What is Personal Information?
“Personal Information” means information about an identifiable individual. For clarity, information that by itself cannot be connected to an identifiable individual is not considered Personal Information.
Why is Personal Information collected and used?
Square One collects and uses your Personal Information for the purpose of:
- promoting, offering, quoting, and selling insurance to you;
- improving our website and the various services offered to you on it;
- processing and administering your insurance policies and any renewals or changes in coverages for which we act as your agent;
- adjudicating your insurance claims;
- contacting you in compliance with the law; and,
- complying with the law.
We will limit the Personal Information we collect about you to that which is needed to meet these purposes.
Please be aware that, as part of our use of your Personal Information, we may transfer it for processing in jurisdictions outside of Québec (if you are a Québec customer) and Canada, which may not have laws that provide privacy protections that are substantially similar to those in Québec or Canada.
Will Personal Information be disclosed to others?
We will only disclose your Personal Information to:
- the insurer and/or reinsurer of your policy to underwrite your policy, adjudicate claims, fulfill its obligations under your policy, and comply with the law;
- independent contractors of Square One or your insurer to investigate, assist with, or adjudicate your claim;
- consumer reporting agencies and appropriate regulatory or industry entities, as governed by the law;
- any other third party, if the disclosure is reasonable for the purposes of detecting, suppressing, or preventing fraud that is likely to be committed;
- any other third party, if authorized to do so by the law; and,
- any other third party, if you provide us with your express consent to do so.
How is Personal Information collected?
We collect your Personal Information:
- during all telephone conversations you have with us, which we will record only with your express consent for our mutual protection and to improve the service we offer to you;
- from all written and electronic communications that you have with us;
- when you use our website or mobile app;
- from any publicly or commercially available source of information; and,
- from consumer reporting agencies with your consent as required by the law.
By volunteering your Personal Information to us, you are providing your consent for us to collect, use and disclose your Personal Information as described in this Policy. If you provide us with Personal Information about others, you represent that you have obtained their consent for us to collect, use and disclose their Personal Information as described in this Policy.
We will make every reasonable effort to keep your Personal Information accurate and up to date.
Our employees and/or independent contractors, and the employees and/or independent contractors of our insurer and/or reinsurer, will have access only to the personal information they need to perform their duties.
How is Personal Information retained?
We retain your Personal Information for as long as necessary to meet our obligations to you and our legal, regulatory, and contractual obligations. We are subject to various provincial and federal laws and regulations with different minimum retention periods, including limitation periods, which may vary depending on the circumstances. Therefore, we may retain your Personal Information for as long as it serves its identified purpose, even if you are no longer a customer with us.
How is Personal Information disposed of?
Subject to applicable laws, once your Personal Information is no longer required for the purposes for which it was collected, we will dispose of, de-identify, or anonymize that Personal Information.
How do we use and collect Personal Information through our website or mobile app?
When you use our website or our mobile app, we may place cookies on your device. A cookie is a piece of data stored on your device by the website you visit and collects information such as your IP address and details about your device, operating system, browser, and browsing preferences. This information is saved by your browser for the next time you visit the webpage. You can opt out by setting your browser settings to disable cookies. However, this may prevent you from accessing parts of our website or mobile app or prevent parts of our website or mobile app from working as intended.
How is Personal Information used for online advertising?
When you use our website or our mobile app, Google and other select advertisers may place cookies on your device. These cookies allow us to display online advertisements to those who visited our website. We cannot identify specific users with these cookies.
Google can associate your browsing history, IP address and device information with your Google account to personalize ads; other advertisers can do the same. To better protect your privacy, and to prevent online advertising, you can:
- disable third-party cookies;
- opt out of digital advertising by visiting the National Advertising Institute or Digital Advertising Alliance websites;
- update your Google ads settings; and,
- opt out of Google Analytics.
We may use website traffic data from Google Analytics to help us understand how visitors use our website and mobile app, evaluate, and improve the effectiveness of our marketing campaigns, and to improve the user experience.
What safeguards protect Personal Information?
We will always:
- use all reasonable physical measures, technical tools, and organizational controls at our disposal to protect your Personal Information from misuse or inappropriate disclosures;
- ensure that the contracts provide appropriate safeguards to protect the confidentiality of your Personal Information.
Managing or deleting Personal Information
Please email email@example.com if you wish to:
- withdraw your consent to our collection, use, and/or disclosure of your Personal Information; and,
- access, change, or delete your your Personal Information.
Our system may make automated decisions (decisions made without human involvement) using Personal Information provided to us, regarding:
- whether or not to offer you a policy; and,
- what terms and conditions are applicable to your policy.
What recourse is available?
The individual responsible for the protection of Personal Information is our In-House Legal Counsel. You are encouraged to contact firstname.lastname@example.org to:
- request access to your Personal Information in our control, including transcripts of recorded calls;
- correct any of your Personal Information that may be inaccurate;
- request a review of an automated decision;
- address any complaints you may have about our collection, use, disclosure, or protection of your Personal Information; or,
- withdraw your consent to our collection, use, and/or disclosure of your Personal Information; however, this means that we may not be able to continue to provide you with insurance products and services, or the best rate on your insurance policy. Alternatively, you may specifically withdraw your consent for the use of your Personal Information for marketing purposes.
Please note that the ability to withdraw your consent to our collection, use, and/or disclosure of your Personal Information is subject to certain restrictions, which means that we will not be able to accommodate the request if we are required to retain the Personal Information due to legal, regulatory, and/or contractual obligations, including if the Personal Information is still required for the purposes for which it was collected.
You can also contact the Office of the Privacy Commissioner of Canada (or the Commission d’accès à l’information, if you are a Québec resident) if you are not satisfied with our response.
In-House Legal Counsel
Square One Insurance Services Inc.
Suite 1410, 650 West Georgia Street
Vancouver, BC V6B 4N8