Notice to Customers relating to the Personal Data (Privacy) Ordinance (“Notice”)

Definitions

1. “Data access request”, “data correction request”, “data subject”, “data user”, “direct marketing”, “matching procedures” and “personal data” used throughout this Notice shall have the meaning as defined in the Ordinance.

For the purpose of this Notice:

“customers” shall, for the purpose of this Notice, mean data subjects and include (but not be limited to) existing and prospective insurance policy owners, insured, beneficiaries and other persons designated or entitled to receive moneys and/or other benefits under an insurance policy; and members under an occupational retirement scheme; and scheme members under a mandatory provident fund scheme; and share/unit holders of investment funds; and any individuals from whom Manulife may collect personal information, regardless of whether they currently hold a policy or have a formal business relationship with Manulife.

“Hong Kong” shall mean the Hong Kong Special Administrative Region.

“Manulife” shall mean Manulife (International) Limited, Manulife Provident Funds Trust Company Limited, Manulife Investment Management (Hong Kong) Limited, or a Manulife Fund (as the case may be) in respect of its respective customers.

“Manulife Fund” shall mean any investment fund sponsored or managed from time to time by a member of the Manulife Group (including but not limited to Manulife Global Fund and Manulife Advanced Fund SPC) and “Manulife Funds” shall mean all such investment funds.

“Manulife Group” shall mean Manulife Financial Corporation and its subsidiaries and affiliates from time to time (including but not limited to Manulife (International) Limited, Manulife Provident Funds Trust Company Limited, Manulife Investment Management (Hong Kong) Limited), and Manulife Funds. The rights and obligations of each member of Manulife Group under this Notice are several and not joint. No member of Manulife Group shall be liable for an act or omission by another member of Manulife Group.

“Ordinance” shall mean Personal Data (Privacy) Ordinance (Cap 486).

Collection

2. From time to time, it is necessary for customers to supply Manulife with personal data for various purposes, including but not limited to, the establishment or continuation of interactions, or the provision of products or services. Providing personal data to Manulife is voluntary, but failure to supply such data may result in Manulife being unable to establish or continue Manulife’s various engagements or provide products or services.

3. Personal data is also collected or received by Manulife from any person acting on the customer’s behalf or other sources available to Manulife, in the ordinary course of interactions, for example, when an application is made for a change of beneficiary/insured member under the insurance policy; or when notification is made by the employer of a change of employment/address of an employee member of an occupational retirement scheme/mandatory provident fund scheme; or when a joint share holder of an investment fund applies for investment fund switching.

Purposes

4.  The purposes for which personal data of a customer may be used will vary depending on the nature of the customer’s relationship with Manulife. Such purposes may include the following:

a. processing, assessing, determining, and approving applications and/or requests made by customers for products and/or services offered by Manulife;
b. providing services to customers, including but not limited to administering, advisory, investment management, maintaining, communicating, managing, and operating products and/or services provided to customers, including but not limited to confirming the accuracy of information collected;
c. confirming the customer’s identity and uniquely identifying the customer;
d. processing any medical, security, eligibility, and underwriting checks;
e. understanding the customer’s financial situation, such as understanding and evaluating financial appetite and needs, evaluating the customer’s application, assessing the risks taken on by Manulife, and dealing with claims submitted to Manulife;
f. any purposes in connection with any claims made by or against or otherwise involving customers in respect of any products and/or services. In these instances, Manulife may collect, use, and disclose relevant information, including but not limited to, making, defending, analysing, investigating, processing, assessing, determining, or responding to such claims. Apart from the necessary processing associated with such claims, Manulife may also use this information to detect and prevent fraud, whether or not relating to the policy issued in respect of the application;
g. providing investment management services, dealing and advisory services, custody services and other services under the terms and conditions of the accounts a customer holds with Manulife;
h. performing and/or exercising any rights, functions, and activities Manulife may have in connection with the products and/or services offered by Manulife or those by Manulife’s business partners to customers, including but not limited to marketing (see “Use/Provision of Personal Data in Direct Marketing” below), audit, reporting, research, analysis, reinsurance, and general servicing and maintenance of online and other services;
i. researching and/or designing products and/or services for customers, and promoting, improving, and furthering the provision of products and/or services;
j. conducting matching procedures on any data held which relates to customers from time to time for any of the purposes listed herein, whether or not for the purpose of taking adverse actions against customers such as declining an application;
k. making disclosure under and/or complying with, whether compulsory or voluntary, any present or future law, rules, regulations, judgment, court order, sanctions regime, codes of practice, guidelines or guidance, demand, request, or commitment or arrangement binding on or applicable to Manulife or any member of Manulife Group within or outside Hong Kong including but not limited to making disclosure and/or compliance with any court, legal, local or foreign regulatory, governmental, administrative (credit reference agencies or auditors), tax, law enforcements, or other authorities, or self-regulatory and industry bodies, or associations, or federations, or similar organizations relevant to Manulife Group (collectively the “Authorities”);
l. complying with any contractual or other commitment or arrangement with the Authorities that are assumed by or imposed on Manulife or any member of Manulife Group by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction;
m. for operational purposes, credit assessment, credit scoring models, or statistical analysis (including in each case, behaviour analysis and evaluation on the overall relationship with Manulife Group which includes using such data to comply with any obligations, requirements, policies, procedures, measures, or arrangements for sharing data and information within Manulife Group and/or other use of data and information in accordance with any Manulife programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing, or other unlawful activities), whether on the data subjects or otherwise;
n. exercising any rights, including but not limited to subrogation, if applicable, Manulife may have in connection with the provision to customers of products and/or services;
o. verifying and conducting identity and/or credit checks and/or debt collection;
p. determining any amount of indebtedness owing to or from customers, and collecting and recovering any amount owing from customers or any person who has provided any security or undertaking for customers’ liabilities;
q. enabling an actual or proposed assignee, transferee, participant or sub-participant of the rights or business of Manulife or any member of Manulife Group to evaluate and/or undertake due diligence in relation to the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;
r. purposes specifically provided for in any particular service or product offered or to be offered by Manulife; and
s. any purposes relating to any of the above (including seeking professional advice) or any other purposes in accordance with the general policies of Manulife or any member of Manulife Group in relation to insurance, occupational retirement schemes, mandatory provident fund schemes, investment funds, wealth management services and other financial products and services as set out in notices, circulars, or other terms and conditions made available by Manulife or any member of Manulife Group to customers from time to time.

Transferees

5.  Personal data of a customer held by Manulife will be kept confidential, but subject to the provisions of any applicable law. Manulife may transfer such data to the following persons and/or entities (whether within or outside Hong Kong) to fulfil any of the purposes set out in paragraph 4 above:

a. any person in connection with any claims made by or against or otherwise involving customers in respect of any products and/or services provided by Manulife;
b. any agent, contractor, sub-contractor, or third party service provider (including their employees) who provides administrative, financial advisory, legal counsel, telecommunications, computer, information technology, payment, securities clearing, debt collection, data processing or storage, marketing (including direct marketing services), mailing, printing, telemarketing, call centre services, customer satisfaction analysis, distribution, publishing, research, or other services to Manulife or any member of Manulife Group in connection with the operation of and provision of Manulife services to customers, including any custodian, administrator, investment manager, investment adviser or distributor;
c. any credit reference agencies or, in the event of default, any debt collection agencies;
d. any adviser, adjuster, or other intermediary authorized by Manulife for the distribution of products and/or services, including their employees;
e. reinsurers, private investigators, hospitals, clinics, laboratories, health care professionals, technicians, medical service providers, loss adjustors, legal advisers, and financial advisers that may be engaged by Manulife or on behalf of Manulife;
f. charitable or non-profit making organizations;
g. employers of the customers;
h. third party financial institutions, insurers, credit card companies, securities and investment service providers, third party reward, loyal, co-branding programme providers or merchants, or any person which has undertaken to Manulife or any member of Manulife Group to keep such data confidential;
i. any actual or proposed assignee, transferee, participant or sub-participant of the rights or business of Manulife or Manulife Group;
j. any member identified as a Manulife Group, including subsidiary and affiliates;
k. Manulife’s business partners (see “Use/Provision of Personal Data in Direct Marketing” below);
l. any Authorities;
m. organisations that consolidate claims and underwriting information for the insurance industry, fraud prevention organisations, other insurance companies (whether directly or through fraud prevention organisation or other persons named in this paragraph), the police and databases or registers (and their operators) used by the insurance industry to analyse and check information provided against existing information; and
n. any other person in the context of the sale or transfer by Manulife or any Manulife Group of all or part of its business or portfolio of products, policies or other assets or any proposed or confirmed transaction relating to such sale or transfer.

USE OF PERSONAL DATA IN DIRECT MARKETING

6.  Manulife intends to use, from time to time, customer’s personal data in direct marketing of the following classes of products and services:

a. insurance, provident funds and/or schemes, investment funds, wealth management services, or other financial products and services;
b. reward, loyalty or privilege programmes and related products and services; and
c. products and services of co-branding partners of any member of Manulife Group (the names of such co-branding partners can be found in the application form(s) for the relevant products and services as the case may be).

6.1. Only the following kinds of personal data of the customer may be used in such direct marketing:

a. name;
b. gender;
c. date of birth;
d. part of identification document number;
e. contact information (including but not limited to phone number, fax number, email address, correspondence address and residential address); and
f. information about the products and/or services the customer has purchased or applied, including the distribution channels (including their individual advisers or intermediaries) through which the products and/or services were purchased or applied for.

6.2. Manulife will not so use the data unless it has received the customer’s consent (which includes an indication of no objection) to the intended use.

PROVISION OF PERSONAL DATA FOR USE IN DIRECT MARKETING

7.  Manulife intends to provide, from time to time and for money and other property, customer’s personal data to Manulife Group (other than Manulife itself) for use by Manulife Group in direct marketing of the following products and services:

a. insurance, provident funds and/or schemes, investment funds, wealth management services, or other financial products and services;
b. reward, loyalty or privilege programmes and related products and services; and
c. products and services of co-branding partners of any member of Manulife Group (the names of such co-branding partners can be found in the application form(s) for the relevant products and services as the case may be).

7.1. Only the following kinds of personal data of the customer may be provided to Manulife Group (other than Manulife itself) for use by Manulife Group in such direct marketing:

a. name;
b. gender;
c. date of birth;
d. part of identification document number;
e. contact information (including but not limited to phone number, fax number, email address, correspondence address and residential address); and
f. information about the products and/or services the customer has purchased or applied, including the distribution channels (including their individual advisers or intermediaries) through which the products and/or services were purchased or applied for.

7.2. Manulife will not so provide the data unless it has received the customer’s consent (which includes an indication of no objection) to the intended provision.

8.  Under the Ordinance, a data subject has the right to:

a. request access to his or her personal data;
b. request correction of any of his or her personal data which is inaccurate;
c. ascertain and obtain a data user’s policies and practices in relation to personal data;
d. be informed of the kind of personal data held by the data user;
e. be informed of the main purposes for which personal data held by the data user are or are to be used; and
f. make data access request and data correction request through the channel set out in paragraph 9 below.

9.  Manulife has the right to charge a reasonable fee for processing any data access request as provided under the Ordinance. Requests for access and correction of data or for information regarding Manulife’s policies and practices and kinds of data held should be addressed to the Privacy Officer at:

Manulife (International) Limited
22/F., Tower A, Manulife Financial Centre, 223-231 Wai Yip Street,
Kwun Tong, Kowloon, Hong Kong.

Manulife Provident Funds Trust Company Limited
22/F., Tower A, Manulife Financial Centre, 223-231 Wai Yip Street,
Kwun Tong, Kowloon, Hong Kong.

Manulife Investment Management (Hong Kong) Limited
23/F., Manulife Tower, One Bay East,
83 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong

Manulife Global Fund, Manulife Advanced Fund SPC, or any of other Manulife Funds
23/F., Manulife Tower, One Bay East,
83 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong

Updates and Changes

Manulife reserves the right, at any time and without prior notice, to add, revise, update or modify this Notice, by notifying customers of such addition, revision, update or modification. If Manulife decides to change this Notice (or its equivalent), Manulife shall notify customers on the company’s website or in writing so that they are aware of the information that is collected, how that information may be used and under what circumstances that information is disclosed. Any such revision, update or modification will be effective immediately upon posting or as otherwise specified by Manulife.

Important Note: For customers located within the borders of the People’s Republic of China (excluding Hong Kong, Macao, and Taiwan for the purpose of this Notice), please be aware that a specific “Privacy Addendum for Personal Information Protection Law (For Mainland Chinese)” (“Privacy Addendum”) is applicable. This Privacy Addendum is available and can be accessed on Manulife’s website: here.

This Notice is provided in multiple languages to ensure all customers are fully aware of Manulife’s practices and standards regarding personal information handling. In the event of any discrepancies between the translations, the English version will prevail.

(Last Updated: November 2023)