Privacy information

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 this Notice covers

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 certain 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 Bermuda Personal Information Protection Act (PIPA).

Our Privacy Officer oversees how we collect, use, share, and protect your personal information. If you have questions about this Notice or your rights 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 categories of personal information we collect vary depending on the nature of the contract, agreement, product, or service you obtain from us.

Collecting personal information helps us service your policy, facilitate necessary communications, 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 lawful bases including but not limited to:

• when we need to perform a contract or agreement you have entered into with us;
• when 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 Know Your Customer (KYC) requirements);
• for the protection of your vital interests (e.g., confirm your identity, prevent fraud, etc.);

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

• Personal data: Name, address, email address, telephone number, date and place of birth, gender, marital status, government ID such as a passport, citizenship and beneficiary information, tax identification number;
• Financial data: Source of income, assets, banking information, and investment preferences;
• Health data: Medical and health-related information and habits including medical history and diagnoses;
• Interaction data: Data collected when you visit or use our website, customer applications, and social media sites;
• Sensitive Personal Information: As defined by PIPA, the types of sensitive  personal information we may collect could include but not limited to information relating to your race, ethnic origin and data relating to criminal convictions or offences. There may be times where particulars of sensitive personal information may be voluntarily provided to us and when this does happen, we will maintain confidentiality of those details. If we require other sensitive personal information from you, we will obtain your consent before collecting and using this type of sensitive personal information unless we are compelled to do so by a legal or regulatory order;
• Other supporting documents such as but not limited to identity verification, wills, death certificates, power of attorney, Corporate or Entity information. 

Our website uses “cookies” and similar technology. Cookies are text files containing small amounts of information which are sent to your browser and stored on your computer, tablet, smartphone or other device when you visit a website. Cookies collect and store information about your browsing patterns and information you provide; helping websites remember users and tracking their activities to provide a personalized experience. Cookies are also used to help diagnose technical and service problems and for security purposes. More details about how we use data collected from visitors to our websites and information portals, please refer to the Online Privacy Statement.   

We may also obtain or share information from or with third parties and publicly available sources, such as your financial representative, servicing firm, banking providers, broker employer, medical providers, data service providers, social media and online 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 we use and share the Personal Information we have collected about you

We use your personal information to complete transactions that you have requested or authorized and to administer your policy.

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 policy contract, its features and benefits if applicable;
• with your financial representative or firm in order for them to service your policy;
• with third parties* that help us conduct our business or perform services on our behalf;
• with companies from which we purchase reinsurance coverage;
• to conduct routine or required activities such as audits and tax filings; 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 and we will not sell or share your personal information with any unaffiliated company for the purpose of that company marketing its own products or services directly to you. 

How 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 policy, 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 personal information we have collected 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 client for example, we will retain your personal information for no longer than is necessary for its use from the date your policy is closed or your relationship with us 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.

Storing of your Personal Information

Manulife Bermuda’s data centers, websites and applications that store your personal information are hosted in the United States, Singapore, Japan 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

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

• Request access to the personal information that we hold about you, how it is being used, who we are sharing it with and where we obtained it from;
• Request an update or correction; and
• Request its deletion and destruction in certain circumstances where the personal information is no longer relevant for the purpose of its use.

If you want to exercise one of these rights, please contact your firm or write to us at the address noted above. As part of your written** request, please include information that may help us identify you and your up-to-date contact details. Please note that if your request is incomplete, we may ask you for further information.

Request to withdraw consent 

If you wish to request to withdraw your consent to any use of your personal information as set out in this Notice, you may contact your firm or us at the address noted above. However, please note that your request may not be able to be granted due to our contractual, legal and regulatory obligations.

Making a complaint

If you have a complaint about the use of your personal information or your rights in accordance with PIPA, please contact your firm or alternatively you can visit the client complaint resolution page found here for further details.

We respond to privacy-related complaints in accordance with our complaint resolution process. The Privacy Officer will help ensure your privacy concerns are appropriately addressed. In the event that you are not satisfied with the results of the resolution of your complaint, please contact your firm or alternatively you may file a complaint with the Office of the Privacy Commissioner of Bermuda by submitting a written request form found at www.privacy.bm/intake-form.

Updates to this Notice

We may make changes to this Notice from time to time, but the most current version is always posted on our website as described above. The last time we updated this Notice was in March 2026.

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

**If you decide to submit your request by email, please note the security of email communication cannot be guaranteed. Do not send us information of a private or confidential nature by email. By contacting us via email you are authorizing us to communicate with you by email.  

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