Privacy Code

Date of last update: December 17, 2018

Previous version

At The Personal Insurance Company (hereinafter “The Personal”), an important part of our commitment to provide our customers with service excellence is our respect for their right to privacy. Keeping our customers' personal information in strict confidence is a cornerstone of The Personal's business. Accordingly, The Personal has adopted this privacy code which details the privacy principles that are to be followed.

Some definitions of terms used in this privacy code:

  • “affiliated general insurance companies” means:
    • The Personal General Insurance Inc. in Quebec
    • Desjardins General Insurance Inc. in Quebec
    • Certas Direct Insurance Company in Alberta and Ontario
    • Certas Home and Auto Insurance Company in Ontario, Alberta and New Brunswick and its agents.
  • "personal information" means any factual or subjective information in any form about an identifiable individual but does not include the name, title or business address or telephone number of an employee
  • "third party" means an individual or corporate entities outside of and not affiliated with The Personal
  • "we" means The Personal
  • "you" means any individuals about whom we collect Personal Information in order to carry out the business of property and casualty insurance. It includes our insureds and any other persons to be insured under your policy, former insureds, applicants, claimants and individuals involved in a claim. It does not include commercial and corporate entities, or individuals carrying on business in sole proprietorships, in partnerships or in other associations.

To learn about our policy when you use the Desjardins Insurance Home-Auto application, read our Management and protection of personal information policy for mobile application users.

Accountability

We are responsible for all personal information under our control and we have designated a person who is accountable for our compliance with this Privacy Code.This person has delegated other individuals within our company to act on their behalf and to assist them in their role.

If we are required to send personal Information to a third party, we will use contractual or other means to provide a comparable level of protection by the third party.

We have established and implemented policies and procedures to give effect to this privacy code in order to protect your personal information and to receive and respond to customer complaints and inquiries.

Identifying purposes

We collect, use and disclose your personal information for the purposes of providing insurance products and services. More specifically, we collect, use and disclose necessary personal information from you, as well as from and to third parties, where applicable, in order to:

  • assess your application for insurance, which includes, in Ontario, verifying information such as prior claims, convictions and annual kilometres
  • manage risk
  • communicate with you concerning our insurance products and services
  • underwrite and service your insurance policies
  • process claims involving you
  • prevent, detect and prosecute fraud
  • analyze business results and for statistical purposes
  • obtain your feedback about our organization, products and services
  • promote insurance products and services
  • update the information we have about you
  • act as required or authorized by law.

If we intend to use or disclose your personal information for a different purpose than those stated above, we will obtain your consent first, unless the new purpose is required or allowed by law.

Under no circumstances will your personal information be sold or inappropriately disclosed to third parties.

We share limited personal information such as your name, address, telephone number and date of birth with our affiliated general insurance companies to make it faster to identify you and to provide you with products and services that suit your needs. Additionally, we share further personal information with The Personal General Insurance Inc. about your transactions and interactions with us. 

Consent

Your consent is required for the collection, use and disclosure of your personal information by us, unless otherwise required or permitted by law.

When you voluntarily provide certain personal information to us, you are also giving your implied consent (if express verbal or written consent has not otherwise been requested) for us to collect, use and disclose that personal information to fulfill the identified purposes.

In certain circumstances, we may ask you to provide us with the personal information of other people to be insured or already insured under your insurance policy. When you provide us with another person’s personal information, you undertake to obtain their consent to provide us with said personal information and to us using it according to this privacy code.

You may withdraw your consent at any time, with reasonable notice, subject to legal or contractual obligations which must be fulfilled by us. Withdrawal of consent may prevent us from providing you with the requested insurance products or services including processing an application for insurance and processing a claim.

Limiting collection

The amount and the type of information we collect shall be limited to that which is necessary to fulfill the identified purposes. We will obtain personal information primarily from you. We may also collect personal information from other external sources including other property and casualty insurers, public and private sector underwriting or claims information databases, and credit reporting agencies.

Limiting use, disclosure and retention

We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as may be required or permitted by law.

We may be required to disclose personal information to external sources in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance practices.

We may store and/or share personal information about you with those performing services for us located outside of Canada. In this event, we ensure that appropriate contractual or other means are in place to protect your personal information. Your personal information is, however, subject to the laws of that jurisdiction and therefore, may be accessible to the authorities of that jurisdiction.

Personal information that we have about you will be retained only as long as it is required to fulfill the identified purposes. Where personal information is no longer required to fulfill the identified purposes, or for any other legal requirements under the law or otherwise, it will be destroyed, erased or made anonymous.

Accuracy

We will use our best efforts to keep your personal information as accurate, complete and up-to-date as is necessary for the identified purposes for which it is to be used.

We will generally rely on you to provide updated information, such as changes to your address and other contact information.

If you successfully demonstrate to us that personal information on file is inaccurate, we will revise or correct the personal information on file. Personal information which includes a matter of opinion will not be considered inaccurate information and will not be subject to correction or amendment.

Safeguards

We will protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, with appropriate safeguards.

Customer access

You have the right to access and correct the personal information we have on file about you. To get access to your personal information on file with us, contact Customer Relations Centre in writing at the address listed below. Upon receipt of your written request, we will respond to you within 30 days or such later date as may be permitted or required under the law.

Your access to personal information may be limited or denied, but only under those circumstances permitted or where we are required under the law.

Cookies

When you visit our website or use our application, information about you may be stored in cookies that we or third parties install on your computer or device.

This section explains what cookies are and describes which web and mobile measurement tools we use and how we use them. It also explains your options with regard to these technologies.

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A cookie is a small data file created by your browser or our application when you visit our website or activate our application. It is stored on your device. Cookies are used to remember information about you to facilitate your authentication and improve your experience. Some cookies are needed to use our website or the application, while others are used to optimize and personalize the content you see. 

We use 2 types of cookies:

  • Session cookies: This type of cookie is temporarily stored in your device’s memory and is deleted when your session ends. Session cookies are used to identify you and are deleted when you leave our transactional site.
  • Persistent cookies: This type of cookie is saved on your device and recalled every time you visit. Persistent cookies are text files, which means they cannot be used for harmful purposes like infecting a device with a virus or any other malicious data.

A web beacon is a tiny image placed on a website, in our application interfaces or in an email. It can be used to anonymously track the number of times a page is visited. Web beacons are invisible and can be found anywhere on our website or in our promotional messages. Unlike cookies, web beacons are not stored on your device.

Cookies and web beacons collect personal information such as your language preferences, your province and certain online behaviour (for example, the number of pages you visit, how long you spend on each page, promotional banners you have clicked, etc.). We store the information we collect by matching it to unique identifiers linked to the application, the browser or the device you are using. This allows us to store your language preferences for all your browsing sessions, for example, or show you relevant ads. While a unique code in the cookie file or web beacon allows us to identify you as a user, it does not contain your name or address.

We use web and mobile measurement tools to:

  • Provide a secure browsing experience and verify your information. Using measurement tools means we do not need to save information about you every time you go to a new page. We can also store information about your sessions to identify you when you visit our website or use our application.
  • Remember your settings and preferences. Measurement tools allow us to remember your preferences, such as your province and preferred language.
  • Compile statistics. We use measurement tools to find out, among other things, which of our website pages or application sections are most popular, the average number of pages or sections visited, and the average amount of time spent on our site or in the application to help us improve our services.
  • Analyze our performance. Measurement tools help us learn what our users like most and what we may need to change.
  • Provide advertising that is relevant to you. We use web and mobile measurement tools to show you online offers on our websites and other websites. We also use them for retargeting and remarketing purposes and to limit the number of ads you see. For more information, see the section on interest-based advertising below.

We use web analytics tools (like Google Analytics and Adobe Analytics) and advertising tools provided to us by advertising partners like Google, Facebook and Twitter. As a result, these partners may have access to the information collected by cookies and web beacons when you visit our website or use our application.

You can disable the personalization features on our sites by blocking cookies in your browser. If your browser is not set up this way, click the link that corresponds to your browser to change the settings.

To block cookies when using the browsers on your mobile device, refer to the procedure for turning cookies on or off in the Chrome and Safari apps.

Blocking cookies may prevent some pages on our site or some parts of our application from displaying correctly, and some features may not be available. For you to be able to use our Online Services, your browser must allow cookies.

You can choose not to allow your information to be used for interest-based advertising by turning off personalized ads and by installing add-ons or extensions that prevent the sharing of information with Google Analytics.

We also use Facebook’s custom audience feature to create interest-based advertising for our clients. You can opt out of seeing these ads by following the procedure to opt out of Facebook’s custom audiences.

Please note that these operations do not prevent the collection of your navigation data. To achieve this, you can refuse cookies by following the procedure in the previous section.

Even if you opt out of interest-based advertising, you may still see The Personal ads. However, the ads you see will not be customized to your needs and may appear more frequently.

For your convenience, we provide links to the sites of third parties. However, we have no control over the content or operation of these sites, nor do we control the confidentiality or privacy practices of the site operators. The owners of these sites may install cookies or web beacons when you click ads or links to their websites. Any personal information you submit through such sites is governed by the privacy policies of the sites in question. It is therefore your responsibility to find out about their policies in order to protect information that concerns you.

Openness

If you have any inquiries about this privacy code, contact Customer Relations Centre.

  • By mail:
  • Customer Relations
  • The Personal Insurance Company
  • P.O. Box 7065, Station A
  • Mississauga (Ontario) L5A 4K7

Challenging compliance

We have established an internal complaint review process and will investigate all complaints regarding privacy. If a complaint is found to be justified, we will take appropriate measures to correct the situation.

If you believe that we are not complying with this privacy code, please contact our Customer Relations Centre.

If your complaint cannot be resolved through our internal complaint review process, or if you prefer, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or with your applicable provincial Privacy Commissioner.

We may amend this privacy code from time to time. You can determine when this privacy code was last modified by consulting the date of the “Last Update” set out above. Your continuing relationship with us shall be deemed as acceptance of and agreement to any such modifications.