HL Hamilton Insurance: Privacy Notice
Last updated: February 21, 2023
HL Hamilton Insurance Ltd. (“HL Hamilton”, “we”, “us”, our“) is committed to protecting the privacy of its customers, (including prospective customers), visitors to its website hlhamilton.com (the “Site”) and applicants for employment with HL Hamilton. HL Hamilton makes every effort to ensure that these individuals understand the nature, purposes and consequences of the collection, use, and disclosure of their personal information, which we explain in this Privacy Notice.
For the purposes of this Privacy Notice, “personal information” means any information that can reasonably be used, either alone or in combination with other information, to identify you.
1. When does this Privacy Notice apply?
This Privacy Notice explains how we collect, use, and disclose your personal information anytime you communicate or interact with us or our employees. This includes when you inquire about or purchase our services or products that we offer, when you visit the Site website hlhamilton.com (the “Site”), or when subscribe to our newsletter or register for a webinar via one of our social media accounts. This Privacy Notice also explains how we collect, use and disclose your personal information when you apply for employment with us.
2. What personal information does HL Hamilton Insurance collect and how does it collect it?
We may collect personal information directly from you when you inquire about or purchase our services or products that we offer. Depending on the type of product or service that you are inquiring about or purchasing, we may collect the following information:
Information establishing your identity (such as your name, address, email address, phone number, date of birth, gender, Social Insurance Number (“SIN”) and copies of government-issued documents);
Information about your financial status, including your annual income, the value of your assets (such as your investments, or assets that you seek to insure such as your home, cottage, vehicle, RV, or horse) and liabilities;
Information about your family, including spouse, children, and dependents;
Information about your vehicle, including make, model, proof of vehicle ownership and VIN#;
Information about your occupation, including your employer;
Information related to your estate or financial planning, including your financial goals, plans for retirement, and identities of your designated beneficiaries and heirs;
Information about your health, including and medical conditions or diseases affecting you, lifestyle habits that may affect your health, medications that you take, or any allergies that you may have;
Information about your travel history; and
Information about your driving or criminal record, including history of any insurance claims.
There are many reasons why we ask for your SIN. As described below in Section 3 of this Privacy Notice, ‘Why does HL Hamilton collect my personal information?’, your SIN is required by law for tax-reporting requirements. With your consent, we use your SIN as a unique identifier to keep your information separate from other customers and people with similar names. For example, if we need to verify your credit history, we use your SIN to confirm that the credit information we ask for and receive is about you and not someone with the same or similar name. You can request that we not use your SIN unless we are required to by law.
In the case of individuals applying for employment with us, me may collect:
Information about your education, employment and educational history, and qualifications, such as the contents of your resume or CV; and
The result of criminal record or background checks.
If you send us an email, phone us or use the live chat feature on the Site, we may collect personal information you provide to us during those communications, such as the content of your comments, complaints, feedback or inquiries. When we do so, we may record your information in order to:
Establish a record of the information you provide
Take or verify instructions from you
Confirm your identity
Maintain quality service levels
Help with staff training
If you don’t want your calls recorded, you can communicate with us in writing instead.
If you attend one of our physical offices, we may collect personal information about whether you have been fully vaccinated against COVID-19.
We may also collect personal information about you from third parties, including:
Information about the insurance and claims history of you and other drivers you seek to include under one of our automobile insurance policies, going back up to 25 years. We collect this information from credit bureaus, the Ministry of Transportation in your province or territory or residence, other insurers and insurance rating service providers.
We may automatically collect certain technical information from any device that you use to access the Site or interact with us online. This includes:
Your device information, including IP address, device model & manufacturer, web browser type and version, hardware model, time zone setting, browser plug-in types and versions, and operating system version, as well as your internet service provider.
Information about how you use the Site, including the uniform resource locators (“URLs”) of other websites that you click to and from our Site (including the date and time clicked), page response times, download errors, length of visits to certain pages on the Site, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the Site;
Information related to emails that we send you, including the types of emails we send that you open and click; and
Information about our product webinars and seminars, including your registration and attendance at such webinars.
We may collect some of the above technical information using cookies or similar technologies. See Cookies & Other Technologies below for more detail on how we collect and use this information.
3. Why does HL Hamilton collect my personal information?
We may use your personal information to:
Assess your application and provide you with quotes for services and products that we offer;
Determine your eligibility for insurance coverage;
Process payments for the products and services, and in some cases, complete transactions for the products and services;
Provide you with our services and products that we offer, including to help you decide which products and services to purchase and determine your financial and retirement goals;
Investigate insurance claims submitted by you
Protect you and us from errors, misrepresentations, fraud, and/or contravention of laws or criminal activity (including facilitating insurance fraud detection and prevention);
Develop and enhance our services through data analysis;
Maintain our customer service records;
Respond to your requests, complaints, comments and questions; comments or requests for information, and correspond with you generally;
Consider if there are other products or services you might be interested in, if you are eligible for those products or services, and sending you details about them;
Provide you with relevant information, send you promotional communications or otherwise market our products to you;
Satisfy any audit, insurance, self-regulatory or regulatory requirements applicable to us (including, know-your-client requirements, provincial and federal tax reporting, anti-money laundering, unclaimed property obligations and audits by our carrier partners);
Maintain the health and safety of our personnel;
Enforce our legal rights with respect to any agreement you may have with us, including to collect a debt or enforce an obligation owed to us by you;
Better understand how visitors interact with our Site, and improve the Site; and
Detect and prevent security threats to the Site.
In the case of individuals applying for employment, we use your personal information to assess your application, decide whether to offer you employment and contact you about your application.
We may use your personal information for marketing purposes, including to educate current and potential customers about our products, identify customers who may be interested in purchasing our products and reach out to them. If you do not want your personal information to be used for marketing purposes, you can withdraw your consent at any time by contacting us at: privacy@hlhamilton.com
4. Cookies & Other Similar Technologies
We may use technologies such as cookies to automatically collect certain information about visitors to the Site. A “cookie” is a unique numeric code that we transfer to your computer that identifies your browser to our server when you visit the Site. We use cookies to recognize you as a return visitor to the Site and save any information you may have entered into a form, as well as to save your screen display choices. You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, or to disable existing cookies. Note that the opt-out will apply only to the browser that you are using when you decide to opt out of cookies. Without cookies though, the features described here will not function properly. Any cookie sent to your computer by HL Hamilton in connection with your use of the Site does not give us access to your computer.
5. Can I opt out of promotional emails?
If at any time you decide you no longer want to receive promotional emails from us, you can opt-out by clicking the ‘unsubscribe’ link located in the footer of the email or by contacting us at privacy@hlhamilton.com. Please note that we may still send you emails concerning your account with us if you choose to unsubscribe from promotional communications.
6. How and why does HL Hamilton share my personal information?
If you apply for any insurance products, we may disclose your personal information to insurance companies, other insurance intermediaries and other third parties such as insurance rating service providers for the purposes of their assessing risk, determining your eligibility for insurance coverage and setting premiums.
We may share your personal information with:
Motor vehicle registries, drivers’ license authorities and other government regulators, in order to fulfill our regulatory obligations;
Credit card companies, issuers and processors, in order to process your payment for our goods and services;
Our insurance carrier partners, in order to provide you with quotes for insurance and to bind insurance policies you may purchase from us; and
Your professional advisors, as directed by you.
When you give us permission to disclose your personal information to these third parties, the information we provide to them is then handled by them in accordance with their own privacy policy. If you have concerns about their handling of your personal information, you should contact them directly.
In addition, to fulfill the purposes described above at Section 3 of this Privacy Notice, ‘Why does HL Hamilton collect my personal information?’ we need to share your personal information with the following types of third party service providers:
Cloud hosting, database and software providers who help us host, administer, maintain and operationalize our information systems, which include our broker management and customer relationship management systems, our telephony systems and the Site;
Vendors, who help facilitate administrative processes for us such as sending documents to our customers;
Client relationship managers, who help us build, maintain and strengthen our relationships with our customers; and
Brokers and consultants, who help us assess your needs and provide you with our products and services.
When we allow a third party service provider to access your personal information, we only allow them to do so for the sole purpose of carrying out the above services on our behalf. In our service agreements with these service providers, we require them to treat your personal information as securely as we do.
In certain narrow circumstances, the law permits us to disclose your personal information without your consent. For instance, we may disclose your personal information to government, regulatory or law enforcement agencies as requested by these agencies, if we have a good faith belief that the disclosure is required or permitted by law. We may also disclose your personal information in order to enforce our legal rights; to detect, prevent or address fraud or security issues; in connection with a court or regulatory proceeding; and to enforce ours or others’ legal rights, property, or safety.
We may also transfer or assign your personal information to third parties because of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.
We do not trade, rent or sell your personal information.
7. How does HL Hamilton keep my personal information safe?
HL Hamilton uses reasonable technical, organizational and administrative measures to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. These include:
Implementing encryption, antivirus and firewall technology as necessary on all of our information systems;
Training our employees on how to securely handle your personal information;
Requiring personnel with access to our information systems to use strong passwords to protect their accounts; and
Implementing policies requiring our personnel to treat mobile devices with access to your personal information securely.
We restrict access to your personal information to only those HL Hamilton employees, contractors and agents who require that information to carry out the purposes identified above at Section 3 of this Privacy Notice, ‘Why does HL Hamilton collect my personal information?’ Anyone with access to your personal information is subject to strict confidentiality obligations. However, you should be aware that no safeguard is 100% secure, and despite our best efforts, we cannot guarantee that your information will be secure, particularly while it is in transit over the Internet.
We only retain your personal information for as long as necessary to fulfill the purposes described in Section 3 of this Privacy Notice, ‘Why does HL Hamilton collect my personal information?’
8. What rights do I have over my personal information?
At any time, you may withdraw your consent for us to collect, use or disclose your personal information. However, this may affect our ability to offer you some of our products and services. For example, you would be unable to acquire or renew an insurance policy with us.
At your written request, we will let you know what information HL Hamilton has about you, what it is being used for, and with whom it has been shared. If you notice any inaccuracies or wish to update any of your personal information, we will make those changes if you request us to do so. If we disagree with your request, we will note that.
At your written request, we will also provide you with access to your personal information that is in our control, subject to certain exceptions. These include where:
Personal information about another person might be revealed and the other person’s personal information cannot be separated from yours;
Commercially confidential information might be revealed and the confidential information cannot be severed from yours
The requested information is subject to solicitor and client privilege;
Someone's life or security might be threatened as a result of giving you access and the personal information about the other person cannot be separated from yours;
The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.
The way in which we will give you access to your personal information may vary, depending on the format in which we hold it and the amount of information. We may provide your information in physical or electronic format. In the case of an exceptionally large file, we may provide you with a summary of the personal information.
To make a request to withdraw your consent, or access or correct your personal information, contact HL Hamilton’s Privacy Officer at privacy@hlhamilton.com.
9. CONTACT US
If you have any questions or concerns about this Privacy Notice, you can contact HL Hamilton’s Privacy Officer:
David Cowlin
HL Hamilton Insurance Ltd
102 Murray Street
Amherstburg, Ontario
N9V 1H9
519-736-2122