ǿմý Global Risks US, Canada Branch (“ǿմý Commercial,” “we,” “our” or “us”) is a part of the ǿմý Group and provides insurance products and related services in Canada. This Privacy and Security Statement describes how and for what purposes we collect, use, and safeguard information that identifies, describes, or is reasonably capable of being associated with, you (your “personal information”) when you utilize our websites or mobile applications (our “Sites”), or use any of our products or services (the “Services”).
This Privacy and Security Statement does not apply to any sites, applications, or services that are not directly offered by ǿմý Commercial, even if you access such sites, applications, or services via our Services.
Personal Information We Collect
ǿմý Commercial lawfully collects the following types of personal information for the purpose of running our business.
- Contact information and other identifiers such as name, address, email address, phone number, driver’s license number, social security number, or other government-issued ID numbers;
- Customer records, account information you provide to obtain insurance or register an account on our website or mobile app, such as email address, user IDs, and passwords used on your account;
- Policy or claims information about the type of policy or coverage you have or information provided in the course of filing a claim, which may include sensitive personal information such as medical or health information;
- Commercial information about your transactions with us, including payment information, information you communicate to us via the Site or through our customer service center, or any other information you provide to ǿմý Commercial;
- Online identifiers such as the information collected when you access the Sites, including browser information, IP address, device type, and device ID;
- Employment-related information you submit to us that may include employment history, qualifications, licensing, and disciplinary records.
Due to the nature of our business, some personal information we collect is considered sensitive personal information under law, such as social insurance number, driver's license and passport numbers, account numbers and credentials, or health information. Personal information does not include publicly available information, such as information we reasonably believe you have made available to the general public or is otherwise not restricted to a specific audience, nor does it include deidentified or aggregated information.
Sources of Personal Information We Collect
ǿմý Commercial lawfully collects personal information from the following sources:
- information you provide directly (most common);
- information obtained from third parties, such as insurance agents or brokers, or service providers, such as credit reporting bureaus, third party administrators, etc.;
- information from our corporate policyholders, which may include information about their employees;
- information collected automatically when you engage the Site by using technologies such as cookies, pixels, or tags.
Upon visiting our website, we and our third party advertising partners use online tracking mechanisms, or cookies, to automatically collect information about browsing activity and effectively market across our Site and third party sites.
“Cookies” are a tracking mechanism transferred from our website to your hard drive via your web browser. Some cookies are necessary for website functionality and cannot be turned off, we call these “strictly necessary cookies,” and they do not collect or store any personal information about you. We use other cookies to count visits and traffic sources so we can measure and improve the performance of our Site. These are called “performance cookies” and all information these cookies collect is aggregated and anonymous.
We also use third party “targeting cookies” that that are set through our Sites by our advertising partners to provide more relevant advertising and content within our Services and across the internet. These targeting cookies collect usage and browsing information within our Site such as IP address, location information, device ID, cookie and advertising IDs, and browsing information.
A more detailed description on the usage of cookies can be found in our Cookies Settings tool , which helps you to manage your cookies preferences upon your initial visit to the Site and each visit following a reset of your browser, which clears your cookie preferences. You may turn off performance and targeting cookies at any time in Cookie Settings, but turning off performance cookies may affect your user experience of our Site.
How We Use and Disclose Personal Information
As permitted by law, we use personal information that we collect for the following purposes:
- to provide you with products and services;
- to communicate with you about your coverage or claim;
- to market or advertise products that may be of interest to you;
- to evaluate and improve our products and services;
- to prevent fraud and enhance security;
- to operate our business, meet legal or regulatory requirements, or other operational and business purposes.
We rely on your consent for each use of your personal information, and you may withdraw your consent for a particular use at anytime, though this may affect Services you receive. Canadian law requires companies to ask for consent for each new use of an individual’s personal information, which we will.
ǿմý Commercial discloses personal information about current or former customers or employees only as permitted by law or as necessary for business purposes. We disclose personal information to the following third parties for the following purposes:
- Agents and brokers to allow them to perform their normal insurance related services for you;
- Consumer reporting agencies to determine eligibility for coverage or to process your requested transaction;
- Third parties that help us carry out our insurance operations, including fraud detection and actuarial research
- Third parties whose only use of the information will be in connection with the marketing of a product or service, and which have agreed not to further use or disclose that information except in connection with the marketing of a product or service;
- Medical professionals and other professional advisors or consultants for the purpose of, and only to the extent necessary for, verifying insurance coverage or benefits or to defend an insured under a liability insurance policy;
- Insurance regulatory authorities;
- Law enforcement, the judiciary, or other government regulatory authority as required by law;
- Affiliates in connection with an audit of our or your agent’s operations, or the marketing of an insurance product or service, provided the affiliate agrees not to disclose the information for any other purpose;
- Group policyholders for the purpose of reporting claims experience or conducting an audit of our or your agent’s operations.
We require nonaffiliated third parties, to whom we legally provide your personal information, to take appropriate measures to protect such data and impose contractual obligations on service providers, contractors, and third parties to that end. We make every effort to use vendors whose approach to customer privacy reflects our own.
We complete Privacy Impact Assessments (PIAs) in certain circumstances, such as when making material changes to our Services that requires use of your personal information and before transmitting and storing your personal information in another province, or outside of Canada, as part of our standard business operations. We perform privacy impact assessments (PIAs) by:
- Assessing the project's compliance with privacy laws;
- Identifying the risks of the project on the privacy of the individuals concerned;
- Implementing strategies and measures to avoid or effectively reduce these risks;
- Monitoring and reviewing the implementation of these measures.
Exercising Your Rights Regarding Your Personal Information
Depending on your province of residence, you may have certain rights with respect to your personal or sensitive personal information. They include:
- Right to access your personal or sensitive personal information. You can request a copy of the personal information we may hold about you.
- Right to correct your personal or sensitive personal information. We will investigate and let you know if our investigation results in correction of your information. If we do not believe an error exists, you may file a statement disputing the information. We will send any corrections we make or your statement to any person or organization to whom we provided your information within the last two years or who may receive your information from us in the future.
- Right to de-indexation or right to be forgotten. We will review your request and remove your personal information from our systems unless it is necessary for us to maintain it in order to complete a transaction or to comply with a legal or regulatory requirement. As we rely on your implied consent to offer our services to you, withdrawing your consent for all use may necessitate cancellation of your insurance policy.
- Right to data portability. Once we verify your request, we will deliver a copy of your personal or sensitive personal information to you by mail or electronically. If provided electronically, it will be in a readily useable format (to the extent that possible to do so). The information will be provided to you free of charge.
If you wish to make any of the above requests, please complete the Privacy Request Form and submit it to us via email at privacyrequests@agcs.allianz.com. Alternatively, you may contact us via toll-free number at 1-800-807-8810 to request a copy of the Privacy Request Form to be mailed to you. Please be prepared to provide your full name and mailing address. You may mail the completed Privacy Request Form to us at the address provided or scan and return to us via email to privacyrequests@agcs.allianz.com. If no further verification is needed, we will respond to your request within 45 days. If your identity cannot be verified, we will contact you for additional information to verify your identity.
You will not be given access to information collected in connection with a claim or a civil or criminal proceeding. If medical information is contained in your file, we will request that you name a medical professional to whom we will send the information.
We will confirm receipt of any of the above requests no later than 10 business days after received and will provide information about how we will process your request, our verification process, and when you should expect a response (except in circumstances where we have already granted or denied such request).
Cross-Border Transfers of Personal Information
We may process, store, and transfer your personal information in and to another province or territory outside of Quebec, or country outside of Canada, with privacy laws that may not be as comprehensive as Canadian law. In these circumstances, the government, law enforcement, or regulatory agencies of that country could obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider subject to these laws, we will perform a PIA, require that the service provider is contractually obligated to keep personal information confidential, and that it will use the information only for the purposes for which we disclose it to them.
Retention of Data
We will retain your personal information generally for 10 [ten] years from the date the insurance policy or product expires, a claim has been settled, or the business relationship ends, unless a longer retention period is required or is permitted by law. We will not retain your personal information for longer than necessary and will use it only for the purposes for which it was obtained.
Data Security
We use a variety of computer hardware and software tools to maintain physical, electronic, and procedural safeguards that comply with applicable federal, provincial, and territorial regulations to guard your personal information. We restrict access to personal information about you to only those employees or vendors who need that information to provide products or services to you. We also ensure that our Sites are secure by employing firewalls, encryption technology, user authentication systems, and access control mechanisms to control access to the personal or sensitive personal information that may be shared over these Sites.
No Data of Minors
Our products and services are not directed at children. We do not knowingly collect personal information from children. If you are a parent or a guardian that believes we have collected personal information of a child, please contact us as provided below.
Notification of Change
Your trust is one of our most important assets. We will continually work to protect the privacy of our individual customers and claimants and will continually review this Privacy and Security Statement. If at some point in the future we revise our privacy practices in a way that affects the accuracy of this statement, we will notify you prior to introducing any changes. This Privacy and Security Statement will be displayed on our website (/global-offices/canada.html)
For More Information
Should you have further questions regarding our privacy practices, you can contact us in a number of ways. You may email us at ܱٲ.Գ.dz or you can write to us at:
ǿմý Global Risks Canada Insurance Company
Legal Department
225 W. Washington Street, Suite 1800
Chicago, IL 60606
United States
James Doty
Head of Digital Law, Data Protection & Privacy
privacyrequests@agcs.allianz.com