Why do we have this notice?
At PHI Direct*, we know the importance of respecting your privacy and maintaining your trust. It is important to us that you understand the purposes for which we collect your personal information (as defined below) and how that personal information is used, protected, stored and disclosed. And, of course, we need to comply with any laws that require us to share with you how we manage this information.
What information do we collect?
If you are a customer of ours, we collect two types of information from you: personal information and non-personal information.
Personal information is any information about you as an identifiable individual, including information that, together with other available information, could be used to identify you (“Personal Information”). Non-personal information is any information that is not about you as an identifiable individual, including aggregated statistical information and information that has been anonymized such that it cannot be associated with an identifiable person.
The types and scope of the information we may collect, and the purposes for which we may use it, will depend on the nature of your interactions with us. As an applicant for insurance, or an ongoing customer, we will need to collect certain information from you to assess insurability, manage your account and otherwise operate our business. If you are not a customer of ours, we may still collect information from you, although the collection is more limited. For example, we automatically collect certain information when a user visits our website.
|A. Personal Information||Name; address; telephone number; email address; pet name; age; breed; pet health information and visual images; IP address; signatures; bank account, credit or debit card numbers; and information regarding your dealings with us, including policy information, claims history, premiums and payment information.|
|B. Website Data||Browsing history, search history, date and time you access our Website, the sections of the website you visit|
|C. Non-Personal Information||Aggregated, de-identified data for statistical and research purposes, such as the number of pets insured within a town or city.|
You may choose not to provide us with your Personal Information. However, if you make this choice we may not be able to provide you with a quote, an insurance policy for your pet, or any additional information that you requested. For example, we require your postal code and your email in order to provide you with a policy quote.
How do we collect this Personal Information?
We collect your Personal Information, for example, when you:
- Apply for insurance, pay premiums, or make changes to your policy
- File a claim
- Correspond or interact with us in person, by mail, through our website or mobile app
- Fill out customer surveys
- Participate in a contest or a promotion
- Sign up for marketing communications
- Request a quote from our website or speaking with our Sales Agents or Customer Support Agents
- Visit our website
We also collect Personal Information from others, such as vet hospitals, affiliates, joint marketing partners or lead generators such as social media influencers and review sites, and other third parties and strategic partners through whom we offer insurance products and services.
What other type of information may we collect from you?
Listed here are some further examples of the ways that we collect Personal Information from you and how we use it.
Our Website uses “cookies,” a technology that installs a small amount of information on a Website user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to offer personalized Webpage content and information for your use, to track your activity at the Website, to respond to your needs, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website or engage in transactions through the Website.
(b) Links to Other websites
Our Website may contain links to other websites or Internet resources that are provided solely for your convenience and information. When you click on one of those links, you are contacting another website or Internet resource any reliance you place on the information from those sites is strictly at your own risk. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your Personal Information. We encourage you to read the privacy policies
of those other websites to learn how they collect and use your Personal Information.
(c) Website Tracking Information
We may use web beacons or pixel tags to compile tracking information reports regarding Website user demographics, Website traffic patterns, and Website purchases. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes we may link tracking information with personal information voluntarily provided by Website users. Once such a link is made, all of the linked information is treated as personal information
How do we use your Personal Information?
We collect, use and disclose Personal Information to operate our businesses and to administer our insurance policies, including for the following purposes (the “Identified Purposes”):
- to communicate with customers regarding policies or any concerns or queries the customer may have;
- to determine your eligibility for, offer and/or provide you with the insurance products and services you request;
- to determine prices, fees and premiums
including by evaluating your coverage needs and assessing risk;
- to collect fees and premiums;
- to maintain, administer, collect, service and renew your policies and assess your ongoing needs;
- to investigate, evaluate and pay claims;
- to communicate with customers regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other offers and services that may be of interest to you or that you may request;
- to understand and analyze the interests, needs and preferences of customers;
- to develop, enhance, market and/or provide products and services to customers and
- to verify customers’ identity;
- to reduce fraud or errors in transaction processing;
- to comply, or in accordance with applicable laws and regulatory requirements, or as requested by governments and regulatory authorities;
- in connection with pending litigation;
- to evaluate or conduct an acquisition, restructure, divestment or other transaction;
- to detect or prevent criminal activity, fraud, material misrepresentation or material non-disclosure in connection with an insurance transaction;
- to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
- to compile statistics and conduct market research;
- to conduct actuarial or business analysis, or to conduct an audit of our operations;
- to carry out our obligations and enforce our rights arising from insurance policies issued by us;
- to provide training, development and security, for example the recording or live monitoring of calls.
- to improve our website and the content and features available to you, including to debug and to identify and repair errors that impair existing intended functionality on the PHI Direct Website; and
- for investigation and law enforcement purposes.
We do not collect Personal Information other than for the Identified Purposes unless further consent is obtained, or where otherwise required or permitted by law.
How might we disclose your Personal Information?
We do not sell your Personal Information to anyone, for any reason.
From time to time, we may share your Personal Information with third party service providers that we have engaged to perform services on our behalf, based on our instructions, such as advertising agencies, marketing agents, data processing and storage companies, and payment processors or organizations which provide professional, administrative, underwriting and support services to us. We may also share your Personal Information with third parties which assist in the administration of your policy including veterinarian hospitals, breeders, shelters, and worksite benefits providers through whom we provide insurance services. We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged or which is reasonably necessary for us to satisfy regulatory obligations to our third party business partners.
We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide us with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at ConsumerPrivacy@phidirect.com.
In some circumstances, we may also disclose your Personal Information to third parties as required or permitted by law, such as:
- to government bodies, insurance regulatory bodies and law enforcement agencies, pursuant to warrant, court order or statutory requirement;
- in connection with any legal proceedings or prospective legal proceedings involving us;
- to otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk), as permitted by law.
Your Personal information may be processed in a foreign country and it may be accessible to law enforcement and national security authorities of that jurisdiction.
How do we protect your Personal Information?
We use a number of security measures designed to protect your Personal Information from unauthorized access and use. These measures include computer safeguards and secured files and buildings. The security of your Personal Information is a high priority for us. We maintain a range of safeguards to protect your Personal Information, whether recorded on paper or captured electronically, against unauthorized access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; we employ technological tools like firewalls and passwords; and we ensure our employees are trained annually on the importance of maintaining and protecting the security and confidentiality of Personal Information. Secure methods are also used whenever we destroy Personal Information.
Although we have physical, electronic and procedural safeguards that we believe are adequate to protect Personal Information that is captured electronically and stored online, any such systems may be subject to human and operational error. Moreover, because the internet is an open system, we cannot and do not guarantee that Personal Information entered by you online will not be misappropriated, intercepted, modified, deleted or used by others.
We will keep your Personal Information as accurate, complete and up-to-date as is necessary for the Identified Purposes. Should you feel that any of your Personal Information that we retain is inaccurate, you may request that it be corrected or augmented, by contacting us at the address or phone number listed below. If your Personal Information changes, it is your obligation to inform us as soon as possible.
Can I review or correct my Personal Information?
You have the right to review and, if necessary, correct your Personal Information held by us. If you wish to review your recorded Personal Information, please email us at ConsumerPrivacy@phidirect.com. Please include your name, address, telephone number, and policy number, and let us know what kind of information you want to see. If you see any mistakes, please let us know and we will review it. If we agree, we will correct our files. If we disagree, you may file a short statement of dispute with us. Your statement will be included with any data we disclose in the future.
We will respond to written requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible.
We rely on the following actions by you as indications of your consent to our existing and future use of your Personal Information for Identified Purposes, until you notify us of a withdrawal of your consent:
- Your voluntary provision of Personal Information directly to us or through an insurance representative for the purpose of acquiring an insurance contract or related service or product (including information previously provided to us);
- Your express consent or acknowledgement contained, for example, within a written, verbal or electronic application process;
- Your consent solicited by us (or our agent) for a specified purpose; or
- Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
In the event you request changes, endorsements, or renewals to your policy, the original consent provided directly to us, or indirectly through a third party, will remain in effect.
Withdrawing your consent
You may withdraw your consent to the collection, use or disclosure of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice. However, without your consent we may not be able to provide you with or continue to provide you with insurance coverage or other requested products, services or information. We will inform you of any consequences of withdrawing your consent.
With your consent, or as otherwise permitted by law, we may send you electronic marketing communications. We will always provide you with the opportunity to “opt-out’ or unsubscribe. For example, if you receive these types of emails from us, we will provide a link in the email that you can use to unsubscribe.
For how long is my Personal Information retained?
We keep your Personal Information only as long as is necessary for the Identified Purposes and to meet any legal or reasonable contractual requirements, in compliance with applicable law. We have retention standards that meet these parameters.
Please note that we are required by law to retain certain records and personal information for a prescribed period of time, such as policy records and the information contained therein. We are also permitted by law to retain other types of records and personal information for an appropriate period of time, such as to prevent fraud or undue risk.
*In this Policy, “customer”, “you” or “your” includes any individual who has requested, applied for or been supplied with, products or services (including claims services) by us including any other individual for whom the customer has acted as agent, guardian or representative. “We”, “our” or “us” means Canada Pet Health Insurance Services, Inc., and Aquarium Software Ltd. and share common ownership.
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