We value your business and thank you for your confidence in choosing CapriCMW as your broker. As our client you trust us with your personal information. We respect that trust and want you to be aware of our commitment to protect the personal information we collect about you.
This Privacy Statement applies to the collection, use and disclosure of personal information by the subsidiaries and operating divisions of CapriCMW listed below (collectively “CapriCMW”, “we”, “us” or “our”). In this document, “you” and “your” refer to any individual whose personal information we collect, use and disclose as described in this Privacy Statement. “Personal information” means information about an identifiable individual.
This Privacy Statement is effective January 1, 2018.
CapriCMW Entities Providing this Privacy Statement
We are providing this Privacy Statement on behalf of CapriCMW entities and operating divisions, including those listed below:
- CapriCMW Insurance Services Ltd.
- Intercity Insurance & Financial Services Inc.
- Intercity Insurance Services Inc.
- Capri Wealth Management Ltd.
- CapriCMW Benefits Inc.
We will only collect, use and disclose your personal information with your consent, except as otherwise permitted or required by law. Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (either orally or in writing) or implied (for example, when you provide information necessary for a service you have requested, or where notice has been provided to you about our intentions with respect to your personal information and you are given the option to “opt out” from such purposes).
Typically, we will seek consent in advance or at the time of collection, and make reasonable efforts to ensure that you understand the purposes for which we will use or disclose personal information. In certain circumstances, we may seek consent regarding use or disclosure after personal information has been collected, but before use, such as when we wish to use personal information already in our possession for a purpose that was not previously identified.
If you obtain insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him or her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his or her personal information in accordance with this Privacy Statement.
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. There may be consequences to failing to provide or withdrawing your consent, such as your inability to acquire or renew an insurance policy and/or cancellation of a policy. Note also that in some circumstances you may not be permitted to withdraw consent to certain uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and foreign government entities as required by applicable law).
We may be permitted or required under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or for debt collection purposes.
Personal Information We Collect
We collect personal information only to the extent required for the purposes that you provide consent. Subject to any legal requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected.
Personal information we may collect includes:
- Name, address, email address, telephone number, and other contact information;
- Age, birth date, social insurance number, ID numbers, gender, drivers license number, credit card numbers or license plate numbers;
- Information about your preferences, income, assets or personal finances;
- Medical records, credit records, loan records, driving record, employment records, insurance or transaction history;
- Information about your insurance claims or claims history; and
- Such other information we may collect with your consent or as permitted or required by law.
We generally collect personal information directly from you offline and online from forms that you complete for our products and services, or when you communicate with us. We may also collect personal information about you offline and online from third party sources, such as other insurance brokers, insurance companies, consumer reporting agencies, industry associations, data banks, product suppliers, marketing agencies, government agencies, claims adjusters, employers and inspectors.
Use of Personal Information
We use personal information to understand your insurance needs, communicate with you effectively, provide you with products and services you request, and otherwise manage and administer our business. For example, we may use your personal information to:
- Determine your eligibility for, offer and/or provide you with insurance products and services that you request;
- Evaluate and monitor credit eligibility, and collect premiums and fees;
- Verify your identity;
- Determine prices, fees and premiums by evaluating your coverage needs and assessing risk;
- Maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services;
- Investigate and settle claims;
- Determine your eligibility for and offer and provide other products or services that may be of interest to you such as investment or retirement products or group benefits, unless you ask us not to;
- Detect and protect against error or fraud;
- Compile statistics and conduct market research;
- Maintain business records for reasonable periods;
- Meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and
- Otherwise with your consent or as permitted or required by law.
What we will not do with your information
We will not sell your personal information to anyone, nor will we share your personal information with organizations outside of CapriCMW entities and their affiliates in accordance with this Privacy Statement.
Disclosure of Your Personal Information
As necessary to carry out the purposes for which we collect and use your personal information, we may disclose your personal information to third parties, such as other insurance brokers, insurers, consumer reporting agencies, claims adjusters, government, regulatory and self-regulatory agencies, lawyers, financial institutions, benefits providers, medical professionals and others involved in the claims handling process in accordance with legal and insurance regulatory reporting requirements or standard practices. We may also disclose your personal information with your consent or as permitted or required by law.
Disclose to Affiliates
We may transfer personal information to our affiliates for internal audit, management, billing or administrative purposes. We may also disclose personal information to our affiliates so that they may send you information about products and services that may be of interest to you. However, if you do not want your personal information disclosed for such marketing purposes, you may opt-out at any time by contacting us at one of the addresses listed below (See: Contacting Us).
We may transfer personal information to outside agents or service providers that perform services on our behalf. The services that may be performed by our agents or service providers consist of data processing, data warehousing, administrative services, or other services to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. If we transfer any personal information to an outside service provider, we will provide the service provider only with the information needed to perform the services and will use contractual or other means to provide a comparable level of protection while the information is being used by them.
Personal information may be used by us and disclosed to third parties connected with a proposed or completed business transaction, including a sale of all or part of our assets, for the purposes of evaluating or completing the transaction. These purposes may include, as examples:
- Permitting those third parties to determine whether to proceed with the transaction; and
- Fulfilling reporting, inspection or audit requirements or obligations to those parties.
In the event of a transaction that proceeds, we will require that the receiving party agree that they adhere to the terms of this Privacy Statement and that they will only use and disclose your personal information as we are entitled to under this Privacy Statement. In the event of a transaction that does not proceed, we will require that the receiving party return or destroy your personal information without using or disclosing it further.
We take reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, copying, use and disclosure. The safeguards applied will depend on the sensitivity of the personal information, with the most sensitive personal information, such as medical information, receiving the highest level of protection. Access to your personal information will be restricted on a “need to know” basis to our employees, contractors and other persons who require such access to do their jobs.
Access and Correction
Subject to applicable legal restrictions, you may request to have access to the personal information we have about you, and in the event of any inaccuracy or incompleteness of such information, you may request that the information be amended as appropriate. You should advise us immediately if you discover any such inaccuracies or if your personal information changes. All notices and requests should be in writing and sent to our privacy officer at one of the addresses listed below (See: Contacting Us).
We have designated a privacy officer who is accountable for our compliance with this Privacy Statement, and for ensuring that information about our policies and practices relating to the handling of personal information is easily accessible. If you wish to make any inquiries or complaints, obtain information on how to access or correct personal information in our possession, or have any concerns about our personal information practices, you may write to the address below. Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request in a timely manner.
CapriCMW Insurance Services Ltd.
100-1500 Hardy Street
International Transfer and Storage
In some cases, such as the transfer of personal information to outside service provides as discussed above, your personal information may be transferred, processed or stored outside of Canada, including in the United States, and may be available to governmental authorities under lawful orders and laws applicable in such jurisdictions. We will use reasonable means to ensure that your information is protected in such circumstances, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada.
Privacy Statement Changes
This Privacy Statement may be revised from time to time. We will undertake to provide you with notice of any such changes. Nonetheless, we urge you to frequently review this Privacy Statement or contact us at one of the addresses listed above (See: Contacting Us) to obtain the current version.