Our Privacy Pledge to You
Combined Insurance Company of America
Your Privacy is Important to Us
Canada's national
privacy legislation, the Personal Information Protection and
Electronic Documents Act came into force on January 1, 2001.
Since January 1, 2004, this privacy legislation applies to all
businesses that collect, use or disclose Personal Information.
Personal Information means information about you that can be used to
identify you. Depending on the province you live in, you may have
rights under similar provincial laws.
At Combined Insurance Company of America, we pledge to protect
your privacy and safeguard your personal information. As part of our
pledge, we have established 10 Privacy Principles to govern our
actions in collecting, using and disclosing our customers' Personal
Information. The 10 Privacy Principles build upon earlier work by
the Canadian Standards Association's Model Code for the Protection
of Personal Information and the national privacy law.
Combined Insurance Company of America's 10 Privacy
Principles
Principle 1 - Accountability
Combined accepts
responsibility for maintaining and protecting Personal Information
under its control. To meet this responsibility, Combined has
appointed a Privacy Officer to ensure we meet the 10
Privacy Principles.
Principle 2 - Identifying Purposes
We will identify
the purposes for which we collect Personal Information from
customers before or as we collect the information.
Principle 3 - Consent
We ask for your consent to
collect, use or disclose Personal Information except where
required or permitted by law.
Principle 4 - Limiting Collection
We do not collect
Personal Information from customers other than the information
necessary for the purposes we identified.
Principle 5 - Limiting Use, Disclosure and
Retention
We will only use or disclose your Personal
Information for the purpose for which it was collected, unless you
otherwise consent, or if it is required or permitted by law. We
keep your Personal Information only for as long as we need to
fulfill the purposes for which it was collected.
Principle 6 - Accuracy
We keep your Personal
Information in as accurate, complete and up-to-date form as is
needed to fulfill the purposes for which we use it.
Principle 7 - Safeguarding Information
We protect
your Personal Information against loss or theft and safeguard it
from unauthorized access.
Principle 8 - Openness
Combined will make information
on the management and handling of customers' Personal Information
available to customers. This Policy is part of that
commitment.
Principle 9 - Customer Access
If you ask us, we shall
tell you whether we have your Personal Information and how we use
it. We shall also give you reasonable access to the information.
If you can show it is inaccurate or incomplete, you will have the
opportunity to correct or amend your Personal Information .
Principle 10 - Customer Complaints and
Suggestions
Customers may direct any questions or inquiries
about our privacy practices to Combined's Privacy
Officer.
The following describes our Personal Information privacy
practices and explains how we collect, use and disclose your
Personal Information.
Kinds of Personal Information We Collect
At Combined,
we collect and maintain information that refers specifically to you.
The types of Personal Information we collect and maintain may
include your:
Name
Mailing Address
E-mail Address
Personal and Business Telephone Numbers
Social Insurance
Number
Date of Birth
Names and Ages of Spouse and
Children
Beneficiary Information
Occupation
Employer
Annual Income
Other General Financial
Information
Health Information
Other Insurance
Coverage
How We Use Your Personal Information
You can trust that
your Personal Information is collected and shared only as is
necessary to provide you with the very best support, service and
product options. We will only collect and use information about you
for the following purposes:
- To understand your product and service needs.
- To ensure that our products and services meet your needs.
- To determine eligibility for our products or services.
- To meet your ongoing service and product needs.
- To administer products and services (investigate and
adjudicate claims, generate billing statements, change coverages,
etc.).
- For internal, external and regulatory audit purposes.
- To fulfill our legal and regulatory responsibilities.
We will obtain your consent before using your Personal
Information for any other purpose.
Where We Get Your Personal Information
We get most of
our information directly from you. Usually, the insurance
application and other standard industry forms give us the
information we need. We may also get information about you from
telephone calls with you, or from letters, e-mail and other
correspondence we have with you.
But sometimes, more information is necessary. For example, we may
ask your doctor for more details about your medical history. We may
also verify or obtain more information about you from a credit
bureau.
Who Has Access to Your Information
We employ physical,
electronic and procedural safeguards to protect your Personal
Information. In addition, we restrict access to your Personal
Information to those employees and agents who use your Personal
Information to deal with the purposes to which you consented. For
example, an Underwriter would need access to your Personal
Information to evaluate your application; a Claims Adjuster to
settle your claim; or a Representative to answer your questions and
offer you other types of coverage that may interest you.
Generally, Combined will not collect or disclose your Personal
Information without your consent, unless required or permitted by
law. Sometimes, we must disclose information about you to an
insurance regulatory authority, a government agency, a law
enforcement agency or, if a court orders us to, to another third
party.
We may also share your Personal Information with other
businesses not officially connected to Combined, but who work for us
to provide our products or services. They will protect any Personal
Information given to them, at the same level as we do.
Various industry and professional organizations may also ask us
for aggregated customer information in order to conduct research
studies. These studies assess conditions or trends in the market and
never identify individuals.
We will not obtain additional consent before providing your
Personal Information in any of these circumstances. But, if we do
provide your information to any party outside of Combined, we will
record each time that a disclosure is made, including the relevant
facts disclosed. As far as possible, we will require anyone who
receives your Personal Information to meet the same privacy
standards we do.
Accuracy of Your Personal Information
We will try to
keep your Personal Information accurate, up-to-date and complete.
However, circumstances may require a change to your information. If
you need to update or correct your Personal Information that we have
on file, simply contact us at the telephone number provided at the
end of this page.
Access To Your Personal Information
To access and
verify any of your Personal Information, simply call us at
1-888-234-4466. In most cases, your Personal Information will be
provided promptly upon request and free of charge. We will provide
in-depth Personal Information, which requires work for us to
assemble, within 30 days of your request. We may charge you for the
cost of providing such information.
Withdrawal of Consent
To withdraw your consent at any
time, simply call us at 1-888-234-4466. You can refuse to consent to
our collection, use or disclosure of your Personal Information. You
can withdraw your consent to our continued collection, use or
disclosure. We may require you to complete a form documenting your
request.
Refusing or withdrawing consent is subject to applicable legal
and contractual requirements. Withdrawing consent does not apply to
Personal Information used in policy issuance or renewal, insurance
underwriting or claims administration of your current policies. It
may also may affect our ability to provide services to you. Federal
and provincial laws may require us to collect and report Personal
Information to government agencies and we will continue to do so.
If You Have Questions or Concerns
We hope this "Privacy
Pledge to You" reassures you that Combined is committed to
protecting your privacy and safeguarding your Personal
Information.
If you have any questions about our privacy
policies and practices, please call us toll free at:
1-888-234-4466
If you do not wish to be made aware of new Combined programs and
services, please write to us at:
Combined Insurance Company of America
Attention: Privacy
Officer
300-7300 Warden Avenue
Markham, Ontario L3R 0X3
Combined Insurance... Sensible Solutions for a Secure
Tomorrow
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