Privacy Policy

“Personal Information” is any information about an identifiable individual. It may include, without limitation, an individual's name, age, date of birth, home address, social insurance number, marital status, income, account number, client identification number, personal email address and messages, and Internet Protocol (IP) address.

Personal Information doesn't include the business contact information of an individual which is collected, used, or disclosed solely for the purposes of communicating or facilitating communications with the individual in relation to their employment, business, or profession.

Personal Information also doesn’t include any information that is aggregated or anonymized.

We collect and use several types of information from and about you to better provide products and services to you. Depending on the products or services you have with us, this may include:

• Personal Information (such as your name, address, contact information, date of birth, occupation and any other type of identification including your driver’s license);
• Financial and bank information including your credit score and information about your assets, liabilities, income and expenses;
• Tax information (including Social Insurance Number (SIN));
• Employment information;
• Information about your interests and purchasing preferences; and
• Information about your transactions with us and our interactions with you (including call recordings and chat transcripts).

We also collect technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our website, and usage details as well as non-personal details about your online interactions, including the Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), products you viewed or searched, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, email response and interactions, and any phone number used to call our customer service number.

Collection of Social Insurance Number (SIN) for Identity Verification (Optional)

Depending on the product or service you have with us, we may also request (with your consent) your SIN to verify your identity through an established credit reporting agency. This will apply for all accounts, with the exception of registered accounts (i.e., RSP, RESP), which do not require the use of a SIN for identity verification. However, if we do request that you provide us with your SIN for a reason other than for income tax reporting purposes, providing us with your SIN is optional and you can refuse our request for this information.

Biometric Information

While we do not collect, use, access, disclose, or retain any biometric data, our applications and identity verification processes may be supported by third parties that do. Through the use of third party devices (such as smartphones) and service providers, users may enable technology which uses biometrics for authentication. When such technology is enabled, we will be notified if the authentication is successful but will not have access to any of the data associated with the authentication.

The Personal Information we have about you may be collected directly from you (or anyone authorized by you to act on your behalf under a power of attorney or other legal authority) using a variety of means (including technological mediums). In addition, we may employ technologies that identify, locate, or profile you. This information may be collected from sources within or outside of our Company including from (depending on the product or service you have with us):

• our interactions with you (including email, instant messaging/chat, telephone and video calls);
• your mortgage broker, real estate agent or broker, or insurance broker (where applicable);
• government bodies, agencies, registries; regulatory bodies, and law enforcement authorities;
• public records;
• third party service providers (including financial data aggregators) and professional advisors (such as accountants and lawyers);
• other financial or lending institutions;
• credit reporting agencies including Equifax Canada Inc. and Trans Union of Canada, Inc.;
• our affiliates, partners, and related entities; and
• organizations with whom you have arrangements or any other sources we deem appropriate (where the information obtained will help us serve you).

Call Recordings

We may record telephone or video calls made or received by our agents and employees for quality assurance and security purposes. If you do not want your call to be recorded, please notify the agent on the call. We keep recordings of calls only for as long as permitted by law.

Providing Consent of Others Including Minors

You may disclose Personal Information about others with consent from such individuals. Where you are disclosing Personal Information about minors, you are doing so as the minor’s parental authority or tutor.

The Personal Information collected is used to ensure we can provide products and services to you and fulfill our obligations to you.

We may use your Personal Information for purposes including to:

• verify your identity and determine your eligibility for products, services or coverage for which you are applying for;
• administer your account and product and services you may have with us (including the administration of claims);
• Complete an application or communicate with you (including responding to any inquiries you may make);
• Pre-populate forms with Personal Information previously provided when applying for or making a request for any additional product(s) or service(s) of the Company;
• evaluate and process your application, accounts, transactions, and reports;
• help analyze and understand your needs in order to serve you better and personalize your experience with us (including our affiliates) and to help us (including our affiliates) develop new products and services. This may include using your Personal Information for study or research purposes, or the production of statistics;
• help us assess your eligibility for other products or services or to renew your current products and services, with us or our affiliates;
• help manage and assess our risks including risk of default, operations and relationship with you;
• help us collect a debt or enforce an obligation owed by you;
• assign or sell your account, or amounts owing under your contract to a third party;
• investigate an anticipated breach of an agreement or a contravention of law;
• comply with applicable laws, internal policies and requirements of regulators, including self-regulatory organizations; and
• best serve you and your interests.

We may use artificial intelligence (AI), machine learning, and automated decision making technologies to evaluate and assess Personal Information.

Additional Collection, Uses, and Disclosures

Marketing and Sales Purposes

Your Personal information may be used for marketing and sales purposes such as:

• informing you about products and services that may be of interest to you (including any new products or services, or the products and services of our affiliates and partners);
• using your Personal Information to determine your eligibility to participate in promotions, including contests;
• contacting you by email, telephone, fax, text message, or any other electronic means; and
• using your Personal Information to conduct research, analysis, modeling, and surveys to improve your experience with us and for product/service development.

Where you do not wish for your Personal Information to be used for such marketing and sales purposes, you may withdraw your consent (subject to certain restrictions).

For Credit/Mortgage Products

For any credit products such as mortgages, lines of credit, overdraft protection, loans, or credit cards, we will exchange Personal Information and reports about you with credit reporting agencies (including creditor and default insurance providers) and other lenders at the time of the application and throughout your relationship with us to review and verify your creditworthiness, establish credit and hold limits, help us collect a debt or enforce an obligation owed to us by you, and/or manage and assess our risks. Once you have such a credit product with us and for a reasonable period of time afterwards, we may from time to time disclose your Personal Information to other lenders and credit reporting agencies requesting such information, which helps establish your credit history and supports the credit granting and processing functions in general. We may obtain Information and reports about you from a credit reporting agency such as Equifax Canada Inc. and Trans Union of Canada, Inc.

Using Your SIN for Non-Tax Purposes

With your consent, and where SIN has been collected, we may also use it as a unique identifier. There are situation(s) where it is necessary to keep your Personal Information separate from that of other customers or individuals with similar names, for internal matching of your personal records against records received from authorized third parties, and to help maintain the accuracy of your Personal Information. You can withdraw your consent for the non-tax use of SIN at anytime by contacting privacy@thinkinsure.com and putting “Withdraw Non-Tax Use of SIN” in the subject line or in the body of the message.

Fraud Management

Your Personal Information may be used to help protect you and us against fraud risk and errors. This includes for the purposes of preventing, detecting, suppression of any financial abuse, fraud, criminal activity, and improving security measures. To protect both your and our assets and interests we may collect, use, and disclose your Personal Information to assist with both external and internal fraud investigations. The investigations may be related to suspected or actual illegal or suspicious activity, or to manage, defend, or settle any potential or actual loss in connection with the activity. Such Personal Information may come from you or any other source listed in this Privacy Policy including other financial institutions. In addition, we may disclose your Personal Information to any person or organization, fraud prevention agency, regulatory or government body, operator of any database or registry used to check information provided against existing information, or other financial/lending institutions for the purposes of fraud management.

Personal information will not be used, disclosed, or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law. Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In order to provide you with the best products and services, we may need to share your Personal Information with other parties who are under an obligation to protect the confidentiality of that information. The shared information will be limited to such information which is necessary to facilitate the arrangement.

Your Personal Information may be disclosed:

• to carry out a mandate or perform a contract of enterprise or for services;
• as part of a business transaction that we are considering or involved in (including the purchase of a business or the sale of part or all of our business);
• to respond to a court order, search warrant, or any other valid demand or request;
• to satisfy any applicable legal or regulatory requirement (including to a self-regulatory organization of which we are a member);
• to any advisors we may engage which may include financial advisors, consultants, accountants, lawyers, and auditors;
• to suppliers, service providers, agents or other organizations that perform services for you, for us or on our behalf;
• to your real estate agent or broker, mortgage broker or creditor/default insurance provider, or insurance provider;
• to our active and prospective funding partners for purposes of credit risk management and to meet our contractual obligations to them;
• to any authorized individual with legal authority including Power of Attorney;
• for study or research purposes or for the production of statistics;
• to help us collect a debt or enforce an obligation owed to us by you; and
• where otherwise permitted by law.

Categories of Service Providers

To provide you with optimal service, we may engage a variety of third party service providers. These service providers may be disclosed or have access to your Personal Information. The types of service providers we engage may include:

• communications service providers;
• compliance and fraud management service providers;
• credit reporting agencies;
• customer management service providers;
• disaster recovery service providers;
• finance, depository, and credit service providers;
• government and regulatory agencies;
• investment management service providers;
• marketing service providers;
• broker managers and mortgage and underwriting service providers;
• payment processing service providers;
• physical storage service providers;
• professional advisors such as lawyers, accountants, consultants, auditors, and financial advisors;
• rating and valuation service providers;
• reward service providers; and
• technology service providers.

Note that the service providers and other organizations we may use could be located outside of your province of residence or Canada. As such, your Personal Information may be collected, accessed, used, disclosed, and stored outside of your province of residence or Canada. In such a case, your Personal Information may be accessible or disclosed to or accessed by law enforcement, regulators, or authorities in the jurisdiction(s) where your Personal Information is being collected, accessed, used, disclosed or stored.

We may also share your Personal Information internally, including with our affiliates, for the following purposes:

• to manage your relationship with us and our affiliates;
• to better understand the products and services you have with us or our affiliates;
• to provide you with improved customer experience including maintaining consistent information about you;
• to manage and assess our risks; and
• to comply with all applicable legal and regulatory requirements for use and our affiliates.

The categories of employees within the Company that may have access to your Personal Information include as it is required:

• Senior management;
• Executives;
• Oversight (compliance, legal, privacy, risk, fraud);
• Information technology and cybersecurity;
• Operations;
• Customer sales and service; and
• Marketing and business analytics.

Disclosing Your SIN

Your SIN may be shared with third parties for income tax reporting purposes, as required by law. Your SIN may be also collected for non-tax purposes and used for identification purposes, records management, or to facilitate credit reporting checks. Where your SIN is being used for non-tax purposes, you may withdraw your consent at any time.

Withdrawing Consent

Subject to applicable legal and regulatory requirements, the consent to use your Personal Information given in any Privacy Agreement, Privacy Policy, and any other consent collected will be valid as long as you have a product or service with us or until we have received written notice that you wish to withdraw it. You may withdraw your consent in whole or with respect to certain uses. In certain circumstances, withdrawing your consent will mean we can no longer administer your products and services. You can only withdraw your consent subject to certain legal and contractual restrictions. You may contact privacy@thinkinsure.com if you wish to withdraw your consent.

Accessing and Correcting Your Personal Information

You have a right to access, update, and correct inaccuracies with your Personal Information that is in our custody and control (subject to certain exceptions prescribed by applicable laws and regulations). This includes obtaining details about what Personal Information was collected about you, how and why it was collected, how we process it, the categories of persons (internally and externally) and service providers who have access to or have been disclosed your Personal Information, the jurisdictions where your Personal Information may be disclosed, and how long we retain your Personal Information (subject to certain exceptions prescribed by applicable laws and regulations). For further information or to submit a request, contact privacy@thinkinsure.com.

Protecting your Personal Information

Please note that sharing your Personal Information with us does have certain risks including risk of unauthorized disclosure of Personal Information, identity theft, and fraud. We take the protection of your Personal Information very seriously and deploy various technical, administrative, and physical safeguards to protect your information.

Consent to Communications

By providing us with your contact information (email, phone number, address), you are consenting to us collecting, using, accessing, disclosing and storing your Personal Information for communication purposes including responding to any inquiries you make, helping us better understand your needs, and advising you of other products and services that may be of interest to you (including those of select third parties and affiliates).

Please note that while clients may withdraw consent from obtaining promotional communications, this withdrawal will not apply to all communications. There are certain communications that all clients must receive (such as those regarding account-related information). Non clients may withdraw consent from all communications at any time.

Opting Out of Commercial Electronic Messages

If you consent to and receive commercial electronic messages from us and you no longer wish to receive them, you can click on the “unsubscribe” link at the bottom of the message and follow the prompts on your screen. You can also contact unsubscribe@thinkinsure.com.

Some emails may not include an ‘unsubscribe’ link because the email contains account-related information that all clients must receive.

• If you receive an email in error after you have unsubscribed, please forward it to unsubscribe@thinkinsure.com and your request will be processed immediately.
• You can change, update and opt-out of mobile alerts (for example, order, custom or smart alerts), through the User Preference pages in IQ Edge or IQ Web Trading (where applicable; depending on the product/service you have with us).

Note: Clients cannot unsubscribe from receiving communications that we are obligated to provide such as account-related information. All clients can unsubscribe from promotional communications at any time. A non client can withdraw consent from all communications at any time.

Our website contains links to other sites that we do not own or operate. We are not responsible for the privacy policy and privacy practices of any other websites.

If you store your financial or authentication information (such as investment account numbers and login information) with online or web-enabled personal finance sites or data aggregators, your security may be at a greater risk.

Updates to Our Privacy Policy

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email using the email address specified in your account or place information banners on our website. We will include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy specifically to check for any changes.

Contact Us

If you have any questions or concerns about this policy or privacy and confidentiality matters, please contact our Chief Privacy Officer at:

Think!nsure Ltd.

5700 Yonge Street

Toronto, ON M2M 4K2 Canada

Toll free: 1-888-415-8802

Email: privacy@thinkinsure.com

Contact the Office of the Privacy Commissioner of Canada

If, after contacting ThinkInsure, you feel your Personal Information concerns have not been adequately addressed, you may contact the Office of the Privacy Commissioner of Canada at:

30 Victoria Street

Gatineau, Quebec

K1A 1H3

Toll-free: 1.800.282.1376

Phone: 819.994.5444

TTY: 819.994.6591

Online: https://www.priv.gc.ca/en/report-a-concern/