Last Updated: August 17th, 2023
- Define the purposes of our collection of your Personal Information;
- Obtain valid and meaningful consent for that collection;
- Limit collection, use and disclosure of your Personal Information;
- Ensure your personal information is correct, complete and current;
- Ensure security measures are adequate to protect your Personal Information;
- Maintain a retention and destruction timetable;
- Respond to complaints, inquiries and requests to access your Personal Information;
- Address breach and incident-management protocols;
- Assess potential risks to your Personal Information;
- Deliver appropriate privacy training for our employees.
Ultimately, we use your Personal Information to provide you with the Services.
We aim to collect, use and disclose only such information as is required to enable us to manage your account, to provide the Services, to maintain our customer/user lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, and for service improvement.
More specifically, the purposes for which we collect, use, and disclose your Personal Information are listed in the Use and Disclosure Section below. Generally, the purposes are to:
- provide you with our products and services, including through third-party suppliers;
- better understand your needs and preferences;
- maintain responsible commercial relations with you;
- determine your eligibility for products and services and recommend products and services to you;
- develop and enhance our products and services;
- market products and services that may be of interest to you;
- manage our business operations;
- detect, suppress or prevent fraud and manage and secure our networks; and
- meet our legal and regulatory obligations.
We also rely on third parties for your consent when you access the Services using devices or software that you have disclosed your personal information to, and those services are permitted to disclose it to us.
We may also seek your express consent to the collection, use or disclosure of your personal information. Most often, we will seek your express consent when it is highly sensitive or required for a new purpose. We may obtain your consent by your checking of a box, your acquiescence to an agreement or your taking another affirmative action.
Two types of information may be collected through the Website and our Services: Personal Information and Website Information.
“Personal Information” is personally identifiable information, such as your name, address, e-mail address, credit card information, address, birth date and gender. At the time of collection, we will clearly identify the Personal Information being collected and the purposes for which it will be used.
“Website Information” is information we collect when you visit our Website, such as an Internet Protocol Address (IP Address), the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the Website.
We may collect Personal Information in respect of the Website through a registration process, request form submissions, financial product and service quote inquiries, communications with you, user support, online tools, and expert advice services.
We also collect aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website. Similarly, business contact information such as the name, title, business address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information when such information is used for the purposes of contacting the individual in their business/professional capacity.
In addition to the Personal information we collect directly from you, we also work with third parties to more fully understand your journey from requesting a quote to receiving a financial product. This information received from third parties is collected in accordance with that party’s privacy policies and may include: date of approval for the financial product, the policy type of product, the finalized value, and whether and what other products may have been bundled with the product you inquired about.
Use and Disclosure
We use and disclose your Personal Information for the following purposes:
- Request Forms: If you request more information about a certain third-party product or service listed on our Website you may be required to input certain Personal Information, such as name, contact information, address, and certain other information depending on the nature of the third party product or service you are interested in. If you submit such a request form, we will send the information contained in the form to the applicable third party offering the product or service. Any Personal Information that we provide to third parties will be treated in accordance with the terms of such third party’s own privacy policies, which you should read.
- Online Tools: As part of the Services, we may offer tools such as a mortgage calculator, Canada child benefit calculator, RESP calculator, TFSA Room calculator, and credit card finder. If you use these tools, we collect the Personal Information you provide (such as your income, RESP balance, credit score, etc.) in order to provide you with the features and functions of the tools.
- Auto Insurance: If you request a quote for auto insurance on the Website, we collect Personal Information related to the driver like date of birth, sex, marital status, job status, driving history, licence class, insurance status, name of current insurer, price of current insurance per month, details regarding any accidents or insurance violations the driver and details about the vehicle include the year, make and model, and number of kilometers driven per year. Necessarily, we will have to disclose this information to auto insurance companies, brokers, or other parties to get you a quote.
- Home Insurance: If you request a quote for home insurance, we collect information such as details regarding your property like address, type of property, and mortgages on the property; Personal Information about the occupant such as first and last name, date of birth, job status, years of property insurance, email address, and damage claims history, occupation and rental information); and property construction details like year property was built, type of exterior, number of bathrooms, property’s estimated replacement cost, and square footage.
- Life Insurance: If you request a quote for life insurance, we collect information such as details regarding the applicant’s coverage needs such as type of coverage, coverage amount, and optional insurance products; and Personal Information about the applicant like first and last name, date of birth, location, sex, smoking habits, email address, and phone number.
- Mortgage Application: If you complete a mortgage application form on the Website, we collect Personal Information including your first and last name, email address, phone number, province, date of birth, address history, annual income, financial institution, employment status and other employment-related information, and financial assets. We will also obtain your consent to obtain your credit report from a credit reporting agency. We share your credit report and other information provided on your application form with potential mortgage lenders so that they can assess your eligibility for a mortgage, and we may also share information with financial intermediaries and mortgage insurers as necessary to offer and provide services to you. Your credit report may include information such as the types and amounts of credit advanced to you, payment histories, negative banking items, collection actions, legal proceedings, previous bankruptcies and other information reported by your creditors. You will have authorized credit reporting agencies to provide such information to us. If we are unable to obtain your credit report based on your name, date of birth and mailing address alone, we may request you to provide other information, such as your social insurance number, on an optional basis which we will use to help us identify you with a credit reporting agency.
- Credit Card Applications: We may also use and disclose your Personal Information to facilitate your applications for credit cards on our Website. We will collect Personal Information such as: first and last name, email address, phone number, date of birth, address and address history, annual income, employment status and other employment information, financial assets, and social insurance number. We may either collect this information and disclose it to a specific credit card provider, or use the information to assess the best credit card for you and provide the information to the applicable credit card providers.
- Location Information: Certain third-party products and services are only available in certain areas, and therefore we may ask for your location, either by requesting your postal code, province, city, and/or address or by using Website Information.
- Marketing Communications and Product Recommendations: If you sign-up to receive marketing communications from us, we collect your name and email address to send you information about our product and services and those of our partners that may be of interest to you. We may also use the information we have about you as well as information obtained from third parties to provide you with personalized product recommendations on the Website. You may withdraw your consent to receiving marketing communications or product recommendations from us at any time by following the opt-out instructions in each communication, or by contacting our customer service department at [email protected].
- Statistics: We also collect statistics about your use of third-party products and services that you request information about through the Website. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
- IP address: Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases. We use this information to improve our Services.
- Analytics: We may use third party software such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
- Interest-Based Advertising: Advertisements appearing on the Website may be delivered by us or one or more third-party web advertisers. We may allow these third-party web advertisers to set cookies or other similar technologies on the Website that collect information about you, including Website Information. As the information is collected on the Website, strictly speaking, we disclose this information to the advertiser. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you.
- Improving our User Experience: We may also use the Personal Information you provide us to access other Personal Information available about you from third parties, in which case the information about you we access from third-parties was collected in accordance with that third-party’s privacy policies. For example, if you seek an auto insurance quote from us, we may access your driving and insurance history from a third-party provider. We also work with third-parties such as ad networks and other advertising companies that use their own tracking technologies, including cookies and pixel tags, on our Website in order to provide you with tailored advertisements on our Website and across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
We disclose your Personal Information solely to carry out the purposes listed above. We engage third parties to directly provide the services underlying the above purposes as service providers to: improve our Website, host our Website, provide advertising services, provide email marketing services, provide cloud services, and engage in analytics for advertising services. These third parties may have limited access to databases of user information solely for those purposes and they will be subject to contractual restrictions prohibiting them from using the information for any other purpose.
We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website users, other users of the Services, or anyone else that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required or permitted by and in accordance with applicable law.
You may withdraw your consent to our collection, use, or disclosure of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using all the features available on the Website and/or the Services.
For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests. To opt out, you must have cookies enabled in your web browser. To do this, see your browser’s instructions for information on cookies and how to enable them. When you opt-out, it only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
Protecting your Information
Our servers (and certain service providers) are also located in Canada and accordingly your Personal Information may be available to the Canadian government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.
We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Services to third parties.
Access and Accuracy
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. This amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
If you are a user who is also a resident of Quebec, you have specific rights with respect to your Personal Information by virtue of the Act Respecting the Protection of Personal Information in the Private Sector, as amended by Law 25 and we are committed to upholding those rights. Accordingly, we have appointed a Person in Charge of Personal Information (the “PCPI”), who can be contacted by emailing [email protected]. The PCPI is the individual ultimately responsible for ensuring our compliance with all rules, regulations, and laws with respect to Personal Information in Quebec. In addition to the PCPI, we will be implementing Privacy Impact Assessments whenever we implement a new Information or Electronic Service Delivery System and whenever a new relationship is set up that could involve your Personal Information being disclosed to a third party outside Quebec. At present, the Personal Information of Quebec residents is disclosed outside Quebec in certain circumstances, these include:
- During normal business operations when Personal Information is accessed and used by us, for the purposes already identified in this Policy, but our workforce is located outside Quebec; and
- To share the Personal Information that you provide to us with a third party to offer you a product or service you have requested.
We also recognize that Quebec users have certain rights with respect to their Personal Information. You are entitled to exercise these rights and they include:
- Access and Rectification: you may request access to any Personal Information in our possession and ask to correct it if it is inaccurate, incomplete, or equivocal.
- Control of Dissemination: you can request that we stop disseminating your Personal Information or de-index any hyperlink providing access to you Personal Information.
- Data Portability: by the Fall of 2024, you will have the right to request that we give you a copy of the computerized PI that we have in our possession.
We will respond to these requests in the time allotted by the Commission – usually 30 days.
Amendment of this Policy
You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions, if you find any errors in our information about you, or for more information on the manner in which we or our service providers use your Personal Information, please contact our customer service team at: [email protected].