Privacy Policy

Kilgour Bell Insurance values your business and we thank you for your confidence in choosing our firm as your source of advice and products. As our client, you trust us with your personal information. We respect that trust and want you to be aware of our commitment to protect the information you share in the course of doing business with us. This document outlines our practices with respect to the collection, use and disclosure of your personal information.

Privacy Statement

Kilgour Bell Insurance (“we”, “us” or “our”) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this Privacy Statement is to inform our customers and other individuals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information. Personal information is information about an identifiable individual, as more particularly defined under applicable privacy legislation. This Privacy Statement applies to our collection, use and disclosure of personal information of Canadian residents. This Privacy Statement does not apply to information about our employees or to information that is not personal information, such as information that does not identify a particular individual, like anonymous or aggregate data.

Personal Information

Kilgour Bell Insurance, 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:

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• name, address, email address, telephone number, and other contact information;
• age, birth date, social insurance number, ID number, gender, credit card number or license plate number;
• information about your preferences, income, assets or personal finances;
• medical records, credit records, loan records, driving records, employment records, insurance or transaction history;
• information about your insurance claims or claims history;
• password and log-in information; and
• such other information we may collect with your consent or as permitted or required by law.

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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 or in person. We may also collect personal information about you from other sources, on notice to you or as required to provide services to you, such as other insurance brokers, insurance companies, consumer reporting agencies, industry associations and data banks, investment product suppliers, marketing agencies, government agencies or medical plans, claims adjusters, employers and inspectors.

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Use of Personal Information

Kilgour Bell Insurance generally uses personal information to manage and administer our business, including to understand your insurance needs, communicate with you effectively and 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 and monitor creditworthiness, 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.

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We 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 to otherwise collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. In some cases, these service providers may be located outside Canada. Reasonable contractual or other measures we may take to protect your personal information while it is processed or handled by these service providers are subject to legal requirements in Canada. However, in limited circumstances, your personal information may be subject to, and accessed under, the laws of the countries in which our service providers operate.

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Disclosure of Your Personal Information

As necessary to carry out the purposes for which Kilgour Bell Insurance collects and uses your personal information, we may disclose your personal information to third parties, such as people who seek your personal information as your authorized representative, 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.

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We may also disclose your personal information with your consent or as permitted or required by law.

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Disclosure to Affiliates. Personal information may be disclosed to our affiliates for internal audit, management, billing or administrative purposes.

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Business Transactions. Personal information may be used by us 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 example:

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• 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.

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Assignees or successors of Kilgour Bell Insurance or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.

Your Consent

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Kilgour Bell 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.

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Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be expressed (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). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt-out” option provided, if any. 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, 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.

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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.

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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 to failing to provide or withdraw 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 fulfil 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 of Personal Information

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. Authorized employees, agents, and mandataries of Kilgour Bell Insurance who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

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We will retain your personal information only as long as it is reasonably required to fulfill the purpose for which it was collected. The retention period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Privacy and the Internet

On our website, we may also collect information that helps us understand how you and others use our website. Examples of these types of information include internet protocol (IP) addresses, cookies, internet tags and navigational data.

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An IP address is a number automatically assigned to users’ computers when they access the internet. This number does not identify the user’s name or email address. This information may be used to perform certain operations including without limitation to measure website traffic, to help to understand how people are using our website and to improve our website and services provided.

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“Cookies” are small text files that our website sends to your browser and ask permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular website. Cookies allow website applications to respond to you as an individual. The website application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies help us analyze data about our website traffic and general internet usage, such as recognizing repeat visitors, while allowing us to improve our website to understand how and when pages are visited. We only use this information for statistical analysis purposes and then the data is removed from the system. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most website browsers automatically accept cookies, but can usually modify your browser settings to decline cookies if you prefer. This may prevent some parts of our website from functioning properly if cookies are disabled.

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Internet tags are smaller than cookies and tell our website’s server information such as the IP address and browser type related to a user’s computer. Tags may indicate how many times a page is opened and which information is consulted.

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Navigational data (including log files) are used for system management, to improve the content of our website, for market research purposes and to communicate information to visitors. This may include the website you came from, your browser type, domain name and time and date of access.

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Access, Correction and Contacting Us

Kilgour Bell Insurance may establish and maintain a file of your personal information for the purposes described above, which will be located at the applicable office set out below. 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, you may write to our Privacy Officer at 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.

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Kilgour Bell Insurance

310-1600 Ness Avenue,

Winnipeg MB R3J 3W7

Attention: Privacy Officer

204-945-9799

info@kilgourbell.com

Privacy Statement Changes

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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 Privacy 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 Privacy 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.

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