FIRST Canada, its subsidiaries, and all service providers collecting, using, or disclosing personal information on its behalf are committed to protecting the personal information of its customers. This commitment includes ensuring the accuracy, confidentiality, and security of our customers’ personal information and allowing our customers to request access to, and correction of, their personal information.
This Privacy Policy is intended to comply with all statutory obligations in the provinces and territories in which FIRST Canada operates and under Canadian law, and sets out the principles and practices FIRST Canada will follow in protecting customers’ personal information.
What We Collect & Why
FIRST Canada will only collect personal information, which is information about an identifiable individual that can be used to identify, locate, or contact an individual, alone or when combined with other personal or identifying information, necessary to fulfill our business purpose.
FIRST Canada, for quality control and training purposes, may record telephone conversations between clients and customer representatives. At all times, the client will be advised of the possibility of recording prior to the conversation taking place.
Consent & Withdrawing Consent
FIRST Canada will obtain consent to collect, use, and/ or disclose personal information, except in situations permitted by law. Each purpose for which the personal information is being collected and that this information may be transmitted/communicated to another jurisdiction will be communicated before or at the time of collection and additional consent will be requested for each new purpose.
A client may withhold or withdraw their consent, except in circumstances where the information is necessary to provide or continue to provide the service or product, or where withdrawal of consent would frustrate the performance of a legal obligation. Withholding or withdrawing consent will not result in a denial of a particular product or service, but it may restrict FIRST Canada’s ability to provide the product or service at the same level. All consequences of withholding or withdrawing consent will be present at the time the client is making their decision.
As it pertains to marketing material, FIRST Canada will abide by all federal and provincial/territorial legislation when obtaining consent, whether expressed or implied. All clients may unsubscribe to email communications from FRIST Canada, outside of account related alerts, notifications that are legally required, and replies to specific requests.
Use & Disclosure of Personal Information
FIRST Canada will only use, collect, and/or disclose our clients personal information where:
FIRST Canada will not disclose our client’s personal information for any additional purpose without obtaining consent prior to doing so.
Retention
FIRST Canada will retain customer information only for as long as is necessary to fulfill the purpose for which it was collected and/or a specified legal purpose. If the information was used to make a decision directly affecting the client, it will be retained for at least one year.
FIRST Canada, or its vendors, may transmit through, store, or process client personal information in a jurisdiction outside of Canada. When this happens, FIRST Canada will endeavor to provide the same level of privacy and protection as would be expected had the information remained in Canada, through the use of appropriate contract clauses, privacy impact assessments (PIAs), and other applicable safeguards, but the laws of the country in which the information is transmitted through, stored, or processed will rule.
Access & Accuracy
All clients of FIRST Canada, or their authorized representative, have the right to request access to the information kept on them and to know how it is being used and to whom it is being disclosed. This information will be made available within thirty (30) business days, though FIRST Canada reserves the right to refuse any request, such refusal will be presented in writing, or where limited by exceptions prescribed by law.
All clients of FIRST Canada, or their authorized representative, have the right to ask for the correction of information kept on them. Any request for correction must be made to FIRST Canada’s Privacy Officer, Brian Day (privacy@firstinsurancefunding.ca), in writing providing sufficient detail to identify the personal information being sought. These requests may be processed at a nominal cost to the client.
Safeguards
FIRST Canada will take all reasonable and appropriate measures to secure our client’s personal information and will likewise use appropriate security measures when destroying client personal information.
FIRST Canada will conduct thorough and comprehensive PIAs where applicable and where required to by law.
Digital/ Technological Privacy
FIRST Canada will collect technical information, which is automatically sent by a client’s computer when they visit one of FIRST Canada’s websites; device information, about the device the client is using; and cookies, tiny files that are downloaded to an individual’s computer to improve their experience.
The cookies that FIRST Canada will collect are required, performance, and personalized/functionality. Only required cookies cannot be disabled, but disabling the others may affect the functionality of FIRST Canada websites.
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