Protecting your privacy is important to us
In this Privacy Policy:
- “we”, “us” and “our” refers to ivari and ivari’s authorized third party administrators
- “you” includes:
- Any individual contracted with, or applying to be contracted with, ivari to solicit or distribute ivari products (“Distributor”, which also includes a producer, and life insurance agency), and
- Any employee or authorized representative of a Distributor communicating with us and/or using the ivari.ca website and/or ivari’s online platforms, including mobile applications (together, the “Websites”).
This Privacy Policy explains:
- What personal information we may collect and retain from you.
- How and why ivari collects, uses, and discloses your personal information.
- ivari’s practices for maintaining, protecting, and disclosing your personal information.
- Your rights and choices in respect of ivari’s handling of your personal information.
- How to contact ivari’s Privacy Office
While collecting and using personal information is necessary to ivari’s business as an insurance provider, protecting your personal information and respecting your privacy is also important and we take this responsibility very seriously. As part of our commitment to protecting your personal information, we will update our Privacy Policy periodically to reflect applicable Canadian and provincial laws and guidelines.
Please review this Privacy Policy carefully and on a periodic basis to understand ivari’s current policies and practices for handling your personal information. We may review and amend this Privacy Policy from time to time to comply with changes in law, guidance and business processes. We will notify you of any modifications to this Privacy Policy that may materially affect the way we handle your personal information.
By accessing or using the Websites and/or by continuing to conduct business with ivari, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.
Except as indicated in this Privacy Policy, if you do not consent to ivari’s policies and practices, it is your choice not to use our Websites and/or to not conduct business with ivari.
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Accountability
ivari is responsible for personal information under its control. ivari’s Privacy Office is responsible for maintaining ivari’s Privacy Program and responding to privacy inquiries.
In Canada, “Personal information” means any information that relates to an actual person and permits or leads to the possible identification (directly or indirectly) of that person, whether alone or when combined with information from sources otherwise available, including sources publicly available.
When you give consent
We require your consent to collect, use and transfer your personal information, except as otherwise authorized by law. When you give us your consent, we collect, use, transfer and maintain your personal information in accordance with this Privacy Policy and as needed for the purposes specified below.
If we collect, use and transfer your personal information for optional purposes not specified in this Privacy Policy, we will obtain your consent separately for such purposes. You may decline to give your consent or later withdraw your consent to any one of these optional purposes without affecting your contract with ivari. No matter the purpose, we will maintain and safeguard your personal information in accordance with this Privacy Policy.
Withdrawing your consent
You may ask to withdraw your consent to any collection, use and transfer of your personal information at any time. If you do so, we may not be able to continue to provide certain resources or other benefits made available by us to you, and we may be required to modify or terminate our contract with you. We will provide an explanation of the impact of your decision.
In some situations, we may not accommodate your withdrawal of consent due to legal and contractual restrictions.
For more information or to withdraw your consent, please contact ivari’s Privacy Office at the address below.
Why we collect and use your personal information
We collect and use your personal information for the following purposes:
- Verifying your identity
- Evaluating your suitability to be contracted with ivari to solicit and distribute ivari products and provide service to consumers
- Administering your contract with ivari and the obligations within, which includes an ongoing review of your performance and suitability to act as an advisor
- Supporting business operations necessary for us to conduct business
- Improving the products and services we offer including through research and analytics
- Communicating with you about other ivari products and services
- Complying with our legal and regulatory obligations (such as tax reporting, compliance with anti-money laundering and anti-terrorist financing laws, prudential and market conduct laws, and unclaimed property laws), and/or any legal or regulatory orders (i.e., a court order, subpoena)
The personal information we collect and use
The personal information we may collect and use includes:
- Name, contact information (i.e., full legal name, residential and/or mailing addresses, phone number, and email address), and authentication details (i.e. passwords, personal identification numbers (PINs), and answers to our identity authentication questions)
- Financial information (i.e., information relating to your tax residency, credit bureau information including past or current bankruptcies, and payment details)
- Current age, date of birth, and gender
- Government-issued identification documents (e.g., driver’s license, passport, and Social Insurance Number (SIN))
- Life agent licensing information and information about errors and omissions insurance coverage
- Residency information, immigration and citizenship status
- Criminal record and records maintained by provincial and federal regulators or government agencies (e.g., provincial securities or insurance regulators, privacy regulators, Canada Revenue Agency, Office of the Superintendent of Financial Institutions, Financial Transactions and Reports Analysis Centre of Canada)
- Employment information (i.e., name of employer, occupation, salary, and benefits)
- Relationships with other insurers and distributors
- Social media accounts and activity
- Character, general reputation, personal characteristics, and connections to certain individuals
- Information provided through your interactions and communications with us and our Websites.
This list is not exhaustive and is intended to provide examples of what personal information we collect. We collect personal information as needed for the purposes specified in this Privacy Policy, and we may collect additional personal information provided by you or your authorized representatives.
Where we collect your personal information from
We collect personal information when you start an application to be contracted with ivari and throughout the duration of your contract with ivari in accordance with the consents you provide or ivari’s obligations. In particular, we collect your personal information from:
- Applications, forms, questionnaires, and supporting documentation disclosed or submitted by you, your authorized representative(s), or your contacts in respect of your application or contract with ivari
- Information disclosed by you when communicating with us, including via email, phone, fax, online, or interacting with our Websites (see our Cookie Policy)
- Your supporting associates, which may include your managing general agency (or other distributor), market intermediaries, and your employees and subcontractors (current or former)
- Public sources, such as government agencies, registries, social media, and websites
- Third parties that we work with to administer your contract, including address and identity verification service providers
- Any other sources as authorized by you in respect of your application or contract
We may also collect your personal information from the following external sources:
- Current or former insurance companies or agencies to whom you may apply to or be or have been contracted with to solicit or distribute insurance
- Consumer and credit reporting agencies, including credit bureaus
- Personal information agents
- Law enforcement, motor vehicle and driver record authorities, regulators (e.g., financial services, securities, privacy, etc.), and other governmental agencies or registries in any relevant jurisdictions
- Professional or industry registries or associations,
- Detective and security agencies, or other organizations whose functions are the prevention, detection or repression of crimes, offenses, breaches of regulatory requirements, and/or violations of professional requirements and/or codes of conduct
- Any other sources as authorized by you in respect of your contract
These lists are not exhaustive and are intended to provide examples of sources of personal information. We collect personal information as needed for the purposes specified in this Privacy Policy.
You have choices regarding some of our collection of personal information:
- Collection of SINs: When paying compensation to you, we require your SIN for tax reporting purposes. We may also receive your SIN in a credit check report. In other instances, such as identification purposes, providing your SIN is optional. If you provide it to ivari for optional purposes, ivari may use it to streamline screening and administrative processes.
- Phone calls: Your calls may be recorded in order to document the information you provide and to monitor and improve our customer service.
- Cookies: We may send cookies to visitors of our Websites. You can select your preferred cookie settings in our cookie consent manager.
Transfers of personal information to third parties
If required for the purposes described in this Privacy Policy, we may share your personal information with:
- Trusted third-party processors retained by ivari to assist in administering your contract with ivari
- Third party service providers, including consultants or consulting firms, information technology services and products companies, cloud, web hosting, data analytics, processing and management services, and similar service providers retained by ivari to support business operations
- ivari’s affiliates and reinsurers
- Your supporting associates, which may include your managing general agency (or other distributor), market intermediaries, and your employees and subcontractors
- Current or former insurance companies to whom you may apply to or be or have been contracted with to solicit or distribute insurance
- Other persons authorized by you or by law, but only to the extent permitted by you or by law
Your personal information may also be released:
- In cases of suspected criminal activity, financial abuse, contravention of law, for the detection and prevention of fraud, if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of you or of others (for instance, by disclosing to an investigative body, legal, or regulatory authorities)
- To comply with a court order, search warrant, or other demand or inquiry from a legal or regulatory authority, or to initiate or respond to any legal proceeding
- To a buyer or other successor, in the event of a merger, divestiture, restructure, reorganization, sale or transfer of some or all of our assets, or other corporate change, in which your personal information is among the assets transferred, to the extent required for the purposes of such transaction or corporate change or to the extent permitted by applicable law
Please note that we will never sell your personal information.
Information may be located outside of your jurisdiction
We and our third-party processors/service providers may conduct operations outside of your jurisdiction. Your personal information may be used, stored, or accessed in these other jurisdictions and may be subject to the laws of those jurisdictions. For example, personal information may be disclosed in response to demands or requests from governments, regulators, courts, or law enforcement agencies in those jurisdictions. When your personal information is transferred to a different jurisdiction, we will take steps to protect your information in accordance with applicable data protection laws and this Privacy Policy.
How we protect your personal information
During the course of your business relationship with ivari, we create and maintain a file that includes your personal information and is maintained on our systems. We have physical, electronic and administrative safeguards in place to prevent unauthorized access, transfer, use, or loss of your personal information.
To safeguard your personal information, we:
- Use technology, such as firewalls, anti-virus software, and passwords
- Develop and comply with internal privacy policies and procedures to protect personal information, respond to privacy questions, complaints or breaches, and destroy personal information that is no longer required
- Regularly review and update our policies
- Regularly update internal access levels to match the sensitivity of the information
- Administer regular employee privacy training
We will access and use your personal information only as required to carry out our work or contractual or legal responsibilities in relation to the purposes described in this Privacy Policy. Our employees and third parties are also required to protect the confidentiality of your personal information in accordance with this Privacy Policy, ivari’s privacy and security practices, and applicable Canadian and provincial privacy laws.
How long ivari retains your personal information
We will only keep your personal information for as long as it is needed for the purposes described in this Privacy Policy, or as required by applicable Canadian laws or guidelines. The length of time we keep personal information depends upon nature of the information and may extend beyond the end of your relationship with ivari.
When such personal information is no longer required, we have procedures to destroy, delete, erase or convert it to an anonymous form so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or without your further consent.
Know your risks
While we have safeguards to protect your personal information, in the event of an unauthorized access, use, disclosure, or loss of your personal information (a “data security incident”), ivari will follow all steps required by applicable privacy laws in the event of a data security incident, including, as applicable, notifying any affected individuals, and suggesting steps to reduce risk of harm, and reporting the incident to the appropriate regulatory authorities.
We also ask you to contact us immediately if you are affected by identity theft or other data security incidents so we can help you protect the information in your ivari file.
Automated Decision-Making Processes
The personal information provided in your application and during the duration of your contract may go through an automated decision-making process. If you would like more information and/or to submit observations regarding the automated decision, please contact ivari’s Privacy Office at the address below.
Your right to request access to your personal information
You have the right to request access to your personal information at any time.
In some situations, we may not be able to provide you with all your personal information.
To access your personal information, please contact the Privacy Office at the address below.
Accuracy of personal information
In the event our records contain inaccurate or incomplete information about you, you have the right to request corrections by ivari. To do so, please contact the Privacy Office at the address below.
In some situations, we may not accommodate a request to change information.
Contacting the Privacy Office
If you have privacy-related questions, concerns, complaints, or comments, please contact the Privacy Office at:
Chief Privacy Officer
Privacy Office
200-5000 Yonge Street
Toronto, ON M2N 7E9
Email: [email protected]
Telephone:
1-866-447-7390 (English)
1-866-880-6075 (French)
To help us respond to your message, please provide your name, contact information, and any details relevant to your request, including the name of the department or person you have already contacted at ivari.
Cookies
ivari uses cookies and web beacons on our Websites (together, “Cookies”). Where required by applicable law, we will not activate certain Cookies without your consent.
Social media
ivari is active on social media and you may interact with us on these platforms. These social media platforms have their own privacy policies, cookie policies, and terms of use. We are not affiliated with the providers of the social media platforms we use. Content that you post may not be private and may be seen by others who use the platform. We advise you to read the privacy policies, cookies policies, and terms of use of these platforms before using them and posting any personal information.
ivari reserves the right to remove any posts or comments that constitute or include sensitive personal information, personal attacks, defamatory, abusive, or hateful comments.
Third-Party Links
ivari’s Websites may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you.
If you follow a link to a third-party website or engage a third-party plugin, please note that this Privacy Policy does not apply to information that you provide to or is collected by such third parties through any content that may link to or be accessible from the website. These third parties may have their own privacy policies and we do not accept any responsibility or liability for the actions or policies of third parties. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.