Consent to collection, use and disclosure of personal information

Users of The Vitality Group website or application (“app”) or the Manulife Vitality program are required to provide certain personal information in order to receive products and services. By providing such information, you are agreeing that The Vitality Group, Inc. and its parents, affiliates, subsidiaries, employees, directors and agents (“Vitality”, or “we,” “us,” and “our “) will collect, use, store, process, access, review and disclose such personal information as set forth in this Consent.

Our definition of personal information means information about an identifiable individual, such as:

• your name; mail address; telephone number; email address
• user name and password
• demographic information, such as age, date of birth and gender;
• health status; geolocation or other geographic location information;
• employment information, such as position and years of service;
• communications preferences;
• health and fitness information, such as medical history, illnesses, disabilities, fitness level and participation in health and wellness related activities (including exercise activities, frequency of exercise, participation and completion of classes and courses);
• reward and point redemptions (“Vitality Rewards”);
• correspondence and other information that you send to us;
• where applicable, payment information, such as such as credit card number, expiration date and CVV code;
• additional information as otherwise described to you at the point of collection or pursuant to your consent, or as required or permitted by applicable law.

We may collect your personal information through our website or app or the Manulife Vitality Program and use such information for management, oversight and general administration of your membership in the Manulife Vitality Program, including to:

• determine your eligibility for the Manulife Vitality Program and other incentives and rewards;
• provide you with the products, services, promotions, newsletters and information you request, and respond to correspondence, queries or requests that we receive from you;
• customize and personalize your use of the Manulife Vitality Program;
• contact you with surveys, legal notices and other information that are relevant to your use of the Manulife Vitality Program;
• maintain and administer the Manulife Vitality Program (such as suggesting personal pathways, calculating points, calculating rewards, shipping/processing rewards); maintain and administer other incentives and rewards (such as sharing information for discounted premiums); perform business analyses; or for other internal purposes to improve the quality of our business, the Manulife Vitality Program and other products and services we offer;
• where applicable, bill for services and products provided to you for which there is a charge;
• compile statistics for analytical and marketing purposes;
• protect the legal rights, safety, and security of Vitality and The Manufacturer’s Life Insurance Company (“Manulife”),Manulife’s parents, affiliates, subsidiaries, employees, directors and agents, Manulife plan sponsors;  and the users of Vitality’s and Manulife’s products and services; enforce our terms and conditions of use; prevent fraud or other misuse (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required; and
• as otherwise described to you at the point of collection or pursuant to your consent, or as required or permitted by applicable law or required or recommended by any government authority (including a privacy commissioner).

When you sign up for the use of apps, devices or other technology with the Manulife Vitality Program, you may choose to have those apps, devices or other technology share information with Vitality for the purposes listed above.

In order for Vitality to administer the Vitality Rewards such as mall incentives and discounts, additional payment information may need to be provided, such as such as credit card number, expiration date and CVV code. Your participation in these incentives is completely voluntary and not required to utilize the Manulife Vitality Program. We may also use your personal information to notify you of updates, products, services, surveys or upcoming events which we think may be of interest to you. You may, at any time, advise us that you do not wish to receive such notifications from us by contacting us using the contact information below.

The Vitality Group may disclose or transfer your personal information as follows:

• Vitality may share your personal information with Manulife in order for them to provide and administer your incentives, such as discounts on insurance premiums, health plan premium discounts, health club dues subsidies, fitness and activity trackers, and entertainment, shopping and travel rewards and discounts. Such information may include, but is not limited to your Vitality Status level (such as Silver or Gold).
• Vitality may share your personal information, other than your medical and lifestyle information, with Manulife for its reasonable business purposes related to the Manulife Vitality Program, including as necessary to administer your Manulife insurance policy or group benefits plan and to allow Manulife to provide administrative support in respect of the Manulife Vitality Program, as well as for research purposes and the development, marketing, sale and administration of insurance and other financial products to its customers. Manulife may share such information with its agents, third-party partners, affiliates and subsidiaries to enable them to perform functions or services on their behalf.
• With your express authorization and consent, we may also share more detailed information with Manulife in support of the Manulife Vitality Program.
• The Manulife Vitality Program is designed to encourage engagement through various forms of incentives including friendly competition. Voluntary participation in programs including, but not limited to Vitality Challenges may result in your name, status in the challenge, awards won or other information being shared publicly about your participation in that activity.
• We may share your information with our corporate parents, subsidiaries and other affiliated entities for the purposes referred to in this Privacy Statement.
• There are instances in which Vitality may share your personal information with our agents, third-party partners, affiliates and subsidiaries to enable them to perform functions or services on our behalf. These business functions may include order or service fulfillment, email campaign provision, and credit card processing services. These companies are only permitted to share, access, store and/or use personal information for contracted business purposes.
• We may disclose your information to third parties in order to protect the legal rights, safety, and security of Vitality, Manulife and its parents, affiliates, subsidiaries, employees, directors and agents, and the users of our products and services; enforce our terms and conditions of use; prevent fraud or other misuse (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
• If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger, acquisition or business transfer, or in the event of bankruptcy, we may transfer your information to the purchaser(s) or acquirer(s) as part of those transaction(s).
• We may also share information about you with third parties in other circumstances when you consent to such sharing (including when you post information to a public area of our website, such as a chat room, discussion board, forum, blog, or other community tool) and otherwise as required or permitted by applicable law or required or recommended by any government authority (including a privacy commissioner).
• We may disclose to third parties analytics and other information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

As part of our business operations, where permitted by law, your personal information may be collected, stored, processed, accessed and transferred in and to the United States and/or South Africa. Please note that privacy laws in such jurisdictions may differ from those of your jurisdiction, and that your personal information may be accessed by law enforcement authorities or the courts in such jurisdictions. You may obtain information and address questions about the privacy policies and practices relating to handling of your personal information outside of your jurisdiction by contacting our Privacy Officer using the contact information below.

In order to evaluate and improve the Manulife Vitality Program, we may share de-identified data with third party researchers to study engagement, health improvements and website improvements.

You can obtain our full privacy policy here.

Privacy Officer:

Email: Lauren.Prorok@vitalitygroup.com
Telephone: 312-224-7100
or write to: 120 S Riverside Plaza Suite 400 Chicago, IL 60606