Privacy Policy and Notice and Statement of Privacy Principles and Practices

Who we are

In this Privacy Notice, “we,” “us,” and “our” mean The Manufacturers Life Insurance Co. (Phils.), Inc. (Manulife Philippines), Manulife Financial Plans, and Manulife Investment Management and Trust Corporation (MIMTC). “You” and “your” mean individuals whose personal information we are collecting, using, processing, sharing, transferring or disclosing.

The information we collect and how we collect it

We collect personal information fairly and lawfully, and only when it is necessary and relevant for identified purposes. We may collect information directly from you or your authorized representative(s) through completed applications, forms, and other means of communication, such as phone calls, mail, websites, mobile applications, and other online channels, as well as through your business interactions with us. We may also collect personal information from third parties, such as employers, healthcare providers, banks, other financial institutions, or regulators, with your consent or as permitted by law.  As part of our obligations in the financial services industry, we are required to verify your identity and, where applicable, the identity and authority of your authorized representative(s). For this purpose, we will request supporting documents or, in certain cases and with your consent, obtain additional information from independent sources. These sources may include your employer, doctor, other financial institutions, credit reporting agencies, and healthcare providers or facilities.

If you prefer not to have your telephone calls recorded, you may choose to communicate with us in writing. In such cases, our response to you will also be provided in writing. 

What we need to know and why

The type of personal information we process will depend on the product or the service you avail from us.

Generally, we process, collect and maintain your personal information:

• To verify and confirm your identity;
• To approve, facilitate, administer, and process your investment application and transactions;
• To evaluate your financial needs, suitability and risk profile;
• For underwriting, policy issuance, fund management, trust and investment management and administration and account maintenance;
• For after-sales servicing, including claims processing, benefit payouts, redemptions, transfers, settlements, including the generation of statement of account, billing notices and reinsurance of your policy, if necessary;
• To comply with legal reportorial and regulatory requirements of local and foreign regulatory authorities, including local and foreign tax authorities and stock exchanges;
• To comply with court orders, lawful requests, legal, regulatory, reporting or contractual obligations of any Manulife entity within the Manulife Financial Group on information sharing, tax reporting or otherwise;
• To prevent money laundering or terrorist financing activities, including conducting customer due diligence, know-your-customer, fraud prevention, sanctions screening, and financial crime detection;
• To comply with Manulife’s internal purposes such as governance, operations, administrative, audits, management of risks, reporting, studies which include actuarial, financial, credit risk, investment risk, claims experience, research and analysis to improve pricing and product design;
• To adhere to reasonable purposes that are relevant or related to your insurance, investment and other financial products and services;
• To better understand your current and future needs through data analytics, behavioral modeling, digitization and the use of automated data processing tools and artificial intelligence technologies to support customer service, fraud detection, risk assessment, operational efficiency, and limited-decision making, and to promote Manulife products and services effectively;
• To improve overall customer experience and relationship management, customer service, communication, product enhancement and gather feedback and measure your satisfaction;
• To provide incidental services such as business process improvement, system upgrades, testing and operational efficiency initiatives;
• To decide on any insurance, investment, or related claim, including enforcing or defending the rights of Manulife;
• To strengthen risk assessment and prevent fraud by uploading your personal and medical information to the Medical Information Database pursuant to Insurance Commission Circular No. 2016-54 among others; and 
• To send you information about Manulife, subsidiary, affiliate or business partner products, services, promotions and offers that may be relevant to you, subject to your consent. You may opt out of receiving marketing or sales communications at any time, without affecting the products or services you currently have with us.

During the effectivity of your investment account or contract/policy, you also agree to the following: in case we are unable to comply with relevant customer due diligence (CDD) measures, as required under the Anti-Money Laundering Act, as amended and relevant issuances, due to your fault, we may apply the following: (a) measures to restrict the services available or prohibit any further transactions on the account or  contract/policy until full and proper CDD measures have been successfully conducted; and (b) in case the foregoing is unsuccessful, terminate the business relationship. In which case, you shall only be entitled to receive, either the unused portions of premium or withdrawal value, if any, whichever is applicable. You also agree to be bound by obligations set out in relevant United Nations Security Council Resolutions relating to the prevention and suppression of proliferation financing of weapons of mass destruction, including the freezing and unfreezing actions as well as prohibitions from conducting transactions with designated persons and entities.

Data Retention

We will keep your personal information in our records only for as long as necessary to fulfill the identified purposes, or as required or permitted by law. Personal information that is no longer required will be securely disposed of or anonymized with appropriate security safeguards.

Child and Minor Privacy Notice

We recognize the importance of protecting the privacy of children and minors. When personal data relates to a child or minor, we collect and process such information only with the consent of a parent or legal guardian, or as permitted by law. Information relating to a child/minor is processed for legitimate insurance, investment, trust, or legal purposes, such as coverage, benefits, or regulatory compliance. We apply heightened safeguards to protect personal data of minors. If you are a parent or legal guardian and believe we have collected a child’s personal data improperly, please contact us immediately using the DPO contact details in this Privacy Notice.

Your consent

By providing us your personal data (including the data of third parties), and any subsequent changes to it, you give us your consent, represent that you have obtained the necessary consent of any third parties or are otherwise authorized by law to provide such information, and explicitly authorize us to collect, use, process, store, share, transfer and disclose the personal data for the purposes stated in this Privacy Policy and Notice.

For those acting on behalf of corporations and partnerships, by providing us with the personal data of your directors, officers, employees, members and other individuals, you also represent that you have obtained the necessary consent of such parties.

You may withdraw your consent, unless restricted by legal or contractual obligations.  However, withdrawal may limit our ability or prevent us to service your policy or investments account and may result in the termination of the product or service.

We disclose personal data only as necessary for the purposes described in this Privacy Notice and subject to applicable law and appropriate safeguards. It will be accessed by those who have a need and the right to it, including Manulife, our directors, employees, agents, and representatives, including our entity shareholders, business partners, affiliates, and our subsidiaries, any member of the Manulife Financial Group (including those located overseas), advisors, industry associations and databases, local and foreign authorities having jurisdiction over companies within the Manulife Financial Group (including tax authorities and stock exchanges), external auditors/counsels, and our third party service providers (whether within or outside the Philippines), and others authorized by law. For cross-border transfers, we implement contractual, organizational, and technical measures designed to protect personal data and limit access to authorized persons.

Service providers

We may use service providers for various services such as printing, mail distribution, information technology, data storage, administration, marketing (including market research and promotional services), medical/paramedical, investigation, and reinsurance. Our service providers are contractually required to protect your personal information in a manner that is consistent with our privacy policies, principles, and practices.

Accessing and amending your information

We ensure that any personal data we collect and keep in your file is accurate, complete, and updated for the identified purposes. We will rely on you to give us accurate information and to update us on any changes.

If your contact information changes, please contact us right away.

You have the right to access and verify your personal data in our records, and to request that it be corrected or updated, with certain exceptions such as where the correction requires an order from a competent court or other government agency. Depending on the particular circumstances of your request, you may verify the accuracy and completeness of your information and request changes, if appropriate. We may require reasonable fees to cover administrative costs to obtain your requested personal data. Please be assured that we will let you know when this happens.

We are committed to protecting your information

We are committed to protecting your personal data from unauthorized use, access, disclosure, loss or alteration. We ensure that reasonable and appropriate physical, organizational, and technological safeguards are in place to keep your data safe.

Personal data is protected:

• Physically, by such means as controlled access to offices, building security measures, physical barriers and secure storage of records;
• Organizationally, by such means as our privacy policies, practices and defined access levels, training and incident response procedures;
• Technologically, by such means as authorization, authentication, encryption, infrastructure and network protection, malicious content detection and virus intrusion prevention and other means. For example, we employ encryption technologies and authentication standards to safeguard the transmission of information over the internet.
  
  

All employees, representatives, and agents get information protection and ethics training every year. Our information security team works together to help ensure your personal data is protected by the right safeguards. All of our third party service providers, who act on our behalf or with whom we share your information, are required to abide by our privacy policies, principles, and practices and to have and maintain appropriate security measures in accordance with industry standards. If we receive a request to release your personal data, we will only do so upon satisfactory identification and proof of entitlement of the requestor, or as required or permitted by law.

We regularly review and improve our security controls to address evolving risks and technologies. While no system can be guaranteed to be completely secure, we take appropriate steps to safeguard personal information through its lifecycle. 

Special offers and marketing promotions... it's your choice

From time to time, we may send you marketing communications about our products and services, or those of our subsidiaries’, affiliates’, business partners’, and select third parties’ that we think you might have interest in.

We will share your personal information, limited to your name and contact details, with our subsidiaries, affiliates, business partners and select third parties for these purposes, only if permitted by law and with your consent.

You may opt out of marketing communications at any time by contacting us through the channels stated in this Privacy Notice including the DPO contact details below to remove your name from our mailing, calling or electronic mailing lists.

When you opt-out, you still receive information from us about the products and services that you have with us and general product and service updates or information.