Introduction

In this privacy policy, “we”, “us”, and “our” means Neilson Financial Services Inc. and “you” and “your” means the individuals whose personal information we may collect, use, and disclose in accordance with this privacy policy.

By providing us with your personal information you will be deemed to agree to the terms of this privacy policy. We therefore encourage you to read this privacy policy carefully before you provide your personal information to us.

Our Commitment to you

We understand how important your privacy is. To evidence our commitment to managing your personal information properly we have developed and follow a privacy code which is based on the ten fair information principles contained in the Personal Information Protection and Electronic Documents Act. Please see Appendix 1 of this privacy policy to view a copy of our privacy code.

Your personal Information

What types of personal information we may collect, use and disclose.

Personal information means any information which is about an identifiable individual. The types of personal information we may need to hold about you include your name, address, email address, and telephone number, as well as more sensitive information such as your age, gender, financial information, and health information.

In order to process your application, a report concerning your medical conditions and insurability may be made to MIB. MIB, LLC, is an organization of insurance companies that operates a confidential database of personal information about individuals, including health information.

If you apply to an MIB Member company for life or health insurance coverage, or if a claim for benefits is submitted to a Member company, MIB may, with your authorization, supply that company with the information in its file. You can request a free copy of your MIB Consumer file at www.mib.com, or by calling 866-692-6901 toll free. You can also seek a correction from MIB if you believe any information held is inaccurate.

You authorize MIB and any MIB member insurer to provide any medical or personal information that it has about you to Canadian Premier Life Insurance Company its reinsurers and any MIB authorized third party service provider acting on Canadian Premiers behalf and also authorize these companies to make a brief report of your personal health information to MIB.

How we may collect your personal information

We may collect your personal information when you interact or engage with us by telephone, mail or via our website or we may also collect your personal information via your authorized representative(s). Please see Appendix 2 of this privacy policy for further detail about the information we may collect via cookies, web beacons and other similar technologies when you use our website.

How we may use and disclose your personal information

We may use your personal information: (i) to inform you about products or services which we think may be of interest to you, (ii) to assess your eligibility for any insurance products or services we distribute, (iii) to provide administration services in respect of any insurance products or services we distribute, (iv) to respond to questions and other requests raised by you, (v) to optimize your experience on our website, (vi) for internal purposes, such as analyzing and managing our business and improving our products and services and (vii) to satisfy our legal and regulatory requirements.

We may need to disclose your personal information to third parties in connection with the above purposes, such as our insurer and reinsurer partners, service providers and the Medical Information Bureau. We may also be required to share your personal information from time to time with legal and regulatory bodies, organizations who work to detect and prevent fraud or anybody to whom we may transfer or sell all or part of our business.

How long we will retain your personal information for

We retain your personal information only for as long as is necessary for legal, regulatory, or operational reasons, such as to administer any insurance products or services we distribute to you or for tax and other reporting requirements.

How we will protect your personal information

We have appropriate safeguards in place to protect your personal information against loss, theft, and unauthorized disclosure, copying, use or modification. We also strictly limit access to your personal information to those of our employees, partners and service providers who require access to it.

Transferring your personal information outside Canada

We or our partners and service providers may need to transfer your personal information to our service providers located in the United Kingdom and/or the United States of America. This means that your personal information may be accessible to law enforcement and regulatory authorities in the United Kingdom and/or the United States of America. However, if we transfer your personal information to third parties outside Canada, we will ensure that such third parties protect your personal information in a manner which is consistent with this privacy policy.

Your consent

We rely upon your consent to collect, use and disclose your personal information for the purposes set out in this privacy policy unless we are permitted or required to do otherwise by law. We may obtain your consent in writing (including electronically), verbally or through your authorized representative(s). In limited circumstances, your consent may also be implied.

Subject to any legal or contractual restrictions, you may withdraw any consent upon which we rely to use and disclose your personal information for the purposes set out in this privacy policy by contacting our Privacy Officer. However, we may be unable to provide or to continue providing our products and services to you in these circumstances.

Your rights

You have the right to request to be informed of the existence of any personal information which we hold about you, as well as the way in which we use and disclose that information. You are also entitled to request access to any personal information which we hold about you.

You may also challenge the accuracy and completeness of any personal information which we hold about you. Where any personal information which we hold about you is inaccurate or incomplete, you are entitled to request that the inaccurate or incomplete personal information is appropriately amended.

You may exercise your rights set out above at any time by contacting our Privacy Officer. There may be a reasonable charge incurred in connection with us providing any copies of your personal information or we may be unable to comply with your request fully, but we will inform you beforehand if this is the case unless we are prohibited from doing so by law.

Contact Us

For further information or if you wish to make a complaint with regards to our management of your personal information, please contact our Privacy Officer by writing to us at Cover Direct, PO Box 64004, Royal Bank Plaza, Toronto, Ontario, M5J 2T6, by email at service@coverdirect.ca or by telephone at 1-844-990-4254.

We reserve the right to update this privacy policy from time to time and any changes made by us to this privacy policy will be posted on this website.

Last updated: September 1, 2021

Appendix 1

Our Privacy Code

Accountability

We are responsible for your personal information which is in our control. We have therefore appointed a Privacy Officer to oversee and hold us accountable for our management of your personal information.

Identifying Purposes

We will always identify the purposes for which we may use and disclose your personal information before or at the time of its collection by us. These purposes are referred to as the “identified purposes”.

Consent

Except as otherwise permitted or required by law, we will only collect, use or disclose your personal information with your permission.

Limiting Collection

We will only collect your personal information in a way which is fair and lawful, and we will only collect as much of your personal information as is necessary for the identified purposes.

Limiting Use, Disclosure and Retention

Except as otherwise permitted or required by law, we will only use and disclose your personal information for the identified purposes. We will also retain your personal information only for as long as is necessary for the identified purposes.

Accuracy

We take steps to ensure that the personal information you give to us is recorded accurately and completely, and that any changes required to be made to your personal information are made promptly.

Safeguarding Information

We will always take steps to protect your personal information which are proportionate to the sensitivity of that information.

Openness

We will always make detailed information about our policies and procedures for managing your personal information readily available to you.

Individual Access

Subject to exceptions permitted by law, we will comply with any request you make to us to access the personal information we hold about you and be informed of the existence, use and disclosure of that information by us. You may also challenge the accuracy and completeness of the personal information we hold about you and have that information updated as appropriate.

Challenging Compliance

You may challenge our compliance with these principles or raise a complaint about our management of your personal information by contacting our Privacy Officer. We will always treat such challenges or complaints seriously.

Appendix 2

We may use cookies, web beacons and other similar technologies on our website to understand how you use our website and hence improve the ease of use of our website. Such technologies may also be used by us to temporarily store information, personalise your experience on our website or to ensure that any advertising delivered to you via our website is informative and relevant.

The type of information we may collect via cookies, web beacons and other similar technologies does not typically constitute personal information but includes information such as the type of operating system you use, the time and duration of your visits to our website and which parts of our website you visit.