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 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. More details about how we use data collected from visitors to our websites and information portals, is available at www.manulifebermuda.com/privacy.html

We may also obtain information from third parties and publicly available sources, such as your insurance agent, broker, financial advisor, 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 advisor, 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 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.

MBD120325044-5