Privacy Policy

Privacy Policy – EFS North America Limited o/a ClearCompare.ca

Our commitment to privacy:
EFS North America Limited o/a ClearCompare.ca (the ”Company”) knows that protecting the privacy and confidentiality of your personal information is important to you. This Privacy Statement describes the Company’s personal information handling practices. The collection, use and disclosure of personal information by us and our affiliates are governed by the Personal Information Protection and Electronic Documents Act, and any applicable provincial privacy legislation. We only collect, use and disclose personal information in accordance with the consent provided by the person to whom the information relates, this Privacy Policy, our contractual rights and as required by law. This Privacy Statement explains what personal information is collected from its customers and how it is used. It also explains how you can ask questions, make suggestions, and complain about our privacy practices. This Privacy Statement applies to personal information (see below) collected by us, including on our websites. Be aware that our websites may contain links to other websites provided and maintained exclusively by third parties not subject to this Privacy Statement. Please review the privacy policies on any external websites to determine their personal information handling practices.

Please read this Privacy Statement carefully, and check back periodically as we update it from time to time. By submitting your personal information to us, you signify your agreement to the terms and conditions of this Privacy Statement. If you have any concerns or questions, we encourage you to contact us using the contact information set out below and we will address your concerns to the best of our ability.

What is personal information?
Personal information is any information about an identifiable individual. Personal information does not include the name, title, business address or telephone number of an employee of an organization.

We are responsible for personal information under our control. Our employees are informed about the importance of privacy and receive periodic information and training to update them about our Privacy Statement and related policies.

In addition, we have appointed a Chief Privacy Officer to oversee personal information-handling practices of the Company. .

What personal information do we collect, and why?
We collect personal information for specific, limited purposes by fair and lawful means. Anyone can navigate this website without giving us personal information. We use personal information to provide insurance quotes that you request and to arrange for and administer the insurance products that you request. We collect personal contact information (for example, name, address, email address and telephone numbers), medical information and credit card information if you request an insurance quote or other insurance service. We also collect personal contact information if you sign up for a newsletter or other email services; are an insurance broker or agent and have an account with us; or provide it to us when you click the submit button on our website forms. This personal information is used to fulfill your request, provide targeted advertising and respond to your inquiries and feedback.

We collect this information from you and with your consent. Any information requested on any form on our website will be clearly marked and no collection will take place unless you fill in the form and successfully submit that form to us.

We also use your personal information for the purposes of:

• managing, administering, collecting or otherwise enforcing accounts;
• maintaining business records for reasonable periods of time and generally managing and administering our business;
• meeting regulatory, legal, insurance, audit, security and processing requirements;
• if you enter a contest or other promotion, we use your personal contact information to administer the contest or promotion including contacting, announcing and promoting prize winners; and
• providing notes and special instructions on file for employees insurance brokers and agents to help us fulfill your request and provide customer service.



We may use your personal information without consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.

Occasionally, we ask our customers to complete market research surveys. Survey results are aggregated and shared with our advertisers, sponsors and affiliates in a manner that does not disclose personal information

We collect demographic information, as well as quote request history and a list of promotions offered to you (“history”), to gain a better understanding of your interests so that we may develop better products and services, and to determine eligibility for our products and services. We may also use demographic, personal contact and history information from time to time to contact you about changes, enhancements or other notices related to goods or services you requested and which we provide.

In addition, we may use this information to send you offers or information from us, our affiliates and from selected sponsors or advertisers (“Marketing Offers”). If you do not wish to receive Marketing Offers, you may opt-out at any time by following the procedure set out in our opt-out policy (see below).

Other than as permitted or required by law, any purposes for the collection, use or disclosure of personal information which are not set out in this Privacy Code, will be set out at the time of collection.

You will be given a reasonable opportunity to opt-out of any additional purposes no later than the time of collection.


To whom do we disclose personal information, and why?
ClearCompare.ca is not an insurance company. We work with insurance companies and insurance brokers/agents on this website and you will be disclosing information to them as well as to us if you choose to receive an insurance quote from us.

We may also disclose your personal information under the following circumstances:

• In order to provide you with Marketing Offers (see above), we may disclose your personal contact information to affiliates and selected sponsors and advertisers. If you do not wish to receive Marketing Offers, you may opt-out at any time by following the procedure set out in our opt-out policy (see below).
• We may transfer your personal information on a confidential basis to a third party (which party may be outside of Canada) acting on our behalf in order to perform processing and other specialized services, for example, prize fulfillment of our contests or product delivery.
• Your personal information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third-party service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your personal information.
• We may disclose your personal information to our affiliates for internal audit, management, billing, administrative, marketing, promotion, or other business purposes.
• We may disclose your personal information without your consent where required or permitted by law, for example, if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law, in order to protect or defend our legal interests, or to comply with applicable laws and lawful governmental requests.
• We may disclose your personal information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We will require such parties to treat your personal information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.



Security


We maintain personal information in a combination of paper and electronic files. We take technical, contractual, administrative and physical security measures to protect your personal information against loss, theft, copying, unauthorized disclosure and unauthorized use or modification. For example, when you provide personal information to us, we work to help protect the security of your information by using industry standard secure sockets layer (SSL) encryption technology. We limit access to your personal information to authorized employees and agents who need your personal information to provide you with insurance products and services.

Although every effort is taken to ensure no one else will see or obtain your personal data, complete confidentiality and security is not possible over the Internet. Any unencrypted e-mail communication over the Internet is not secured or confidential, and is subject to possible interception, loss and alteration.
Cookies
If you use any of our websites, we may assign an internet cookie. An internet cookie is a small text file that a website stores on your internet browser and that can collect and store information. We use cookies to better understand how you use our websites, to make sure our ads and dynamic content are served correctly and to improve the performance of our websites.

For example, a cookie may recall a set of preferences you have set for our website and record items that you have registered for. Storing cookies on your web browser allows us to present you with custom web pages and other content that are tuned with your preferences. For example, if you are a registered user, you may see a welcome page with your name on it. These activities are invisible to you, and are generally intended to improve your internet surfing convenience. Unless you have set your preferences so that you will be alerted when a cookie is being stored on your computer, you won’t know about it.

If you are concerned about cookies, it is possible to turn them off in your web browser preferences. However, please be aware that by disabling cookies, you may not be able to use all portions of our websites, particularly pages requiring registration.

We may place advertising or other links on our sites that originate from outside advertisers. If you view these ads, the advertisers may assign a cookie. We do not control these cookies, nor are we responsible for any marketing or other use of your name by these advertisers.


Marketing Offers and opt-out policy:
If you do not wish to receive Marketing Offers, you may opt-out at any time by doing any of the following:


• Follow the instructions at the bottom of any email Marketing Offer you receive.
• Call the Company at 416-814-5591 and request that your personal information not be used for Marketing Offers.
• Email the Company at privacy@ClearCompare.ca and request that your personal information not be used for Marketing Offers



Please allow a reasonable time (approximately 2-3 weeks) for processing of your request. If you choose to opt-out of any use of your personal information in accordance with our opt-out policy, we keep your contact information on a list so that your request can be honoured. If you complain to any of our departments, we collect your contact information and the nature of your complaint, for the purpose of investigating and responding to you.


How to access and correct your personal information:
You may call the Company at: 416-814-5591 and we will make the changes upon receipt of appropriate evidence.
We will give you access to the information we retain about you within a reasonable time, upon request, satisfactory identification and proof of entitlement. In some cases, we may not be able to provide access to personal information in our possession or control. If we deny your request, we will advise you in writing of the reason for the refusal and you may challenge our decision.

How to challenge our privacy practices:
We encourage you to contact us with any questions or concerns you have about your privacy or this Privacy Statement. If you have a question concerning our Privacy Statement, or if you have a complaint, please contact EFS North America Limited o/a ClearCompare.ca at:
Privacy Officer
EFS North America Limited
2 Bloor Street East, Suite 3500
Toronto, Ontario
M4W 1A8
Canada
Phone: 416-814-5591
Email: info@ClearCompare.ca


This Privacy Statement was last updated on: May 24, 2017