permitted to use or disclose your information for their own marketing purposes.

• with companies from which we purchase reinsurance coverage;
• to conduct routine or required activities such as audits and tax filings;
• to participate in research studies or to conduct surveys; and
• in response to subpoenas and court orders, or to comply with legal requests made by law enforcement and regulatory authorities.

We will use your personal information only for the purposes for which it was obtained, unless we reasonably consider that we need to use it for another purpose which is compatible with the original purpose for which you provided it to us. If we need to use your personal data for a purpose that is unrelated to the original purpose for which you provided it to us, we will notify you and explain the legal basis which allows us to do so.

We will not sell to or share your information with any unaffiliated company for the purpose of that company marketing its own products or services directly to you.

How Do We Protect the Personal Information We Have Collected About You?

We have administrative, physical, and technical safeguards in place that are intended to protect your personal information. Our employees respect your personal information and are trained to keep it safe. You should be aware that we will never ask for your personal information (such as account numbers tax identification numbers, or passwords) through an unsolicited email or phone call.

How Long Do We Retain Your Personal Information?

We need to retain the information we have gathered about you to meet regulatory oversight, tax laws, and other legal obligations to which we are subject. The length of time we retain personal information depends on your relationship with us. If you are a customer, for example, we will retain your personal information for no longer than is necessary for its use from the date your account is closed, policy surrendered or other relationship ends, unless a longer retention period is required by law. We will assess and, where appropriate, securely delete the information to ensure it is not retained for longer than reasonably necessary.

Processing of Your Personal Information Outside of Your Country of Residence

Manulife Bermuda’s data centers, websites and applications are hosted in the United States and Canada. Your personal information will be processed subject to contractual restrictions regarding confidentiality and security in accordance with applicable data protection laws and regulations. We will not disclose your personal information to third parties who are not authorized to receive it. We have administrative, physical and technical safeguards in place that are intended to protect it and help ensure it receives an adequate level of protection as it does in the country in which you reside. 

Your Rights

You have rights, which you can exercise in relation to the personal information we hold about you. In certain circumstances you have the right to:

• Request a copy of your personal information and further details about its processing;
• Request an update or correction to it;
• Request its deletion in certain circumstances where the personal information is no longer relevant for the purpose of its use;
• Request that we cease, or not begin, to process your personal information for the purpose of advertising, marketing or public relations; 
• Request that we cease, or not begin, to process your personal information where the use of your personal information is likely to cause substantial damage or substantial distress to you or another person;
• Be informed and to decide on the processing of your personal information, as well as the right to restrict or deny another person from the processing of your personal information, unless otherwise provided by law or administrative regulations;
• Require that we explain our rules of processing of personal information; and
• Request the transfer of your personal information to another person or entity. 

If you want to exercise one of these rights, please contact us in writing.

Making a Complaint

If you have a complaint about our use of your personal information, please let us know by contacting our Privacy Officer in writing at the mailing address or email provided in this Notice.

While we would appreciate the opportunity to address your concern first, you also have the right to make a complaint at any time to the Office of the Privacy Commissioner in Bermuda.

Changes to this Notice

This Notice is effective as of June 2022. We may make changes to it from time to time. You can always find an up-to-date version on our website or can contact us for a copy.