Federated Privacy policy

Our client relationships are based on a foundation of trust. We are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information collected, used, retained, and disclosed while doing business with you. We are responsible for all personal information under our control, whether supplied to us directly by you or by a third party or that we have provided to our third-party service providers for processing. We take our privacy obligations seriously and strive to implement privacy practices guided by the highest standards of ethical conduct.

We do not sell your personal information.

We will obtain your consent prior to collecting, using, retaining, or disclosing your personal information for specific purposes, except where we are specifically permitted by law to collect, use, retain or disclose your personal information without your consent such as when we are required by law to disclose your personal information to a government institution. If we wish to collect, use, retain or disclose your personal information for a new purpose, we will seek your consent before doing so.

Your consent can be implied or express. Implied consent refers to consent that is inferred from your actions. For example, when you provide personal information to us to obtain an insurance quote, we would infer that you are consenting to our collection and use of the personal information you provide to produce a quote. Express consent is consent that is given specifically, either verbally or in writing. When we ask for your express consent, we will explain what personal information we need, what we will use and disclose it for, and who we will share it with.

We may collect personal information directly from you, and from third parties as described in this privacy policy. When you provide us with personal information about any other persons, it is your responsibility to ensure that you have the approval from these persons to provide their personal information to us and to allow us to collect, use and disclose their personal information for the identified purposes.

Depending on the type of products or services we provide to you, and the consent that you have provided, we may collect the following personal information:

• Name and contact information including email address
• Demographic information (age, date of birth, gender, family and marital status)
• Previous insurance and claims history
• Financial and payment information, including credit card and bank account numbers and billing addresses
• Driving records and history
• Identification numbers (for example your driver’s license number)
• Financial and insurance needs
• Personal information publicly available from external sources as permitted by applicable laws
• Information contained in legal documents, including court orders, powers of attorney
• Information related to a specific claim or investigation, including information contained in police reports, officer notes, photographs, videos, voice recordings, investigation reports, and mobile phone records. This may include geo-location or other metadata.
• Your IP address and characteristics about the electronic devices you are using to transact with us

The following are some of the purposes for which we may, with your prior consent, collect, use, or disclose your personal information:

1. To conduct a needs analysis, including:

• Determining and evaluating your insurance coverage needs
• Determining the suitability of and recommending insurance products and services tailored for you

2. To obtain a quote for you from an insurer, including:

• Analyzing and determining the risk of providing insurance to you
• Determining premiums for insurance products you are interested in
• Detecting, investigating, suppressing, and preventing misrepresentation and fraud

3. To process your application and obtain a policy for you from an insurer, including:

• Confirming your identity
• Verifying the information you disclose (for example verifying your address or your phone number)
• Detecting, investigating, suppressing, and preventing errors and omissions and/or fraud (for example for online purchases we may verify the location you are transacting from, the unique identity of the device you are using or the email address). Where permitted by law, we may obtain and share information with other organizations for these purposes.
• Obtaining access to historical insurance policy and claim details through property and casualty industry databases
• Analyzing and determining the risk of providing insurance to you
• Processing your application
• Obtaining your policy from an insurer
• Billing and processing payments, including debt collections and setting-up pre-authorized payments (where available) if you choose to do so

Where permitted by law, we may obtain and share information with other organizations for these purposes.

1. To assist Federated in the administration of your insurance policy, including:

• Processing policy changes, renewals and terminations
• Confirming your identity
• Communicating with you regarding products and services you have with us
• Ensuring quality customer service
• Resolving disputes
• Training and development of staff
• Issuing surveys
• Confirming your registration for our Online Services (OLS) secure site
• Processing of digital signatures
• With your consent, disclosing policy information to leaseholders, lienholders, mortgagees, and other persons with an insurable interest
• Periodically reviewing your insurance needs and determining the suitability of our products and services for you
• Performing monitoring and audit activities
• Assist with general claims questions

2. To comply with regulatory obligations set out in applicable federal and provincial laws

3. To conduct business analysis and data analytics, including:

• Using your personal information in conjunction with advanced analytics and artificial intelligence techniques to perform business analysis and data analytics, for example:
• To enable us to detect patterns of fraud to reduce its impact
• To use insights from your interactions with us to be proactive in our service and to resolve complaints

4. To communicate with you across multiple channels, including by email, SMS messages and telephone calls, including:

• With your consent, advertising and marketing our products, services, offers, contests, or community events that may be of interest to you, or to conduct market research or surveys

5. To serve advertisements through social media and other advertising platforms, and to improve our marketing campaigns.

6. To test and troubleshoot our internal systems, and assess and enhance our security safeguards, business planning, and management, including assessing resource needs.

We may disclose your personal information to others where necessary and appropriate, but only if we need to for the purposes that you have consented to. We may disclose your personal information to the following:

• Third parties who provide services to us or perform services on our behalf, including, but not limited to, payment processors, data processors, electronic storage providers, investigators, engineers, and disaster recovery services providers
• Third parties as needed to provide you with the product or service you have requested from us
• Operators of insurance industry databases (for example to analyze and verify information you have provided, such as previous policies and claims, against information contained in insurance industry databases)
• Insurance eligibility and risk assessment organizations
• Other companies within the Co-operators group of companies
• Our insurance distribution partners for insurance administration and distribution purposes
• Parties involved in the sale, acquisition, disposition, merger, or amalgamation of companies or as part of other business arrangements, such as joint ventures
• Government agencies, as required by law (for example for periodic regulatory filing, reporting in accordance with anti-money laundering or unclaimed property requirements or under other lawful authorities, and for income tax purposes)
• External auditors, legal counsel and other professionals
• Any other parties you authorize

To achieve our business purpose of providing financial security for Canadians and our communities, we may use technologies that incorporate automated decision making, while keeping your personal information safe.

We will inform you if we make a decision based exclusively on automated processing of your personal information, no later than at the time we inform you of such decision.

Where we are making a decision based exclusively on automated decision making, at your request, we will explain the personal information used in such automated decision-making process to make such decision, and the reasons, principal factors and parameters that led to the automated decision.

Where we are making a decision based exclusively on automated decision making, you can contact us by e-mail at privacy@cooperators.ca to correct any personal information used to render such decision.

We may use technology that includes functionality that, if activated, would allow us to identify, locate, or profile you. If we do so, and you are located in the Province of Quebec, we will provide you with the means to activate such functionality.

To find out how we use cookies, web analytical tools and similar technologies, visit profiling and cookies.

You have a choice

We want you to know that you can always:

• Decline to provide us with some of your personal information. If you do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.
• Withdraw your consent at any time, and, subject to any applicable legal or contractual restrictions which we must fulfill, we will cease to collect, use and disclose your personal information after the withdrawal of your consent. If you withdraw your consent, or do not provide us with all necessary personal information, we will still do our best to provide you with our products or services; however, it may not be possible for us to do so.
• Update your marketing permissions and contact preferences at any time by contacting us.

We retain personal information only as long as is necessary to fulfill the purposes for which it was collected, unless authorized or obligated by applicable laws to retain personal information for a longer period.

Safeguards

We are committed to protecting your personal information. We take the security and confidentiality of your information very seriously. Learn more about our security practices..

Your personal information may be accessed by our employees and other authorized personnel who need to use it to perform their duties. This may include third party service providers, including those that are located outside of Canada. If your personal information was collected, used or disclosed within the province of Québec, it may be communicated outside Québec. In all cases, our employees and other authorized personnel, whether or not they are in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy and practices, as well as with Canada’s privacy laws and regulations. They could also be required by law to give your personal information to courts, governments or regulators, both inside and outside of Canada. If your personal information is transferred outside of Canada, your personal information may be subject to the laws of other countries. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with third party service providers.

Accuracy

We make every effort to ensure that the personal information we collect is accurate, complete, and as up to date as possible to properly satisfy the purposes for which it is to be used. It is important that you promptly notify us of any change to your contact information.

If we are unable to verify your personal information or contact you, we may be limited in our ability to provide you with our products and services.

Access to and correction of personal information

Upon written request, and confirmation of your identity, we will provide you access to the personal information that we have obtained about you while doing business with you. However, there may be instances where we may, in accordance with applicable privacy laws, restrict access to your personal information, including where such information is subject to legal privilege, contains confidential commercial information, or relates to other individuals. If applicable, we will advise of the reasons for restricting access and inform you of any recourse that you may have. A response to your request will be provided within 30 days after we receive a written request, and we have sufficient information to permit us to identify the existence of the personal information. In Alberta, a response will be provided within 45 days after receipt of a written request, and sufficient information to permit us to identify the existence of the personal information. Where permitted by applicable law, if we need more time to fulfill your request, we will notify you of such delay. There may be instances where medical information obtained about you from a third party can only be released to you through a physician.

For individuals living in the province of Québec: You can request a copy of your computerized personal information that we have collected about you. This computerized information will be transferred in a structured and commonly used technological format either to you or to a person or organization designated by you and who is authorized by law to collect such information.

If you exercise these access rights, we may charge you a reasonable fee for the transcription, reproduction or for the transmission of the personal information.

If you believe that the information in our files is inaccurate or incomplete, you have the right to ask us to correct it. We will review your request and, if we agree, will promptly make the necessary corrections.

To request access to or rectify your information contained in our file, contact us atprivacy@cooperators.ca. If you authorize a third party to make a request on your behalf, we need your written consent to release your personal information to the third party.

Register a privacy concern

Our goal is to help you meet your needs and provide the best service we possibly can. If you ever have a privacy-related concern, do not hesitate to contact us at privacy@cooperators.ca to discuss it. We take your privacy concerns seriously and we will investigate all privacy-related complaints, and where necessary we will take appropriate measures to address your complaint. Should you remain unsatisfied with our complaint process, we will inform you of what other complaint procedures are available to you.

We may review this Privacy Policy periodically to reflect changes in privacy regulations and in our practices. We will post a notice of any relevant and material changes to this Privacy Policy when they occur.