Statement of Privacy Principles and Practices (the Policy)

At Manulife Bank, we respect your privacy

At Manulife Bank of Canada1, protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business. As a member of the Manulife Financial affiliated group of companies2,we strive to help provide you with the best customer service. To us, that includes treating you fairly and with respect.

Manulife Banks Statement of Privacy Principles and Practices (the Policy) informs you of the ways we help protect your privacy and the confidentiality of your information. We may amend this Policy from time to time. We will post the revised Policy on our website (www.manulifebank.ca).

In this Policy, the words "you" and "your" mean any person, or that person's authorized representative who has requested from us, or offered to provide a guarantee for, any product service or account offered by us in Canada. The words "we", "us" and "our" mean Manulife Bank. The word "information" means personal, financial and other details about you that you provide to us and we obtain from others outside Manulife Bank.

Ten Privacy Principles

Manulife Bank abides by Ten Privacy Principles. These Principles are based on the federal government's privacy legislation, the Personal Information Protection and Electronic Documents Act. In addition to our Policy, our Online Privacy Statement, our Statement of Voiceprint Password Privacy and our practices and procedures to manage your personal information, define the high standards we set for ourselves to help manage and protect your personal information.

1. Accountability: We are responsible for personal information under our control. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.

2. Identifying Purposes: The purposes, for which personal information is collected, will be identified by us, or through our or your authorized representatives.

3. Consent: Your consent is required for the collection, use and disclosure of personal information, subject to certain exceptions. Such exceptions are set out in the law and include where legal, medical or security reasons make it impossible or impractical to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our or your authorized representatives. In certain circumstances, it may also be implied.

4. Limiting Collection: The collection of your personal information must be by fair and lawful means, and be limited to that which is necessary for the purposes identified.

5. Limiting Use, Disclosure and Retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may only be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.

6. Accuracy: Any personal information that is collected, used or disclosed should be as accurate, complete and as up-to-date as is necessary for the purpose for which it is to be used.

7. Safeguards: Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.

8. Openness: Information about our privacy policies and practices for managing your personal information shall be made available to you.

9. Individual access: Upon written request, you will be informed of the existence, use and disclosure of your personal information and you will be given access to it, subject to certain exceptions, as permitted by law. You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate.

10. Inquiries and concerns: You may contact us if you have any inquiries or concerns about our privacy policies and practices.

What you should know about our privacy practices

At the time you begin a relationship with us and during the course of our relationship, we may collect information about you. We obtain most of our information about you directly from you, including your visits to our website. For every product or service we offer, we require various types of information to complete our application process. This would include things such as your name, address, birthdate, occupation and other forms of identification. This information is required to establish and serve you better... as our customer.

For any product or service you obtain from Manulife Bank, we will tell you the purposes for which any personal information is collected. We will also tell you how we will use and share your information. We will collect, use and share information from you and about you, only with your consent, or as required or permitted by law.

The information we collect

We will use fair and lawful means to collect your personal information. We will only collect information that is pertinent and consistent with the purposes of the collection. We may collect the required information directly from you, or from your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet, and through your business dealings with us.

We may collect your personal information through public sources such as the Internet or through other third party service providers. In some cases, and with your consent, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers we retain, other banks or financial institutions, your employer or credit reporting agencies.

If your information is being collected by telephone, the call may be recorded or monitored for the following reasons:

  • To establish a record of the information you provide;
  • To take or verify instructions from you;
  • To confirm your identity;
  • To maintain quality service levels; and
  • To assist in staff training.
  • If you are not comfortable with having your telephone calls recorded, you have the option of communicating with us in writing instead. Where you have chosen to only communicate with us in writing, your written communications should request that any response to you be in writing, as well.

    What we ask you for and why

    The type of personal information we may ask for depends on the product or service you are requesting. For example, if you were applying for a loan or a bank account, the information gathered may be financial, which would include such information as occupation and place of employment, annual income, assets and liabilities. It may also include information such as your date of birth or reference numbers of identification documents, such as your passport or other documents.

    Generally, we collect, use and disclose your information to:

  • Confirm your identity and to protect both you and us against errors, fraud or other misrepresentations;
  • Evaluate your financial needs and determine the suitability of our products and services for you;
  • Determine your eligibility for, and provide you with information about, products and services;
  • Properly administer the products and services we provide to you;
  • Support and maintain the accuracy and integrity of the credit reporting system, which includes your past credit and repayment history as well as other financial transactions;
  • Communicate to you with regards to the administration of your products;
  • Comply with a variety of legal and regulatory requirements, such as provincial and federal tax reporting, anti-money laundering and unclaimed property obligations; and
  • Assist us in understanding your current and future needs, for example, to conduct customer surveys and other forms of market research and analysis.
  • Your Social Insurance Number

    There are a number of reasons why we may ask for your Social Insurance Number (SIN). If the product you are requesting earns interest or there is other income to be reported, your SIN is required by law, in order to meet tax-reporting requirements.

    With your consent, we may also use your SIN as a unique identifier, to keep your information separate from that of other customers, or individuals with a similar name, and to help maintain the integrity and accuracy of your personal information. For example, where it is appropriate to verify your credit history, we may use your SIN to help ensure that the credit information we are asking for - and receiving - is about you, rather than someone else with the same or similar name.

    You may elect not to have your SIN used for purposes other than as required by law; however, this may affect our ability to fully ensure the accuracy and integrity of your information.

    Use of Cookies and Web Beacons

    Some of the information we collect will be gathered, by us or by agents on our behalf, through the use of "cookies" and "web beacons".

    Cookies are small text files that are automatically placed on your web browser in your computer by a web server. Cookies contain information that can be retrieved by a web server in the domain that issued the cookie to you. Cookies can make a website more useful by storing information about your preferences on our websites, which allow us to provide more useful features to you. For more information, visit our Online Privacy Statement.

    Your consent

    Your consent may be expressed in writing, verbally, electronically or through our, or your, authorized representative(s), such as your financial services advisor.

    Your consent may also be implied or inferred from certain actions. For example, if you present your driver''s license as identification to your advisor, it is understood that you are giving your consent to your advisor to provide us with your driver''s license reference number to be kept in our files. Or implied consent may be obtained through your use of a product, or when you approach us to obtain information, inquire about or apply for products, or services from us.

    In order to continue to grow our business and provide you with new innovative products and services, we may, from time to time, inform you of new uses or disclosures of your personal information. Depending on the nature or sensitivity of your personal information to be used or disclosed, your consent may be implied or in some cases, we may seek your express consent. Where we will rely on your implied consent, we will provide you an opportunity to ask questions or to "opt out" of the new uses or disclosure.

    You may withhold or withdraw your consent for us to collect, use and disclose your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested, such as your bank account or loan. For example, if you withdraw your consent for us to evaluate your credit history in relation to your existing loan, depending on the situation, we may not be able to properly monitor our credit risk and demand that you repay your loan in full.

    Sharing your information

    Your personal information will be accessible by or shared with those who have a need for, and the right to, the information including:

  • Our employees, agents and representatives who need the information in the performance of their duties for us;
  • Our affiliates, to resolve your concerns about any related products and services or assist in other required investigations;
  • Service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us;
  • Other institutions that may have granted you credit, credit bureaus and personal information agents with respect to your credit or financial history;
  • Any person or organization to whom you have provided consent; and
  • Anyone who is otherwise authorized by law, for example regulators, law and enforcement agencies and other government agencies.
  • In some cases, your personal information will be provided to these people, organizations and/or service providers in other provinces or jurisdictions outside Canada and would, therefore, be subject to the laws of those provinces or jurisdictions.

    Service providers

    We use service providers to provide us with various services such as debit and credit card services, printing, mail distribution, data storage, information technology services, insurance services, administration, marketing (which would include market research and promotional services) and investigation. Where your personal information is provided to our service providers, we will require them to protect the information in a manner that is consistent with our privacy policies and practices.

    Affiliates

    At Manulife Bank, we offer various loan products that enable you to purchase investment products offered by our affiliates. If you have a question or concern about these related products, we may need to confer with our affiliates, to help ensure that we address your questions or concerns properly and in a timely manner.

    Our affiliates may also have access to your personal information, when providing us with certain services, such as information technology services or other services, as described in the Service Providers section, above.

    Since all Manulife Financial companies abide by common privacy principles and practices, our customers have the assurance that the same commitment to privacy is maintained in their dealings with any of the Manulife Financial group of companies.

    How we keep your information up-to-date and accurate

    We will make all reasonable efforts to help ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of changes, such as changes in your contact information.

    Accessing and amending your information

    You have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate. Depending on the circumstances, we may not always be able to give you access to all information, or there may be a charge for doing so. Should this happen, we will let you know.

    Much of your information is available to you online by accessing your account via the Internet. For other information, you may use our toll free number to contact our Customer Service Centre or you can send a written request to our Privacy Officer (for details, refer to our Contact us section below).

    We are committed to protecting your information

    We are committed to protecting your information with appropriate safeguards and security measures. We have security standards (that are appropriate to the sensitivity of the information) to help protect our systems and your information against unauthorized access and use.

    Your personal information is protected:

  • Physically, by building security measures and physical barriers;
  • Organizationally, by our policies, procedures and access levels; and,
  • Technologically by, for example, where appropriate, the use of passwords, encryption, firewalls, anti-virus and anonymizing software.
  • All our agents, service providers and suppliers, as part of their contracts with Manulife Bank, are bound to maintain your confidentiality and are not permitted to use your information for any unauthorized purpose.

    If we receive a request to release your personal information, we will only do so upon satisfactory identification and proof of entitlement of the requestor, or as required or permitted by law.

    At Manulife Bank all employees must act in accordance with the requirements of Manulife's Code of Business Conduct & Ethics ("the Code"). Included within the Code are the requirements of safeguarding customer information.

    Retention and destruction of your information

    We will only keep your personal information for as long as it is needed to fulfill the identified purposes or as required or permitted by law. Personal information that is no longer required will be destroyed, erased or made anonymous. When we destroy personal information, we will use safeguards to prevent unauthorized access to the information during the destruction process.

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

    Some of our business areas may, from time to time, offer or promote other financial products and services, or those of our affiliates and select third parties, that we believe may be of interest to you. These offers or promotions may be in print or in the form of electronic communications, such as email. We will share personal information with our affiliates and select third parties for these purposes, only with your consent or if the law permits it.

    We do NOT give your personal information, without your consent, to any organization outside of our affiliates for the purpose of that organization marketing their own products or services directly to you.

    Print Marketing

    If you do not wish to receive our marketing offers or special promotions by mail, you may choose to "opt out", by contacting us, and we will remove your name from our mailing lists. This means you will not be eligible to receive addressed, direct mail offerings.

    This opt-out will not extend to:

  • Information included in or with monthly statements, which relate to any Manulife Bank or Manulife Trust product or service that you currently have with or receive from us;
  • General product and service information and updates included in or with client statements; or
  • Email and telephone marketing, unless you specify otherwise.
  • To remove your name from any marketing mailing list that we maintain, please contact us by telephone or mail. Please note: When you contact us to remove your name and address from our marketing mailing lists, we will use all reasonable efforts to do so in a timely fashion.

    Electronic Marketing

    We require your consent to send you our marketing offers or special promotions by electronic means (such as email). Under Canada's Anti-Spam Legislation (CASL), as our customer we have your implied consent to send you electronic messages unless you notify us otherwise. You may do this by using the unsubscribe feature found in any electronic message we send you or at any time by contacting us by telephone or mail. We will remove your name from our electronic mailing lists within 10 business days of receipt of your request.

    Contact us:

    If you have any questions or concerns about privacy, or you want to know more about the process for accessing and / or correcting your information, or opting-out of marketing offers, please contact us. If you choose to mail us, please include your full name, address and telephone number.

    Mail:

    Manulife Bank of Canada

    Privacy Officer

    500 King Street North

    P.O Box 1602

    Waterloo, Ontario N2J 4C6

    Telephone: 1-877-765-2265

    Website: www.manulifebank.ca

    1This document applies to Manulife Bank of Canada ("Manulife Bank" or "the Bank") and its wholly owned subsidiary, Manulife Trust Company ("MTC" or the "Trust Company"). Unless specifically mentioned otherwise, all references to the Bank include its subsidiary, Manulife Trust Company.

    2Affiliated companies include The Manufacturers Life Insurance Company ("Manulife") - Canadian Division Operations, Manulife Securities Inc., Manulife Securities Investment Services Inc., Manulife Securities Insurance Inc., Manulife Mutual Funds and First North American Insurance Company.