Privacy policy and use of personal data

Here you can find information about what personal data we collect from you either via the website or other interactions with you, what we do with that information, who we may share it with and why, and your choices and rights when it comes to personal information you have given us.

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 of 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 via 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 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.
    Where we need to comply with a legal or regulatory obligation.

Your legal rights

Under certain circumstances, if you are an individual, you have rights under data protection laws in relation to your personal data as set out below:

  • 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.
  • 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.
  • 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 share your personal data with any third party marketing agencies. We may share your information with other affiliated companies within the Manulife group of companies if we have a legitimate interest for doing so. We may also 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, direct 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.

Transfers of data to a country outside the European Economic Area (the “EEA”)

We may share your information with Manulife affiliated companies in non-EEA states. To the extent that your information is shared outside the EEA, 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.
  • We may enter into a specific contract with the recipient of your personal data which has been approved by the European Commission which gives the personal data the same protection it has in Europe.

The main countries to which your information may be transferred are:

  • Canada
  • United States
  • Hong Kong
  • Singapore

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 Asset 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 GDPR, 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.

Under GDPR, you 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 Asset 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, via 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:


FAO Data Protection Officer
Manulife Asset Management (Europe) Ltd
1 London Wall London EC2Y 5EA
dpo_europe@manulifeam.com
T: 020 7256 3500