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This Privacy Policy sets out principles and practices of Dion Insurance Program Management Inc. (“us”, “our”, “we”), with respect to the handling of the personal information our customers (“you”, “your”). As part of our ongoing commitment to protecting your personal information, we have adopted a Privacy Policy, which is based on the privacy principles set out in the Personal Information Protection and Electronic Documents Act as well as applicable provincial privacy laws. For the purpose of providing you with certain services, we work together with the property and casualty insurance companies (“Insurers”) with whom we place insurance policies on behalf of our clients. Your personal information may be collected, used and disclosed by our Insurers, and this collection, use and disclosure is also governed by the privacy policies of our Insurers.

Our Commitment to You
Respecting your privacy and protecting your personal information is an important part of how we do business. Regardless of how the services we offer expand and the technology we use changes, we remain committed to protecting the privacy of your personal information. This Privacy Policy is part of our commitment to ensure that all personal information in our possession is protected and used in accordance with the law. This Privacy Policy does not replace the applicable privacy policies of our co-venturers. To the extent that a co-venturer’s privacy policy may permit disclosing your personal information to us, and when such disclosure occurs, your personal information will then be collected, used and disclosed by us according to this Privacy Policy. This Privacy Policy is subject to changes from time to time. Please ensure that you review this Privacy Policy regularly.

Your Personal Information
“Personal Information” is defined as information about an identifiable individual, or information that allows an individual to be identified, but does not include the name, title or business address or telephone number of an employee of an organization. This is a very broad definition and may encompass most types of information held such as race, medical, criminal, employment and financial history. The legislation only applies to information collected, used or disclosed in the course of commercial dealings.

It also includes, for example, an individual’s address, personal telephone number, date of birth, family status, marital status, occupation, driver’s license, driving record information, mortgage and loan details, an individual’s previous insurance experience, including claims history and an individual’s driving record, policy number and vehicle identity number.

We recognize that some Personal Information is highly sensitive, and we consider the sensitivity of the information in deciding how we will use it, and, if appropriate, disclose it, and in how we will obtain your consent to such use and disclosure.

Safeguarding Personal Information
Confidentiality is a priority for us and we take all the necessary measures to safeguard the privacy of the Personal Information contained in your file, whether you purchase your insurance through our service or not. We use SSL (Secure Socket Layer) protocol Internet security software together with VeriSign certificates for securing the exchange of confidential data. This security technology encrypts the Personal Information that you send us (including things like names, addresses, emails and telephone numbers), to protect it against being read as it travels over the Internet.

Collection, Use and Disclosure of Your Personal Information
We may collect Personal Information about you, including information obtained as a result of your relationship with us and others. We may collect, use and disclose your Personal Information for several purposes, including:

To communicate effectively with you;
To develop and maintain our relationship with you, including inviting you to comment on the services we provide to you;

To process your application or quote for services, and share your information with the providers of those services;

To provide and administer the services you have requested;

To approve transactions;

To verify your identity and to protect all parties from errors and fraud;

To verify your eligibility for certain services;

For marketing analysis purposes and to track and analyze your purchases and other transactions (including the number and amount of transactions by type, product code information, brand, etc.) and market our services;

For research and statistical analysis purposes (we anonymize information used for such purposes to the extent possible);

For testing, such as when updating systems or adding new vendor relationships (we anonymize information used for such purposes to the extent possible);

For data processing, website administration or information technology support;

To respond to inquiries about your application, account, insurance policy or any other business that you have with us;

To comply with legal and regulatory requirements; and

For any other purpose as set out in this Privacy Policy.

In addition to the purposes outlined above, we also collect, use and disclose to the Insurers Personal Information required to complete any applications for insurance that you make. Where permitted by law, we may use and/or disclose the information we have collected from your request for a quote or on your online application, for any purpose described in this Privacy Policy, even if you do not purchase the insurance or your application for insurance is declined.

To Whom We Disclose Your Personal Information
We do not sell or rent your Personal Information to anyone. Subject to the terms of this Privacy Policy, we may disclose your Personal Information within our company, to our Insurers, to third party service providers, and to other select unaffiliated entities. We make reasonable efforts to ensure that all co-venturers, third party service providers and select unaffiliated entities have privacy policies and security measures in place that conform to our high standards.

When we disclose Personal Information, we only provide as much Personal Information as is required to fulfill the purpose for which the Personal Information is being disclosed. In order to provide you with the services you have requested, your Personal Information may be processed and stored by us, within our company and its affiliates, by Insurers, by third party service providers or by select unaffiliated entities located outside the province in which the information was collected. However, before your Personal Information is transferred in this manner, we will take reasonable steps to ensure that your Personal Information will not be used for purposes other than those set out in this Privacy Policy, or communicated to third persons other than those contemplated in this Privacy Policy without your consent, except as provided by law.

Your Consent
By applying (even if your application is declined) or requesting an offline and/or online quote (even if your quote is not fully processed) for any product or service covered under this Privacy Policy, or by accepting, using, or continuing to hold any such product or service, you consent and agree to the collection, use and disclosure of your Personal Information in accordance with the terms of this Privacy Policy. Consent can be express or implied, depending on the circumstances. We will obtain your consent if we wish to use Personal Information that we or our Insurers have already collected in a manner that is not identified in this Privacy Policy, beyond what you would reasonably expect. For more information on refusing or withdrawing your consent, please see the section ‘Our opt-out policy’, below.

Our Opt-Out Policy
You have the option to refuse or withdraw your consent to the collection, use or disclosure of your Personal Information as follows:

You may choose not to provide certain Personal Information to us. Please understand that this may limit our ability to serve you, and may prevent us from providing certain services to you.

You may, with reasonable written notice, withdraw your consent to the collection, use or disclosure of your Personal Information, subject to any legal or contractual restrictions.

You may request, by reasonable written notice, that you not receive personalized direct marketing communications from us. However, due to printing and distribution schedules, you may continue to receive some communications that were in progress before we were able to process your request.

If you advise us in writing that you do not wish to receive any marketing communications from us, we will do our best to accommodate your request, within current industry standards and our technical capabilities. This will not limit information that we may send to you with your account statement, or discussions with any of our associates.

If you have previously sent a written request to us not to receive marketing communications from us, we will continue to honour that request. You may, with reasonable notice, request to opt-out from any disclosure to merchants of any changes to your account, including the account number, any card number or card expiry dates, and the status of your account.

If accommodating your request would limit or prevent us from providing you with a product or service you have requested, where possible, we will explain the implications of your request to you in order to help you make an informed decision.

You may contact us regarding your consent to the collection, use and disclosure of your Personal Information at the addresses shown in the ‘How to contact us’ section below or Contact Us.

Accessing Your Personal Information
Requests for disclosure of your Personal Information must be made in writing, by fax, email, or letter. Upon such request, we will provide you with reasonable access to your Personal Information that is in our possession. It is important to verify that the individual requesting information is in fact the person in question. For this reason we demand that all inquiries be in writing and that our responses, also in writing are sent to the address we have on file. We will also update and/or correct your Personal Information as required. It is your responsibility to provide updates on changes to your Personal Information.

If we are unable to provide you with access to your Personal Information, we will provide reasons for our inability to do so, unless we are prohibited from doing so by law.

How to Contact Us
If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Privacy Officer
Dion Insurance Program Management Inc.
1935 Silicone Drive
Pickering, ON L1W 3V7
Fax: 416-408-0974
Email: info@ipmgainsurance.com

If you are not satisfied with our response to a complaint regarding our compliance with this Privacy Policy or regarding any of our policies and practices with respect to the handling of Personal Information, you may contact the Federal Privacy Commissioner at 112 Kent Street, Ottawa, Ontario, K1A 1H3, 1-800-282-1376 or the provincial privacy commissioner of the province where the Personal Information was collected or is stored. More information, including contact information for the provincial privacy commissioners, can be obtained at the Federal Privacy Commissioner’s website, www.privcom.gc.ca