Management and protection of personal information policy for mobile application users
Last update: June 17, 2019
We are committed to respecting our clients’ right to privacy. As a result, we have put measures in place to effectively manage and protect your personal information in accordance with the applicable laws.
This policy applies to users of The Personal mobile application (the “Application”). It includes information about how your personal information is managed and protected when you download the Application and use its features, which include Ajusto®, AlertTM, RadarTM, Insurance and Photo-Based Estimate (the “Features”).
We answer the following questions for each of the Features:
- What personal information do we collect?
- How is your personal information used?
- To whom do we disclose your personal information?
Also, when you use the Application, information about you may be stored in cookies installed on your device. Some cookies are needed to use our Application, while others are used to optimize and personalize the content you see.
By agreeing to the conditions of use for each of the Features and by using the Application, you agree to the collection, use and disclosure of your information in accordance with the applicable sections of this policy.
Here are some definitions of terms used in this policy:
We/us/our means The Personal.
Personal information means any information pertaining to a specific individual which, alone or in combination with other information, can be used to identify that individual.
You/your means any individual who has downloaded the Application.
This policy should be read in conjunction with the terms and conditions specific to the Ajusto, Alert and Photo-based estimate Features. You can view these terms and conditions in the “More” section of the Application.
We are responsible for the personal information we have under our control, including personal information entrusted to third parties, and have put safeguards in place to ensure the confidentiality of that information.
We collect only the information required for the purposes specified in this policy. We obtain personal information primarily from you but may also obtain it from external sources with your consent and within the limits authorized by law. We may also collect personal information through our service providers.
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 your personal information to external sources in accordance with legal and applicable regulatory requirements or generally accepted insurance practices. Personal information that we have about you will be retained only for as long as it is required to fulfill the purposes identified in this policy. When personal information is no longer required to fulfill the identified purposes, or for any other legal requirements or otherwise, it will be destroyed, erased or made anonymous.
We retain the services of external service providers to administer certain components of the Application’s Features. If we need to send personal information about you to these providers, we ensure that appropriate contractual or other means are in place to provide a comparable level of protection and to ensure that your personal information is sent in a secure manner. In addition, we only send information that is necessary for providing services, and we ensure that such information is only used in accordance with this policy and the terms and conditions of the Features.
We may share personal information about you with external service providers located outside Canada or who store your information outside Canada. In that event, your personal information is subject to the laws of that country and therefore, may be accessible by the authorities of that country.
We have appropriate safeguards in place to protect your personal information against loss or theft, and against unauthorized access, disclosure, copying, use or modification. Personal information contained in your file is accessible only to individuals authorized and qualified to access such information, and only when such access is required in the course of their duties.
Application of The Personal Privacy code
Please refer to the following sections of The Personal Privacy code, which apply to the Application with any necessary adjustments:
- Customer Access
- Challenging Compliance
What information is collected by the Application and how is it used and disclosed?
Once you have downloaded the Application, we ask you to provide us with personal information such as your first name, last name, province, email address, cell phone number and insurance policy number in order to create your account and validate your identity.
Your email address and cell phone number are used to send you notifications about the Application’s Features. You can choose not to receive notifications from the Application at any time by changing your Communication preferences under Account settings in the “More” section of the Application.
To find out more about the personal information collected when you activate the Features, refer to the following sections:
We ask for your date of birth to validate the activation of the Ajusto Feature.
We also ask for authorization to access your geolocation, which is needed to use Ajusto during the collection period (100 days and 1,000 km travelled). Once the collection period has ended, you can disable the Application’s geolocation service at any time from your mobile device settings.
When Ajusto is activated, the following personal information is collected about the enrolled driver (the “Ajusto Data”):
- Smart phone movement data (trip details, distances travelled, length, etc.)
- Accelerometer and gyroscope data (speed, fast accelerations and hard braking)
- Time of day travelled
- Distractions (handling the phone while travelling)
- Anomalies (turning off the phone, revoking access to geolocation information, etc.)
We reserve the right to request that your Ajusto Data be updated as specified in the Ajusto program terms and conditions.
The Ajusto Data is used to calculate your driving score, which may entitle you to a discount based on your driving habits.
Peripheral Ajusto Data (e.g., movements on foot or trips of less than 1 km) is only used to improve the accuracy of the Ajusto Feature.
Ajusto Data could also be used for research and development purposes and to improve our fraud prevention practices. However, these uses has no impact on your file. Ajusto Data will not be used to cancel your insurance policy, to refuse to renew your policy, or to increase your premium.
We retain the services of external service providers primarily to activate the Ajusto Feature and to analyze Ajusto Data. Your information will only be used for the purposes specified in the previous section. Refer to the “Privacy principles” section for more information about our information disclosure practices.
When you activate the Alert Feature and your detector, we ask you to register the location where the detector is installed.
The following information is then collected by the detector (the “Alert Data”):
- Relative humidity and room temperature where the detector is installed
- Dates of events (alerts)
- Reasons for events (detection of water, humidity or freezing, low battery, weak Wi-Fi signal)
- Detector’s status (active or inactive)
The Alert Data is primarily used to generate alerts and prevention messages. It may also be used to improve the performance of the detection system. Some of the data collected when you enrol in the program (mailing address, first and last name) will be used to send you the detector.
We retain the services of external service providers to supply detectors and to analyze the Alert Data. Your information will only be used for the purposes specified in the previous section. Refer to the “Privacy principles” section for more information about our information disclosure practices.
When you use the Photo-based estimate (PBE) Feature, the following information is collected (the “PBE Data”):
- Photos you have taken using the PBE Feature, but only if you send us the photos. This includes information about the photos (date, time and location) and the content of the photos (e.g., vehicle serial number and licence plate).
- The date and time the photos are sent.
Access to your camera and photo files
In order to use the Feature, you must grant access to your device’s camera. We will only have access to photos taken using the Feature, unless you save these photos on your device. By choosing to save the photos, you grant the Feature access to your photo files, but only the photos taken using the Feature will be collected and used.
The PBE Data is used to estimate the damage and process your claim. The data could also be used for research and development purposes to improve the accuracy of our estimates.
We retain the services of service providers, such as body shops, and we send them the PBE Data and the information required to estimate the damage to your vehicle and to process your claim. Your information will only be used for the purposes specified in the previous section. Refer to the “Privacy principles” section for more information about our information disclosure practices.
To use the Radar Feature and get alerts about severe weather that could cause damage to your home, vehicle or property, you need to register the addresses you want to receive alerts for. To register your addresses more easily, you can authorize the Feature to access your geolocation. You may disable the Application’s geolocation service at any time from your mobile device settings.
The addresses you have registered are converted to geolocation data (longitude and latitude). This data is only used to send you severe weather alerts and prevention tips for the weather events you have selected.
We retain the services of external service providers and we send them the geolocation data for the locations selected for weather alerts. Your information will only be used for the purposes specified in the previous section. Refer to the “Privacy principles” section for more information about our information disclosure practices.
When you access the Insurance section, your email address and password are collected to authenticate you. You are then redirected to the Online Services section of our website. Refer to The Personal Privacy code and the Conditions of use section of our website for more information about how your personal information is managed and protected when you use our Online Services.
Your consent is required for the collection, use or disclosure of your personal information by us, except where not required or permitted by law. When you voluntarily provide certain personal information to us, you are also giving your implied consent for us to collect, use and disclose that personal information in compliance with this policy.
In addition, by downloading the Application, activating and using any of its Features and accepting their specific terms and conditions, you agree to the collection, use and disclosure of your information in accordance with the applicable sections of this policy.
Withdrawal of your consent
Downloading the Application and using each of the Features is entirely voluntary. If you do not agree with any part of the practices for managing and protecting your personal information or with any part of the terms and conditions, do not activate or use the Feature in question.
You may withdraw your consent to the collection, use and disclosure of your personal information at any time by terminating your participation in the Features, subject to legal or contractual obligations which must be fulfilled by us. For more information on terminating your participation, refer to the terms and conditions specific to each Feature or contact us.
Cookies and other tools
When you use our Application or visit our website, information about you may be stored in cookies that we or third parties install on your computer or device.
We may amend this Management and protection of personal information policy at any time. To find out when this policy was last updated, refer to the date of the “Last update” set out at the beginning of this policy. Your use of the Application and its Features will be considered as acceptance of these modifications.
AjustoMD® is a registered trademark of Desjardins General Insurance Inc., used with permission by The Personal. The Ajusto program is offered in Quebec and Ontario only.
Alert and RadarTM are trademarks of Desjardins General Insurance Group Inc., used under licence.