First Acre Insurance Inc. (“First Acre”) appreciates the opportunity and confidence you have shown us by choosing our product through your broker. As part of our commitment to you, it is our responsibility to protect your right to privacy and the confidentiality of your personal information by complying with the laws and regulations under applicable privacy laws across Canada, including the Personal Information Protection Act and the Personal Information Protection and Electronic Documents Act. Any personally identifiable information about you is considered personal information (Personal Information) and will be treated in accordance with this Privacy Policy and applicable privacy legislation.
Identified Purposes of the Use of Your Personal Information
First Acre uses personal information to manage and administer our business, including understanding your insurance needs, communicating with you effectively and to provide you with the products and services you request. First Acre relies on insurance brokers to obtain your agreement to provide us with your personal information so that we can use it for the purposes set out in this privacy policy. We do not sell, trade or rent the personal information we collect, and we do not knowingly disclose personal information to third parties. For example, we may use your personal information to:
- Determine your eligibility for, understand your insurance needs, offer or provide you with insurance products and services that you request;
- Evaluate credit worthiness and monitor, collect premiums and fees;
- Verify your identity;
- Determine prices, fees and premiums including by evaluating your coverage needs and assessing risk;
- Determine your eligibility for, offer and assess your needs to provide current and future products and services to you
- Maintain, administer, collect, service and renew your policy(ies);
- Investigate and settle claims;
- 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 consent or as permitted or required by law.
In some cases, refusing to provide certain Personal Information or withdrawing consent for First Acre to collect, use or disclose your Personal Information could mean that we cannot provide you with insurance coverage or other requested products, services or information.
Limiting Collection, Retention and Disclosure of Personal Information
First Acre will only collect, use or disclose personal information that is necessary for the identified purposes or as required by law. If we require personal information for any other purpose, you will be notified of the new purpose, and use of your Personal Information will be subject to your consent. First Acre will only collect Personal Information by fair and lawful means. We will retain personal information only as long as necessary for the fulfilment of the Identified Purposes. We collect personal information from you when you inquire about our insurance policies, request a quote, apply for insurance, make a payment, or open a claim under your insurance policy. This information includes personal information such as your name, contact information, date of birth, family or marital status, occupation, medical or health records, driver’s license, previous insurance experience including claims information, assets or liabilities, credit history or status, loan or mortgage details, payment or banking information, information in legal documents, and your marketing preferences.
We may record calls, online chats and other communications between us to ensure quality customer service, confirm our discussions and your instructions, resolve complaints, and train our staff. If you do not want your communications recorded, you can do business with us by emailing us.
We may use cookies, web beacons and other technologies to identify you on our website, to gather information about how you use our website, and to enable our and third party web-based services. For information about the cookies, web beacons and other technologies we use, and how to disable these, visit our website Terms of Use. However, if you disable these, you may not be able to successfully access parts of our website.
We may ask you for information about other persons covered by your insurance (employees residing in dwellings, persons away at school or in care homes). When you give us information about another person, we expect you to ask for their permission to do this and consent to this Privacy Promise on their behalf.
Disclosure to Affiliates
Personal information may be disclosed to our affiliates (including outside of Canada) 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 their products and services. However, if you do not want your personal information disclosed for these marketing purposes, you may contact us at any time as described further below.
Service Providers
First Acre 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 or administrative services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Some of these service providers or affiliates may be located outside of Canada and your personal information may be collected, used, disclosed, stored and processed for the purposes described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada, the United States and other foreign countries applicable to our affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.
Business Transactions
Personal information may be used by First Acre and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of First Acre or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
- Permitting those parties to determine whether to proceed or continue with the transaction; and
- Fulfilling reporting, inspection or audit requirements or obligations to those parties.
Assignees or successors of First Acre or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.
Sharing of Personal Information with:
- Operators of insurance industry databases for the purpose of verifying the information submitted;
- Your insurance broker for the purpose of your broker providing services to you;
- Independent insurance adjusters for the purpose of obtaining assistance in processing and administering your claims;
- Governmental authorities, claims investigation service providers, medical organizations, other vendors, other insurance carriers, re-insurers, and regulatory organizations for the purpose of assisting in the investigation and processing of claims;
- Other persons for whom you have provided your consent, for the purposes, and;
- As otherwise permitted or required by law.
Consent
Your knowledge and consent of First Acre’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information directly to First Acre through one of our independent insurance brokers for the purpose of acquiring an insurance contract or related service or product (including information previously provided to First Acre;
- Your express consent or acknowledgment contained within a written, verbal or electronic application process;
- Your consent solicited by First Acre for a specified purpose;
- Your receipt of this Privacy Policy, until you notify First Acre of a withdrawal of this consent;
- Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney; or
- If you make changes to your policy or when your policy renews, it is inferred that any consent you have previously provided to us relative to your policy remains in effect unless the consent is otherwise withdrawn.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time by emailing us at compliance@firstacre.ca. First Acre will inform you of the consequences of withdrawing your consent.
Maintenance of Information Kept
First Acre will maintain your Personal Information as accurate, complete, and up to date as is necessary for the Identified Purposes.
Deletion of Data Kept
You may make a request that we delete certain Personal Information we hold about you. To do so, please send your request to compliance@firstacre.ca We may not be able to assist in all cases. Deletion of your data will also be subject to legal, regulatory and contractual considerations. Deletion of your data may also mean that we cannot provide you with insurance coverage or other requested products, services or information.
Protection of Personal Information
First Acre will protect your Personal Information by security safeguards appropriate to the sensitivity of the information. We do this by implementing physical, organizational, contractual, and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, and use or modification.
Responsibility
First Acre is responsible for all Personal Information under its control and has designated a Privacy Officer.
Who to talk to
If you have any questions or concerns regarding our privacy policy, please contact our Privacy Officer at:
First Acre Insurance Inc., Suite 307, 1235 Fairview Street, Burlington, ON L7S 2K9
Email: compliance@firstacre.ca
If you are not satisfied with First Acre’s response to a privacy related inquiry or complaint you may contact the office of the Privacy Commissioner of Canada during business hours at 1-800-282-1376 or at www.priv.gc.ca.
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