Privacy Policy

Last updated: July 2, 2020

Hugh Wood Canada Ltd. (“HWC”, “we”, “our”, “us”) is committed to gaining your trust and complying with our obligations under applicable privacy regulations, standards, and best practices. As insurance brokers, we need to collect your personal information in order to provide you with highest quality service. We developed this Privacy Policy (“Policy”) to provide you with transparency into our personal information handling practices, including how we collect, use and disclose your personal information. We may provide additional information about our personal information processing through agreements, notices, and consent forms.

Please review this Policy carefully and check it from time to time to inform yourself of any changes.

1. PERSONAL INFORMATION WE MAY COLLECT
Personal information is information that can directly or indirectly identify you. The personal information we may collect about you will vary depending on the service we provide you with. For example, we may collect the following personal information from you:
• Name, address, phone number, email address and other contact information
• Date of birth, marital status, dependants
• Vehicle identification number, driver’s license, license plate, driver’s record
• Business identification number, incorporation number
• Medical information including past medical history
• Information about your property including the value of the property and its content
• Information about previous insurance claims
• Employment information
• Credit history
• Credit card or other financial/bank information to process transactions
• IP address (if you visit our website) along with the resources on our website that you viewed
• Information you may voluntarily submit to us

2. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information about you in various ways including the following:
• Directly from you
• From insurance companies
• Financial institutions
• Credit bureau
• Ministry of transportation
• Experts (such as property valuators)
We may also collect personal information about you through the use of Cookies when you visit our website. Cookies will automatically collect information about your activity on our website, such as the pages you visit, the date and time of your visit, and the links that you click. We may also collect your IP address. For more information about Cookies and how you may disable them, please review the Cookies section below.

3. WHY WE NEED YOUR PERSONAL INFORMATION
We need to collect your personal information for the following reasons:

• To provide you with professional services or products (e.g. insurance policy)
For example, in order for us to acquire or renew an insurance policy for you, we require information that is requested by insurers and/or we need to evaluate which insurer to seek insurance policies from. We may also require information from you when you need to put a claim through with your insurer in order for us to investigate or adjust claims and arrange for settlement.

• To correspond with you
For example, we may need to contact you when we respond to your inquiry or to provide you with information about your policy. We may also contact you for marketing purposes such as to send you newsletters, to notify you of events, or changes to our services. We may also promote services or products of third parties such insurance companies or our partners.

• To improve our services
For example, we may obtain aggregated and anonymized information about the general use of visitors to our website which will allow us to gain insights and improve our services. We may also use your personal information to conduct market research.

• To comply with our legal requirements
For example, we may need information about you to comply with our legal obligations (e.g. tax purposes, reporting requirements), to verify your identity and to prevent unauthorized or illegal activity. We may also need your personal information to provide emergency assistance in situations that may threaten the life or physical safety of you or others.

4. WHO WE DISCLOSE YOUR PERSONAL INFORMATION TO
We may need to disclose your personal information to third parties. In doing so, we limit the personal information we disclose to them to only what is necessary and we limit the way in which they may use the personal information.

We may share your personal information with third parties, such as:

• Companies affiliated or associated with us, including HW International Group
• Insurance companies
• Ministry of Transportation, Credit Bureaus
• Professionals and experts such as lawyers or property valuators
• Financial institutions
• Payment processors
• Service providers to assist us in carrying out our services such as document management providers or cloud service providers
• Analytics and insights provider
• Law enforcement or government agencies when required to do so by law, regulation or judicial mandate, or when we exercise our legal rights or defend ourselves against a legal claim
• Entities which conduct their due diligence for the purposes of purchasing HWC or merging with HWC

Some of the third parties whom we disclose your personal information to may access, process or store your personal information outside of Canada and therefore the laws of the jurisdiction in which the third party accesses, processes or stores your personal information will apply. The laws of that jurisdiction may require your personal information to be disclosed to government, courts or law enforcement of that jurisdiction.

5. YOU HAVE CHOICES
We assume we have your consent (i.e. implied consent) to collect, use and disclose personal information for the services you requested from us. We may also ask you to sign a consent form so that we have explicit consent from you to collect, use and disclose personal information.
You may withdraw your consent at any time subject to legal or contractual restrictions. For example, you can unsubscribe to commercial emails from us, such as our newsletter.

Withdrawal of consent may result in restrictions in the services we can provide to you. For example, we may not be able to provide you with insurance policies or search in market for the best rate on your insurance. We will inform you how your withdrawal of consent will affect the service we provide to you.

If you have any questions about how to withdraw your consent, you can reach us by sending an email to privacy@hwcanada.com.

6. USE OF COOKIES
When you visit our website, our server may record your IP address through the use of Cookies.

Cookies are small text files that a website transfers to your hard drive to store or collect information about your usage of websites.

Although your IP address is not linked to your personal information, in some circumstances, it can reveal personal information. In general, when we use cookies, we collect information that cannot identify you, such as the type of device or internet browner you used to access our website, the time you visited our website and general location (e.g. city) you viewed our website in. We use this information to provide you with more effective services.

We may use some of the following types of cookies: (a) Strictly Necessary Cookies, which are required for our website to function, (b) Analytics Cookies, which provide us with analytics about website visitors and the way in which they interact with our website, and (c) Functionality Cookies, which recognize users when they return to the website and their username or preferences.

You can control the way in which cookies are used by altering your browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functionality of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our websites.

7. HOW WE PROTECT YOUR PERSONAL INFORMATION
HWC maintains appropriate technical, administrative and physical security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, and alteration. Despite this, the security of information transmitted via the Internet cannot always be guaranteed. We encourage you to take appropriate steps to enhance the security of your information.
We cannot guarantee that any of the links on our website are secure or how those websites may use your personal information. We encourage you to review their privacy policies.

8. ACCESS TO YOUR PERSONAL INFORMATION
You may seek access to the personal information we have about you by sending us a written request. In accordance with applicable law, we will provide you access within a reasonable time and with no cost or minimal cost. You may send your request by email us at privacy@hwcanada.com or by post mail:

Hugh Wood Canada Ltd.
4120 Yonge Street, Suite 201
Toronto, Ontario M2P 2B8
Attention: Privacy Officer

If you identify any inaccuracies or would like to update your personal information, you must notify us immediately. You are responsible for providing us with accurate information so we can update our records and notify third parties.

There may be some circumstances where we are unable to provide you with access to your personal information. For example, we cannot reveal records containing personal information of another individual or confidential information. We also might not be able to provide you with access to your personal information if it is protected by solicitor-client privilege or it is extremely impractical to do so. If we cannot provide you with access, we will let you know why we cannot do so.

If you wish to dispute our decision, you may bring your concern to the attention of the Office of the Privacy Commissioner of Canada of the Privacy Commissioner of your province or territory:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3
Toll-free: 1-800-282-1376
Fax: 819-994-5424
https://www.priv.gc.ca/en/

9. CHANGES TO THE PRIVACY POLICY

From time to time, we may change this Policy and post those changes to our website. The effective date of this Policy is listed at the top of the Policy and indicates the last time the Policy was revised or materially changed. We will notify you of changes to this Policy by posting the revised Policy on our website. We recommend that you revisit our Policy so that you are aware of our current information handling practices. We assume that you will review the Policy on occasion and continue to provide us consent unless you explicitly advise us otherwise.

10. QUESTIONS OR INQUIRIES
If you have any questions about this Policy or the way in which we collect, use or disclose your personal information, please contact us by email at privacy@hwcanada.com or post mail at:

High Wood Canada Ltd.
4120 Yonge Street, Suite 201
Toronto, Ontario M2P 2B8
Attention: Privacy Officer


When you visit this website, we may collect personal data. For more information, please read our Privacy Policy