We encourage you to check this policy regularly for changes or updates to our Personal Information handling practices.
Personal Information: means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include your name and address, age and gender, property information and health information.
Wawanesa Group: means Wawanesa and its affiliates, including its parent, The Wawanesa Mutual Insurance Company.
Wawanesa has policies and procedures governing how we handle your Personal Information. Every Wawanesa employee and every third party that Wawanesa uses is responsible for respecting and protecting the Personal Information that they have access to.
Wawanesa’s Privacy Officer oversees Wawanesa’s practices related to the use, collection and disclosure of your Personal Information. The contact information for our Privacy Officer is available below in the Contact Us section.
2. Identifying Purposes.
We may use or disclose your Personal Information for the following purposes:
To provide and manage the products and services that you have requested from us.
We will use and disclose some of your Personal Information so that we can deliver our products and services to you, and notify you if any changes are made to them.
To assess your application.
We will use and disclose some of your Personal Information to provide quotes for new or renewed insurance policies, assess your application for insurance, process renewals and underwrite policies.
To review and pay claims.
We will use and disclose some of your Personal Information to review your claim documentation, determine any claim amounts owed and arrange for claims payment.
To confirm your identity, protect against fraud and manage our risk.
Wawanesa and other organizations that we have disclosed your Personal Information to may use some of your Personal Information to verify who you are and to detect and prevent fraud. If false or inaccurate information is provided to us and fraud is identified or suspected, we may disclose some of your Personal Information to law enforcement, investigators or fraud prevention agencies, and we or they may store and use that Personal Information for further investigation and record keeping purposes.
To comply with legal or regulatory requirements, or as otherwise permitted by law.
We will use and disclose your Personal Information to comply with our legal or regulatory obligations related to the detection and prevention of money laundering, terrorist financing or other criminal offences, communicate with our regulators, defend or prosecute claims, or conduct regulatory reporting. This could include disclosing some of your Personal Information to third parties, courts, regulators or law enforcement agencies in connection with enquiries, proceedings or investigations both in and outside of Canada.
To offer you products and services that may interest you.
We may use and disclose some of your Personal Information to offer products and services that we or our affiliates produce to you. If you do not wish to be contacted by us or our affiliates for offers of products and services, please Contact Us.
To understand our customers and to develop and tailor products and services.
We will process and analyze your Personal Information, and that of other customers of Wawanesa and its subsidiaries so that we can better understand the product, service and marketing requirements and expectations of you and our other customers, better understand the business of Wawanesa and other members of the Wawanesa Group, and develop and tailor products and services offered by Wawanesa and its subsidiaries.
To operate our business efficiently.
Wawanesa contracts with third parties to assist us in carrying out parts of our business more efficiently. A description of the types of third parties that we share your information with is set out in Principle 5
To make changes to our business.
We may disclose some or all of your Personal Information to a third party, or its advisors, in connection with the sale or reorganization of some or all of Wawanesa’s business, or the business of one or more of its affiliates, for the purpose of conducting due diligence reviews and analysing the proposed sale or reorganization.
To communicate with you.
We may use some of your Personal Information to communicate with you by telephone, email, mail, chatbot, or SMS/text. We may keep records of our correspondence with you. We also may monitor or record calls and other interactions with you in order to ensure service quality, comply with applicable laws and our own internal procedures, and detect, investigate and prevent fraud or other criminal activity.
If we identify a new purpose for using your Personal Information, we will update this policy to identify that purpose.
4. Limiting Collection.
We only collect Personal Information that is reasonable for one or more of the purposes set out in Principle 2 above.
We collect information including your address, telephone number and email address so that we can establish and maintain contact with you.
Information you provide about others.
We may require information about third parties such as additional insureds, beneficiaries, and others that are connected to your insurance policy. You must have their permission to give us their information and you need to let them know how we use their information before providing it to us.
Anti-crime and anti-fraud information.
We collect information that you or third parties provide us that establishes your identity (such as driver’s licenses, birth certificates and passports) and other related information (such as addresses, telephone numbers, email addresses and signatures) that allow us to verify that you are not suspected or a victim of fraud, other criminal offences or suspicious transactions, and that your details do not appear on politically exposed persons and sanctions lists issued by governments and intergovernmental organizations.
We may collect certain financial information to ensure that any products and services we provide you with are appropriate and suitable for you and pay claims.
We collect certain health information from you or third parties such as doctors, hospitals and other healthcare providers to determine eligibility and pricing for our insurance products, process claims, detect and prevent fraud, and manage our risk.
We collect certain information concerning your property from you or third parties such government and civic authorities, as well private service providers to determine eligibility and pricing for our insurance products, process claims, detect and prevent fraud, and manage our risk.
We collect correspondence between you and us, including email, mail, customer feedback tools and processes, and recordings of telephone calls where you have been notified that the call may be recorded, to manage our business, our regulatory obligations and our relationship with you, for training purposes, to detect and prevent fraud, and to manage risk.
We collect information about your operating system, browser, software applications, IP address, geolocation, security status and other device information to improve your online experience with us, to detect and prevent fraud, and to manage risk.
Website and mobile application use information.
Email tracking information.
Our emails contain a single, campaign-unique "web beacon pixel" to tell us whether our emails are opened and, combined with other technology, verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to you and to query whether users who do not open our emails wish to continue receiving them. This information may include your Personal Information. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, please select to receive emails from us in plain text rather than HTML, or choose not to click links that we send you or unsubscribe from the receipt of our emails.
5. Limiting Use, Disclosure and Retention.
We will disclose your Personal Information to the following types of organizations for the purposes noted below.
Regulatory and law enforcement.
We will disclose your Personal Information to third parties, including regulatory or law enforcement authorities, anti-money laundering, anti-terrorist and anti-fraud organizations in cases of suspected criminal or other illegal activity, to detect and prevent fraud, or where we are otherwise required to satisfy a legal obligation that has been placed on us, such as in the case of a court order.
Members of the Wawanesa Group.
We will share Personal Information between the affiliates within the Wawanesa Group to compile and review statistics and for other analytics purposes, for legal and regulatory purposes, to develop and offer you new or different products and services, to ensure that the information that we have about you is correct, and to manage our relationship with you.
We use affiliates within the Wawanesa Group or third parties to provide certain products and services on our behalf, or to enable us to offer and provide our products and services to you. These third parties include:
- agents, brokers and third party administrators;
- underwriting service providers;
- health information networks and healthcare providers;
- market and customer satisfaction researchers;
- materials storage and archiving service providers;
- data analytics and other data processing providers;
- cloud service providers; and
- lawyers and investigators.
Business sale or reorganization.
From time to time, we may sell or reorganize parts of our business. The Personal Information that is associated with any parts of the business that is being sold or reorganized will be reviewed as part of a due diligence process and on the completion of the sale or reorganization, will be transferred to the new owner.
Transfers outside of Canada.
Given the global nature of information processing, the organizations that we disclose Personal Information to are sometimes located outside of Canada, and as a result, all or part of your Personal Information may be transferred outside of the country. It is possible that the third parties that we transfer your personal information to may be located in jurisdictions that do not have laws offering the same level of protection as your jurisdiction. However, regardless of the location of the third party, we will put measures in place to protect your Personal Information, including agreements which hold the third parties to standards of confidentiality and security concerning your Personal Information that are similar to the standards that we adhere to.
Our retention periods for Personal Information are based on our business needs and legal requirements. We retain Personal Information for as long as is necessary for the processing purpose(s) that we collected it for, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such information. When Personal Information is no longer needed, we either anonymise it or destroy it.
We are committed to keeping your Personal Information accurate, complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please Contact Us so that we can make the necessary changes, as incorrect or out of date Personal Information may negatively impact the way we communicate or provide our products to you. Where we determine it is appropriate, we will advise third parties of changes to your Personal Information that has been shared with them.
We use a range of safeguards to protect your Personal Information. We have agreements and controls in place with third party service providers requiring them to safeguard any Personal Information we provide to them and use the Personal Information only to provide the service we have requested them to perform. We have physical and technological controls in place to protect your Personal Information which are reasonable given the sensitivity of it, and we train our employees on the importance of safeguarding your Personal Information.
If you wish to review, access or verify your Personal Information that we hold, or if you wish to find out who we have disclosed it to, you must provide us with your request in writing. We will need specific information from you to enable us to search for, and provide you with, your Personal Information we hold. If we are unable to provide some of the Personal Information we hold about you, we will tell you why. To request to review or verify your Personal Information, please Contact Us.
10. Challenging Compliance.
You can contact us in the following ways:
Via email: email@example.com
Wawanesa Life Insurance Company
#400, 200 Main Street, Winnipeg, Manitoba R3C 1A8
If your Personal Information was collected, used and/or disclosed by Wawanesa:
- Wholly within the province of British Columbia, contact the Privacy Commissioner of British Columbia.
- Wholly within the province of Alberta, contact the Privacy Commissioner of Alberta.
- Wholly within the province of Quebec, contact the Privacy Commissioner of Quebec.
- Involves any other province or territory in Canada, or involves one of British Columbia, Alberta or Quebec and any other province or territory in Canada, contact the Privacy Commissioner of Canada.
"Cookies" are sets of data that are sent between a server and a web browser to make the use of the website easier for the visitor, and to allow us to better understand how a visitor to our website uses it. Different types of cookies are used for different activities. Cookies that we use are:
Session Cookies, which enable the website you are visiting to keep track of your movement from page to page so you do not get asked for the same information you've already given to the site. Session Cookies allow you to proceed through many pages of a site quickly and easily without having to authenticate or reprocess each new area you visit. They are not written to hard drive so they are deleted once you log out of a website or close your browser. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Persistent Cookies help the website remember your information and settings when you visit it in the future, and help us provide you with a more personalized experience when you are using our website by analyzing which products and services you have used. Persistent Cookies are stored on your computer.
Flash Cookies are used to improve your website experience by identifying online behaviors and customizing the ads you view to reflect your browsing experience.
Cookies are a commonly used technology and many web browsers default to automatically accept Cookies. If you decide that you do not wish to receive Cookies, refer to your browser’s online help for further instruction and information on setting Cookie preferences. If you do not accept cookies, you may continue to browse our website; however, you should be aware that certain features of our website may not function properly without Cookies.