Desjardins Insurance Privacy Code

Privacy Code - Quebec

Date of last update: April 12, 2021

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At Desjardins Insurance, an important part of our company's commitment to provide our customers with service excellence is our respect for their right to privacy. Keeping our customers' personal information in strict confidence is a cornerstone of Desjardins Insurance's business. Accordingly, we have adopted this privacy code, which details the privacy principles that are to be followed.

Here are some definitions of terms used in this privacy code:

• “affiliated general insurance companies” means:
  • Certas Direct Insurance Company in Alberta and Ontario
  • Certas Home and Auto Insurance Company in Ontario, Alberta and New Brunswick and its agents
  • The Personal General Insurance Inc. in Quebec
  • The Personal Insurance Company in all other provinces and territories.
• "personal information" means any information pertaining to a specific individual that can be used to identify him or her
• "third party" means any individual or corporate entity outside of, and not affiliated with, Desjardins Insurance
• "we" means Desjardins Insurance
• "you" means any individual about whom we collect personal information in order to carry out the business of property and casualty insurance. It includes our insureds and other persons to be insured under your policy, former insureds, applicants, claimants and individuals involved in a claim.

To learn about our policy when you use the Desjardins Insurance Home-Auto application, read our Management and protection of personal information policy for mobile application users.

Accountability

We are responsible for all personal information under our control and have put safeguards in place to ensure the confidentiality of all personal information that you provide. Individuals within our company who have responsibility for the day-to-day collection and processing of personal information pay special attention to the manner in which such information is handled. If we are required to send personal information to a third party, we will use contractual or other means to ensure the third party provides a comparable level of protection. We have also established and implemented policies and procedures to give effect to this privacy code in order to protect your personal information and to receive and respond to customer complaints and inquiries.

Identifying purposes

We collect, use and disclose your personal information for the purposes of providing insurance products and services. More specifically, we collect, use and disclose personal information from you, as well as from third parties, where applicable, in order to:

• assess your application for insurance and your insurance quotes
• manage risk
• communicate with you concerning our insurance products and services
• issue and manage your insurance quotes and insurance policies
• process your claims
• prevent, detect and prosecute fraud
• analyze business results and for statistical purposes
• obtain your feedback about our organization, products and services
• update the information we have about you
• act as permitted or required by the law.

Certain personal information may also be collected for the purpose of promoting our products and services and those of any other Desjardins Group components that may be of interest to you. If we intend to use or disclose your personal information for a different purpose than those stated above, we will obtain your consent first, unless the new purpose is required by law. Under no circumstances will your personal information be sold or inappropriately disclosed to third parties.

We share limited personal information such as your name, address, telephone number and date of birth with our affiliated general insurance companies to make it faster to identify you and to provide you with products and services that suit your needs. Additionally, we share further personal information with Certas Direct Insurance Company about your transactions and interactions with us.

If you are a Desjardins member, limited personal information could be shared with another Desjardins component for identification purposes, in order to provide access to your insurance file through AccèsD and to determine your eligibility to certain member benefits.

Recording of communications

Exchanges you have with us, such as telephone calls, may be recorded and listened to to ensure the quality of our service and the accuracy of your information and instructions. If you do not want your communications to be recorded, you can notify us at the beginning of the call and alternatives will then be offered to you. You may also use our Online Services to perform certain insurance transactions.

Consent

Your consent is required for the collection, use or disclosure of your personal information by us, unless otherwise required or permitted by law. When you voluntarily provide certain personal information to us, including when you submit an insurance quote, you are also giving your implied consent (if express verbal or written consent has not otherwise been requested) for us to collect, use and disclose that personal information to fulfill the identified purposes in compliance with this privacy code. The applications, quotes, forms and documents we use include information related to your authorization, which allows us to collect, use or disclose personal information concerning you. It is important to read all such points carefully.

In certain circumstances, we may ask you to provide us with the personal information of other people to be insured or already insured under your insurance policy. When you provide us with another person’s personal information, you undertake to obtain their consent to provide us with said personal information and to us using it according to this privacy code.

You may withdraw your consent at any time, with reasonable notice, subject to legal or contractual obligations which must be fulfilled by us. Withdrawal of consent may prevent us from providing you with the requested insurance products or services, including providing you with an insurance quote and processing a claim.

Limiting collection

The amount and the type of information we collect shall be limited to that which is necessary to fulfill the identified purposes. We will obtain personal information primarily from you. However, with your consent and within the limits authorized by law, we may also collect personal information from other external sources, including other property and casualty insurers, public and private sector underwriting or claims information databases, and credit reporting agencies.

Limiting use, disclosure and retention

We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as may be required or permitted by law. We may be required to disclose personal information to external sources in accordance with legal and insurance regulatory reporting requirements or generally accepted insurance practices.

We may store and/or share personal information about you with those performing services for us located outside of Canada. In this event, we ensure that appropriate contractual or other means are in place to protect your personal information. Your personal information is, however, subject to the laws of that jurisdiction and therefore, may be accessible to the authorities of that jurisdiction.

Personal information that we have about you will be retained only for as long as it is required to fulfill the identified purposes. Where personal information is no longer required to fulfill the identified purposes, or for any other legal requirements or otherwise, it will be destroyed, erased or made anonymous.

We may use your contact information, physical addresses or technological addresses and telephone numbers shown on our solicitation lists to contact you and offer you our products and services, as well as those of any other Desjardins Group components that may be of interest to you. These solicitation lists are used strictly within the limits authorized by law, and you can be removed from our mailing list at any time simply by contacting us.

Accuracy

We will use our best efforts to keep your personal information as accurate, complete and up-to-date as is necessary for the identified purposes for which it is to be used. We will generally rely on you to provide updated information, such as changes to your address and other contact information. If you successfully demonstrate to us that any personal information on file is inaccurate, we will revise or correct said personal information. Personal information that includes a matter of opinion will not be considered inaccurate information and will not be subject to correction or amendment.

Safeguards

We will protect your personal information against loss or theft, and against unauthorized access, disclosure, copying, use or modification, with appropriate safeguards. Personal information contained in your file is accessible only to individuals authorized and qualified to access such information, and only when such access is required in the course of their duties.

Customer access

You have the right to access and correct the personal information that we have about you on file. To get access to your file, contact Client Complaint Management Centre in writing at the address shown below. Upon receipt of your written request, we will respond to you within 30 days or at such later date as may be permitted or required under the law. Access to your personal information may be limited or denied, but only under those circumstances where it is permitted or required under the law.

Email Address

We are committed to maintaining the confidentiality of your email address and not using it inappropriately. Email addresses collected are used for the purpose of sending information about our products and services, or to communicate with you about your insurance (such as insurance operations and transactions completed on our website), or to make you any offer you may be interested in. They may be shared in an encrypted fashion with third-party ad servers in order to allow for the identification of similar or customized audiences and also for the purpose of providing you with advertisements that are suitable for you according to your interests and profile. This sharing in an encrypted fashion does not allow the third-party ad servers to identify the email addresses. Third-party ad servers include advertising networks, publishers and social media platforms. You may disable customized advertising functions by adjusting your settings on the websites of the third-party ad servers.

You have the right to be removed from our mailing list at any time by contacting us or by using the unsubscription hyperlink at the bottom of our electronic communications.

Use of advertising tags without collecting personal information

We use advertising tags to help us improve our advertising inventory and placements.

These tags use certain features built into your mobile devices, more precisely the motion and orientation sensors (accelerometer/gyroscope).

Although no personal information is collected by these tags, you can block their activation by going to your browser settings to disable the motion and orientation sensors. Depending on the operating system installed on your mobile device, please note that these motion and orientation sensors may already be disabled by default.

Cookies

When you visit our website or use our application, information about you may be stored in cookies that we or third parties install on your computer or device.

This section explains what cookies are and describes which web and mobile measurement tools we use and how we use them. It also explains your options with regard to these technologies.

Openness

If you have any inquiries about this privacy code, you can contact us.

By mail:

Client Complaint Management Centre
Desjardins General Insurance Inc.
6300, boul. Guillaume-Couture
Levis (Quebec)  G6V 6P9

By phone: 1-866-835-8975

Challenging compliance

We have established an internal complaint review process andwill investigate all complaints regarding privacy. If a complaint is found to be justified, we will take appropriate measures to correct the situation. If your complaint cannot be resolved through our internal complaint review process, or if you prefer, you have the right to file a complaint with the Commission d'accès à l'information du Québec.

We may amend this privacy code from time to time. You can determine when this privacy code was last modified by consulting the date of the “Last Update” set out above. Your continuing relationship with us shall be deemed as acceptance of and agreement to any such modifications.