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Privacy Policy
OUR COMMITMENT
Trans Global Insurance values your business. We thank you for your confidence in choosing Trans Global Insurance as your source of advice and products that protects you and your family from unforeseen events. We care about our customers and, as part of that concern, appreciates that our customers care about how Trans Global Insurance handles their personal information. Our goal is to make your experience searching for and purchasing insurance products the very best we can. This goal includes keeping your information secure, and to collect, use and disclose your information only in accordance with this Privacy Policy. Trans Global Insurance promises to abide by this Privacy Policy and to deal with all personal information in a responsible, professional and respectful manner. In the unusual circumstance that we fall short of these goals, we promise to make every effort to address and resolve your concerns in an appropriate, fair and timely manner.
WHO ARE WE?
“Trans Global Insurance” as used in this Privacy Policy includes Trans Global Life Insurance Company and Trans Global Insurance Company. For the purposes of this Privacy Policy, we, us and our mean Trans Global Insurance, and you and your mean a customer or prospective customer of Trans Global Insurance.
PERSONAL INFORMATION WE COLLECT
Trans Global Insurance and its agents and representatives collect personal information in a number of circumstances in the course of conducting our business. Personal information we may collect includes: • name, address, email address, telephone number, and other contact information; • age, birth date, social insurance number, ID numbers, gender, credit card numbers or license plate numbers; • information about your preferences, income, assets or personal finances; • medical records, credit records, loan records, driving record, employment records, insurance or transaction history; • information collected through your communications and interactions with Trans Global Insurance and our website,● information about your insurance claims or claims history; and • such other information we may collect with your consent or as permitted or required by law.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We generally collect personal information directly from you, for example, from application forms that you fill out for our insurance products and services, or when you communicate with us by telephone, email, our online platforms or in person. We may also collect personal information about you from other sources, such as other insurance brokers, insurance companies, consumer reporting agencies, industry associations and data banks, investment product suppliers, marketing agencies, government agencies, claims adjusters, employers and inspectors.
HOW WE USE YOUR PERSONAL INFORMATION
Trans Global Insurance generally uses personal information to manage and administer our business, including to understand your insurance needs, communicate with you effectively and to provide you with the products and services you request. For example, we may use your personal information to: • determine your eligibility for, offer and/or provide you with insurance products and services that you request; • evaluate credit worthiness and monitor, collect premiums and fees; • verify your identity; • determine prices, fees and premiums including by evaluating your coverage needs and assessing risk; • maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services; • update credit bureau reports • investigate and settle claims; • determine your eligibility for and offer and provide other products or services that may be of interest to you, such as investment or retirement products or group benefits, unless you ask us not to; • detect and protect against error or fraud; • compile statistics and conduct market research; • maintain business records for reasonable periods; • meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and • otherwise with consent or as permitted or required by law.
WHO HAS ACCESS TO MY PERSONAL INFORMATION
Authorized employees and agents of Trans Global Insurance who require access to your personal information in order to fulfill their job requirements will have access to your personal information. Our employees commit annually to protect the confidentiality of the personal information they need while performing their duties and must regularly take security and privacy training.
WHAT WE WILL NOT DO WITH YOUR INFORMATION
We never sell or trade your personal information to any person or organization outside of Trans Global Insurance.
DISCLOSURE OF YOUR PERSONAL INFORMATION
In order to carry out the purposes for which Trans Global Insurance collects and uses your personal information, we may disclose your personal information to third parties, such as other insurance brokers, insurers, consumer reporting agencies, claims adjusters, government, regulatory and self-regulatory agencies, lawyers, financial institutions, benefits providers and medical professionals, and others involved in the claims handling process in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance brokerage and insurance practices. We may also disclose your personal information with your consent or as permitted or required by law. Personal information may be disclosed to our affiliates (including outside of Canada) for internal audit, management, billing or administrative purposes. We may also disclose personal information to our affiliates so that they may send you information about their products and services. However, if you do not want your personal information disclosed for these marketing purposes, you may contact us at any time as described further below. Trans Global Insurance may transfer personal information to outside agents or service providers that perform services on our behalf. The services that may be performed by our agents or service providers consist of data processing, data warehousing or administrative services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Personal information may be used by Trans Global Insurance and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples: • permitting those parties to determine whether to proceed or continue with the transaction; and • fulfilling reporting, inspection or audit requirements or obligations to those parties. Assignees or successors of Trans Global Insurance, our business or our assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.
YOUR CONSENT
Trans Global Insurance collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example, to comply with a court order, to comply with local or federal regulations, or a legally permitted inquiry by a government agency, or to collect a debt owed to us. Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection. If you obtain insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her personal information for the purposes described above. You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. There may be consequences for failing to provide or withdrawing your consent, such as your inability to acquire or renew an insurance policy and/or cancellation of a policy. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and foreign government entities as required to comply with laws).
SECURITY
We take reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
COOKIES AND NON-IDENTIFYING INFORMATION
Trans Global Insurance uses both session cookies (which are automatically deleted from your computer when you close your browser session) and persistent cookies (which remain on your computer between sessions) in order to facilitate your ability to use the website efficiently and effectively. By using our website while your browser is set to accept cookies, we imply your consent to them. If you are browsing, requesting information or quotes or shopping online, we and/or our trusted third party agents track your movement through our website and collect statistics about your navigation, such as page views and time spent on the website, using click stream data and tag software. This information about your visit to our website is then aggregated with the information about other individuals’ visits. Using this non-identifying information, we strive to continually improve and enhance the online experience of all of our customers, to evaluate the success of marketing campaigns and to report on aggregated site usage. In no case is click stream data or tag software used by us to collect or store personally identifiable information.
STORAGE OF YOUR PERSONAL INFORMATION
Trans Global Insurance takes prudent precautions and implements safeguards to ensure the protection and confidentiality of your information. Your information is usually stored in Canada, but we may use service providers located outside of Canada. If we need to disclose personal information with these service providers, Trans Global Insurance will ensure the protection and confidentiality of this information meets our own requirements and will require these service providers to contractually agree to comply with these requirements.
WHEN AND HOW IS MY INFORMATION DISPOSED OF?
Personal information you provide to us is purged from our systems and records after seven (7) years, being a reasonable period of time following expiration of any warranties and other obligations we might have to you and/or to public bodies. Once the retention period has expired, we ensure that your personal information is safely disposed of or de-identified. While deletion is a final and irreversible disposal process, de-identification means that your personal information is altered so that it can no longer directly or indirectly identify you. Deletion and de-identification are carried out in a safe and secure manner, in accordance with applicable best practices.
ACCESS, CORRECTION AND CONTACTING US
Trans Global Insurance may establish and maintain a file of your personal information for the purposes described above. Subject to applicable legal restrictions, you may request to have access to the file containing your personal information and the correction of your personal information by writing to the address below. We may take reasonable steps to verify your identity before granting access or making corrections. In addition, if you wish to make inquiries or complaints, obtain information on how to access and rectify the files held by personal information agents we consulted or have other concerns about our personal information practices (including our use of service providers located outside of Canada), you may write to the address below. Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request correctly. Trans Global Insurance: Suite 275, 16930-114 Avenue Edmonton, Alberta T5M 3S2 Attention: Chief Privacy Officer Email: tgiprivacy@transglobalinsurance.ca. Our Chief Privacy Officer, or an appropriate delegate, will review your communication and, if necessary, respond to you directly.
PROCEDURE FOR RECEIVING AND RESOLVING PRIVACY COMPLAINTS
Our Chief Privacy Officer is responsible for receiving complaints. Our Chief Privacy Officer's responsibilities include receiving complaints alleging a violation of applicable privacy laws including PIPEDA and other provincial laws. Our Chief Privacy Officer is also responsible for investigating and resolving such allegations and complaints, and providing information to persons who request and are entitled to additional information in the manner specified by the privacy laws. ***Filing a Complaint.*** Trans Global shall provide the following assistance when a person wishes to file a complaint: A) Verbal or Written Complaints to Trans Global. If any person or organization wishes to complain to Trans Global, the person shall contact or shall be directed to Chief Privacy Officer or designee. The Officer, or its designee, shall ask the person whether to submit a written complaint. B) Written complaints. If the person wishes to submit a written complaint, the person may be directed to a form that captures the nature of the complaint, relevant dates, individuals involved and any other information necessary to enable a review of the complaint. ***Determination of Privacy Rule Violation*** All complaints in respect of an alleged or suspected violation of privacy or breach of personal information shall be investigated to determine whether a violation or breach has occurred Our Chief Privacy Officer shall conduct a fact-specific analysis, and maintaining documentation of such determinations for a period of seven years. Where a Breach of personal information is determined to have occurred, our Chief Privacy Officer shall notify each individual whose unsecured personal information has been, or is reasonably believed to have been, inappropriately accessed, acquired, or disclosed. Where a breach is not deemed to meet the significant harm threshold Trans Global will apply applicable criteria under applicable laws. For complaints, if after contacting us, you are still not satisfied with the response you received, you may also contact the appropriate provincial or federal privacy commissioner. Our Chief Privacy Officer will give you this contact information upon request.
PRIVACY STATEMENT CHANGES
This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of Personal Information or use of our products or services following any changes to this Privacy Statement constitutes your acceptance of any such changes.
Trans Global Insurance Company
Suite 275, 16930 114 Avenue NW
Edmonton, AB
T5M 3S2
Attention : Chief Privacy Officer
Our Chief Privacy Officer, or an appropriate delegate, will review your communication and, if necessary, respond to you directly..