DAUMIER FINANCIAL SERVICES INC.

PRIVACY POLICY

Collecting personal information about you is essential to our ability to assist in reviewing and advising you of current and future insurance needs with recommendations on high-quality insurance products.  We work to ensure that your personal information we collect is accurate, confidential and secure. 

In this Privacy Policy, you and your mean any individual whose personal information we collect, use and disclose as described in this Policy (including users of this website; referred to this this Policy as our Website) and we, us and our mean Daumier Financial Services Inc. 

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information.  If you do not agree with these, your choice is not to use our Website.  By accessing or using our Website, you indicate that you understand, accept, and consent to the practices described in this Policy.  This Policy may change from time to time (see Changes to Our Privacy Policy), and your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check this page periodically for Policy updates. 

Our privacy principles

This Policy is based upon the following principles. 

Principle 1 – Accountability

Each member of our team is responsible for personal information under their control.

Principle 2 – Identifying purposes

We identify the purpose for which we collect personal information before or at the time the information is collected.

Principle 3 – Consent

We require your prior knowledge and permission before we collect, use or disclose your personal information, except for legal or security reasons.

Principle 4 – Limiting collection

We only collect personal information by lawful means, and limit the personal information we collect to what is necessary for identified purposes.

Principle 5 – Limiting use, disclosure and retention

We will not use, disclose or retain personal information for purposes other than those for which it was collected, other than with your permission or as permitted or required by law.

Principle 6 – Accuracy

Personal information must be as accurate, complete and current as is necessary for the identified purposes for which it is used.

Principle 7 – Safeguarding information

We will protect personal information by safeguards appropriate to its sensitivity.

Principle 8 – Openness

We will make available to you policies and procedures relating to the management of your personal information.

Principle 9 – Individual access

Upon request, you will be informed of the existence, use and disclosure of your personal information and be given access to it.  You may challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Handling customer complaints and suggestions

You may address any complaint regarding compliance with these principles to:

412 – 3621 Highway 7 

Markham, ON 

L3R 0G6

Attention: Chief Privacy Officer

Email: privacy@daumier.ca

Your rights

You have the following rights concerning your privacy:

• the right to know why we collect, use or disclose your personal information,
• the right to know how we will ensure the protection of your information,
• the right to expect us to protect your information from unauthorized disclosure,
• the right to inspect the information we hold about you and make sure it is accurate, complete and current,
• the right to expect us to destroy your information that is not required to be retained by us when requested, and
• the right to withdraw your consent at any time by contacting our office in writing.

What is personal information?

Personal information is information that can reasonably be used to identify you directly or indirectly, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, social insurance number, and any other identifier we may use to contact you.

We also collect non-personal information, including technical information, such as your login information, browser type and version, and non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from this Website (including date and time), or products you viewed or searched for.

How we collect, use, and disclose your personal information

• How we collect

We may collect information about you in writing, electronically or verbally.  These methods include: 

• Information you provide or is collected through this Website:
  • on this Website, and in email, text, and other electronic messages between you and this Website, including by filling in forms on this Website. This includes information you provide: 
    • at the time of registering to use this Website, subscribing to our service, posting material, or requesting further services, 
    • when you report a problem with our Website, 
  • when you interact with our advertising on third-party websites and services, if that advertising includes links to our Website or this Policy, 
  • by any third party (including our affiliates), through any application or content (including advertising) that may link to or be accessible from or on this Website, and
  • through automated technologies or interactions, including cookies (please see ‘Automated Technologies and Interactions’ below).

This Website 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 plug-in, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies.  We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.  (Please also see ‘Third Party Use of Cookies and Other Tracking Technologies’ below.)

• Information you provide by filling in forms or corresponding with us by phone or email, including records and copies of your correspondence (including email addresses)

• If we collect your information by telephone, the call may be recorded for monitoring, quality improvement and training purposes, or to create a record of your information and your instructions.

• Information collected through cookies, web beacons, and other tracking technologies, and 

• Publicly available sources.

We may also collect information about you from other sources with your authorization and consent, such as insurers, your accountant, lawyer, doctor or medical facility, or our business partners.

We will obtain your permission

We collect, use or disclose your personal information with your permission for the purpose identified, or as allowed or required under the law.

Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative.

You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice.  However, without your permission, we may not be able to provide you with the recommended products or services you requested.

Before we make information available to third parties, other than an agent, reinsurer or service provider who needs it to conduct tasks on our behalf, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we need to share with them and why.

Automated technologies or interactions

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website, and 

• information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies).  A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to this Website.
• Flash Cookies.  Certain features of this Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on this Website.  Flash cookies are not managed by the same browser settings that are used for browser cookies.  For information about managing your privacy and security settings for Flash cookies, see ‘Choices About How We Use and Disclose Your Information’ below.
• Web Beacons.  Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity. 

Third-party use of cookies and other tracking technologies

Some content or applications on this Website, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use this Website.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.  In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support this Website so that you may enjoy free content.

You may opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada.  Opting out of a network does not mean you will no longer receive online advertising.  It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.  For more information about how you can opt out of receiving targeted advertising from many providers, see ‘Choices About How We Use and Disclose Your Information’.

• We ask you for only the information we need

We only collect the information about you that we need, such as financial, health, lifestyle and contact information, from you and other persons for the purpose identified to you.

Our files containing information about you are kept for the purpose of providing and servicing financial and insurance products and services that we believe are right for you, over your lifetime.

We will not sell your personal information. 

Why we need the information

Generally, we need to collect personal information to:

• understand your needs, the suitability of recommended products and services, and assess future needs through customer surveys, market research and analysis,
• determine your eligibility,
• provide you with information, products, or services that you request from us, whether directly or indirectly through our agents, brokers, representatives, independent contractors, or service providers,
• continue to offer you and administer the full range of products that you have with us, in accordance with legal requirements,
• fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it,
• identify you and implement risk management programs and procedures to protect against fraud, errors or misrepresentations,
• meet regulatory and contractual requirements,
• present this Website and its contents to you,
• notify you about changes to this Website or any products or services we offer or provide though it,
• improve this Website, products or services, marketing, or customer relationships and experiences,
• allow you to participate in interactive features, social media, or similar features on this Website, and
• measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve this Website and to deliver a better and more personalized service, including by enabling us to:

• estimate our audience size and usage patterns,
• store information about your preferences, allowing us to customize this Website according to your individual interests understand your needs, the suitability of recommended products and services, and assess future needs through customer surveys, market research and analysis,
• speed up your searches, and
• recognize you when you return to this Website.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you may opt out of behavioural tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

We provide an opportunity for any user to unsubscribe from our e-mails or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing privacy@daumier.ca.

• We will limit how long we keep information

We will keep your personal information only as long as legally or operationally necessary.  However, we reserve the right to use anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

How we protect your personal information

We are responsible for your information

We are responsible for all personal information in our possession.  Sometimes, unless we are otherwise prohibited, our employees, advisors and third-party service providers may be located outside Canada, and your personal information may be subject to the laws of those countries.  All of these persons, whether or not they are located in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy and practices.

How we protect information

Access to your personal information is restricted to our affiliates, and to our employees, agents and third-party service providers who need it to do their jobs.  We may also disclose aggregate data to advertisers to permit them to target specific users and, in accordance with applicable law:

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and users is among the assets transferred.
• to comply with any court order, law, or legal process, including to respond to any government or regulatory request,
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 

We have developed and continue to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification.  We and our third-party service providers maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.  While we endeavour to protect all information, the most sensitive information, such as medical information, receives the highest level of protection.

Where we store your personal information

Physical copies of your personal information are stored in our offices in Canada.  However, we sometimes use service providers outside Canada to collect, use, disclose and/or store personal information.  The countries where these services may be provided include the United States.

Please note that foreign countries have different privacy laws that may or may not be as comprehensive as Canadian law.  In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country.  Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation and that they do not use the information for purposes not relevant to the reason of the collection of the information.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your information: 

Tracking Technologies and Advertising.  You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.  If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.  For more information about tracking technologies, see ‘Automated technologies and interactions’ above.

Third-Party Advertising.  If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you may opt-out by sending us an email stating your request to privacy@daumier.ca.

Promotional Offers.  If you have opted in to receive certain emails from us but no longer wish to have your email address or contact information used by us to promote our own or third parties’ products or services, you may opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to privacy@daumier.ca.  If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.

Targeted Advertising.  If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you may opt out by checking the relevant box located on the form on which we collect your data (if any) or at any other time by sending us an email stating your request to privacy@daumier.ca.

Your right to access your personal information

Your rights

You have the right to ask in writing whether we hold any personal information about you, to see that information, and how we collect, use or disclose it.  We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for any copy of personal information requested.  Where we have obtained medical information about you from a third party, we will release this information only through your physician.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.  Examples of these exceptions include:

• information protected by solicitor-client privilege,
• information that is part of a formal dispute resolution process,
• information that is about another individual that would reveal their personal information or confidential commercial information, and
• information that is prohibitively expensive to provide.

How to request an update or correction

If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it, or you may contact us to update your personal information in our records.  We will make the necessary changes as appropriate.

Withdrawing your consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent for the use or disclosure of your personal data subject to certain contractual and legal obligations. To withdraw your consent, contact privacy@daumier.ca.  Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service.  We will explain this to you at the time to help you make your decision.

CHANGES TO OUR PRIVACY POLICY

We may update this Policy from time to time.  We will post any changes we make on this page.  If we make material changes to how we treat our users’ personal information, we will post the new Policy on this page with a notice that the Policy has been updated.

We include the date the Policy was last revised at the bottom of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this Policy to check for any changes.

COMPLAINTS, QUESTIONS AND MORE INFORMATION 

If you have a privacy-related complaint or question or would like more information, please contact us as set out above.

Last modified: August 2023