BlueCircle Insurance and Individual Privacy

We at BlueCircle Insurance Brokers (referred to as, “we”, “our”, or “us”) abide by these Privacy Principles and want you, our applicants, policyholders, insureds, claimants, and any other individuals who provide us with personal information (referred to as “Customers” or “you”), to be aware of how and why we handle personal information. We work hard to respect and maintain your privacy. However, the very nature of our business is such that the collection, use, and disclosure of personal information are fundamental to the products and services we provide. As brokers, we deal in the delivery of insurance products and services and offer numerous products and services to many types of consumers and clients Alberta-wide.

For the purposes of these Privacy Principles, personal information means information that identifies an individual. For example, an individual’s name, birth date, address, age, health and, financial information is personal information which BlueCircle Insurance Ltd may collect, use and in certain circumstances, where necessary, disclose, in the course of providing insurance services and carrying on business. Personal information does not include the name, business title, address, phone or fax number of an employee of an organization.

1. Consent and Personal Information

BlueCircle Insurance Ltd obtains consent for the collection, use, and disclosure of personal information, except where prohibited by law. By applying for or purchasing BlueCircle Insurance Ltd products and services you are providing your consent to our collection, use, and disclosure of your personal information as set out in these Privacy Principles. BlueCircle Insurance Ltd relies on the broker’s advice where the insurance broker tells BlueCircle Insurance Ltd that we have a Customer’s consent to collect information.

Consent may be obtained by BlueCircle Insurance Ltd and its insurance companies directly or through the broker, an insurance adjuster, investigator, or lawyer when personal information is collected for claims purposes.

An individual may decline to consent, or revoke consent, to the collection and use of personal information for insurance purposes but in that case insurance products and related services and benefits and the assessment of applications, claims or complaints may be limited or terminated.

2. Collecting Personal Information

Whenever practical, we collect information directly from the individual concerned on applications for insurance both verbally and electronically or through the direct interactions with us. We also collect information from various third parties sources such as insurance brokers, adjusters, other insurance intermediaries, third party administrators, government, industry associations, personal trade shows and other entities that have information about you. For instance, we may obtain your driving record, claims history and/or credit history, where permitted by law, to assist us in underwriting your application for insurance.

3. Using Personal Information

Personal information is typically collected and used by us for insurance purposes such as: assessing risk, processing applications for insurance coverage, establishing rates, administering insurance products, investigating, and handling claims. BlueCircle Insurance Ltd also uses personal information to detect and prevent fraud, compile statistics, verify and provide information to insurance industry associations, report to regulatory or industry entities in accordance with laws and prudent insurance industry practices, and conduct market research. This may also include collecting and disclosing personal information about third parties with respect to claims made against BlueCircle Insurance Ltd Customers.

4. Use of Personal Information for Marketing Purposes

BlueCircle Insurance Ltd may collect and use personal information for marketing purposes, such as identifying and communicating with individuals who are most likely to find BlueCircle Insurance Ltd products and services of interest. BlueCircle Insurance Ltd may also disclose personal information to our affiliates to use for marketing purposes to offer you their products and services, which may be of interest to you. You may opt not to have us, or alternatively not to have our affiliates, collect, use or disclose personal information for marketing purposes, in which case we will collect, use and disclose personal information for insurance purposes and in accordance with our contractual rights and obligations, but we will not use or disclose personal information for marketing purposes. Offers of upgraded or additional coverage, special offers and, promotional mailings, and offers of additional products and services from our affiliates will not be sent by us.

5. Accuracy of Your Personal Information

BlueCircle Insurance Ltd maintains procedures to ensure that the information we collect and use is accurate, up-to-date, and as complete as possible. However, we rely on individuals to disclose all material information to us and to inform us of any changes required. These changes can be disclosed upon contact or communication from your broker.

6. Protecting Your Information

We apply appropriate safeguards to our computer networks and physical files and we restrict access to personal information to those BlueCircle Insurance Ltd employees, authorized administrators, reinsurers, consultants or insurance representatives who need to know that information in order to underwrite, adjudicate or administer insurance products and services.

7. Disclosure of Personal Information

Personal information is sought and exchanged with both affiliated and unaffiliated insurance companies, reinsurers, and insurance industry organizations at the time of assessing an application for insurance and any renewal, extension, variation or cancellation of any issued policy, as well as in the event of any claim, to the extent necessary for industry statistical purposes or to assess and rate a specific risk, determine the status of coverage, and investigate claims. We also share information to combat fraud; where permitted or required by law; or, at the request of government regulators.

BlueCircle Insurance Ltd sometimes retains an affiliated company or an independent third party or reinsurer (“authorized administrator”) to perform on our behalf, certain functions in support of the products and services we provide. Such functions could include the underwriting, offering or administering of BlueCircle Insurance Ltd products and services or any related claims. Accordingly, in certain instances, these affiliates or third parties will be provided with personal information to the extent that it is necessary for the performance of that specific reinsurance, underwriting, marketing, consulting, administrative, rehabilitative, claims, investigation or related services. Blue Circle Insurance Ltd obligates these affiliates and third parties to use and take steps to protect personal information in accordance with the requirements of these Privacy Principles.

BlueCircle Insurance Ltd may transfer your personal information as an asset in connection with any contemplated or actual sale, merger or another disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of personal information is subject to reasonable data protection security protocols.

We do not sell our customer lists or other personal information.

8. Storage and Access to Your Personal Information

We retain personal information for the purposes described in these Privacy Principles but only for so long as is necessary to fulfill the purpose of underwriting, adjudicating or administering insurance products and services and to meet our legal and contractual obligations. Personal information is stored at our office in Canada as required and defined under Disclosure of Personal Information above. Access to your personal information is limited to our employees, agents and service providers who need access in order to perform their job or provide services to us. Given the nature of insurance and our on-going exposure to potential claims, where necessary, and when legally required, some of the information we collect for insurance purposes is kept indefinitely.

9. Website Privacy Practices

We may collect other information through our website that does not reveal your specific identity. Other Information includes but is not limited to:

• browser information;
• information collected through cookies, pixel tags, and other technologies;
• demographic information and other similar information provided by you; and
• aggregated information.

We and our third-party service providers may collect information in a variety of ways, including the following:

• Through your internet browser
• Using cookies
• Disclosed information, from you.
• By aggregating information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as personal information under applicable law, then, in addition to the uses listed in this “Website Privacy Practices” section, we may use and disclose Other Information for all the purposes for which we use and disclose personal information.

10. Third Party Websites

These Privacy Principles do not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website to which our website contains a link. The inclusion of a link on our website does not imply endorsement of the linked site by us or by our group companies.

11. Changes to these Privacy Principles

BlueCircle Insurance Ltd reserves the right to modify these Privacy Principles from time to time. If these Privacy Principles change materially, we will take reasonable measures to notify you, including posting a copy of the revised Privacy Principles to our website. Accordingly, we recommend that you review our Privacy Principles from time to time.