CUMIS Privacy Policy

In this privacy policy, "CUMIS", “we”, "our" and "us" means, collectively, CUMIS General Insurance Company and CUMIS Services Incorporated. This policy governs in general terms how we collect, use, retain, and disclose your personal information and that of any other person(s) whose personal information is collected by us or our distributors or that is disclosed to us as part of your relationship with us, in accordance with the requirements of applicable legislation and our continuing commitment to privacy.

Creditor insurance policies that are branded CUMIS are underwritten by Co-operators Life Insurance Company. The privacy policy for Co-operators Life Insurance Company can be found here.

Overview

At CUMIS, we recognize and respect the importance of privacy. When you do business with us, we will ask you for your consent to collect, use and disclose your personal information. We will explain the purposes for which we will collect, use and disclose your personal information, and we will not share your personal information except with your consent or as required or permitted by law.

You can withdraw your consent at any time. You may access and correct, if needed, the personal information we have about you by sending us a request in writing to privacy@cooperators.ca or the mailing address below.

Your personal information may be accessed by our employees and other authorized personnel who need to use it to perform their duties. This may include third-party service providers, including those that are located outside of Canada. If your personal information was collected, used or disclosed within the province of Québec, it may be communicated outside Québec. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with our third-party service providers.

With your permission, we may tell you about products and services that may be of interest to you. You can tell us what information you want to receive from us, and you can change your preferences at any time.

For more details about CUMIS's privacy practices, please refer to the information below.

Our commitment

Our client relationships are built on a foundation of trust. We are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information collected, used, retained, and disclosed while doing business with you. We are responsible for all personal information under our control, whether supplied to us directly by you or by a third party or that we have provided to our third-party service providers for processing. We take our privacy obligations seriously and strive to implement privacy practices guided by the highest standards of ethical conduct.

Your consent

We will obtain your consent prior to collecting, using, retaining, or disclosing your personal information for specific purposes, except where we are specifically permitted by law to collect, use, retain or disclose your personal information without your consent such as when we are required by law to disclose your personal information to a government institution. If we wish to collect, use, retain or disclose your personal information for a new purpose, we will seek your consent before doing so.

Your consent can be implied or express. Implied consent refers to consent that is inferred from your actions. For example, when you provide personal information to us to obtain an insurance quote, we would infer that you are consenting to our collection and use of the personal information you provide to produce a quote. Express consent is consent that is given specifically, either verbally or in writing. When we ask for your express consent, we will explain what personal information we need, what we will use and disclose it for, and who we will share it with.

Personal information we may collect

We may collect personal information directly from you, and from third parties as described in this privacy policy. When you provide us with personal information about any other persons, it is your responsibility to ensure that you have the approval from these persons to provide their personal information to us and to allow us to collect, use and disclose their personal information for the identified purposes.

We only collect personal information that we need for the specific purposes described in the consent provided by you.

Depending on the type of products or services we provide to you, and the consent that you have provided, we may collect the following personal information:

• Name and contact information including email address
• demographic information (age, date of birth, gender, family and marital status, income, education, and employment)
• driving records and history
• previous insurance and claims history
• medical and health information
• financial and payment information, including credit card, bank account numbers and loan information
• identification numbers (e.g., driver’s license number)
• Social Insurance Number (SIN) for tax reporting purposes, or other Canada Revenue Agency reporting, as well as verification of non-permanent Canadian residency
• financial and insurance needs
• information about your assets, investments, debts, expenses
• personal information publicly available from external sources as permitted by applicable laws
• credit information (including credit score and other information contained in your credit file) obtained from credit reporting agencies
• information contained in legal documents (death certificates, court orders, powers of attorney etc.)
• information related to a specific claim or investigation (including information contained in police reports, officer notes, photographs, videos, voice recordings, investigation reports, and mobile phone records)
• your IP address and characteristics about the electronic devices you are using to transact with us

Purposes for which we may collect, use, or disclose your personal information

The following are some of the purposes for which we may, with your prior consent, collect, use, or disclose your personal information.

1. To conduct a needs analysis, including:
   • determining and evaluating your insurance coverage or investment needs
   • conducting financial planning
   • determining the suitability of and recommending insurance and investment products and services tailored for you
2. To provide a quote, including:
   • analyzing and determining the risk of providing insurance to you
   • determining premiums for insurance products you are interested in
   • detecting, investigating, suppressing, and preventing misrepresentation and fraud
3. To process your application and underwrite and issue a policy to you, including:
   • confirming your identity
   • verifying the information you disclose (for example verifying your address or your phone number, and your driving records, where applicable, by accessing your provincial Motor Vehicle Report (MVR))
   • detecting, investigating, suppressing, and preventing errors and omissions and/or fraud (for example for online purchases we may verify the location you are transacting from, the unique identity of the device you are using or your email address)
   • obtaining access to historical insurance policy and claim details through property and casualty industry databases
   • performing medical and lifestyle assessments
   • in some circumstances, obtaining a consumer report
   • processing of digital signatures
   • analyzing and determining the risk of providing insurance to you
   • processing your application
   • in some instances, determining if we need to pool the risk associated with your policy or cede such risk to a reinsurer
   • referring you to a broker in the event we cannot offer you coverage
   • issuing your policy
   • billing and processing payments, including debt collections and setting-up pre-authorized payments if you choose to do so
   
   Where permitted by law, we may obtain and share information with other organizations for these purposes.
   
   
4. To administer your insurance policy, including:
   • processing policy changes, renewals and terminations
   • confirming your identity
   • communicating with you regarding products and services you have with us
   • ensuring quality customer service
   • resolving disputes
   • training and development
   • issuing surveys
   • evaluating your insurability at your insurance policy renewal
   • with your consent, disclosing policy information to leaseholders, lienholders, mortgagees, and other persons with an insurable interest
   • with your consent, disclosing policy information to employers and plan administrators in the context of group policies
   • periodically reviewing your insurance needs and determining the suitability of our products and services for you
   • performing monitoring and audit activities
5. To assess and process claims, including:
   • verifying your identity and validating the claim information you provide
   • reviewing previous claims, if applicable
   • assessing eligibility for benefits payments, including conducting audits
   • assessing damage or injury and determining benefits
   • obtaining compensation or contribution from third parties
   • settling any disputes with third parties
   • facilitating claim adjustment and investigation activities with the collaboration of third parties as required (e.g., property repairs, rehabilitation, engineers, inspectors/trades persons etc.)
   • detecting, investigating, and preventing errors and omissions
   • detecting, investigating, suppressing and preventing misrepresentation and fraud or illegal activities, including by pursuing criminal or civil actions. Claim information may be pooled with information from other sources and may be subject to analysis for these limited purposes. For this purpose, the information may be disclosed to fraud prevention organizations, other insurance companies, and the police, and databases or registers used by the insurance industry to analyze and check information provided against existing information
   • making claim payments
   • coordinating payments
6. To comply with regulatory obligations set out in applicable federal and provincial laws
7. To conduct business analysis and data analytics, including using your personal information in conjunction with advanced analytics and artificial intelligence techniques to perform business analysis and data analytics, for example:
   • to enable us to detect patterns of fraud to reduce its impact
   • to use insights from your interactions with us to be proactive in our service and to resolve complaints
8. To communicate with you across multiple channels, including by email, SMS messages, telephone calls, including:
   • with your consent, advertising and marketing our products, services, offers, contests, or community events that may be of interest to you, or to conduct market research or surveys
9. To serve advertisements through social media and other advertising platforms, and to improve our marketing campaigns.
10. To test and troubleshoot our internal systems, and assess and enhance our security safeguards, business planning, and management, including assessing resource needs.

Those we may disclose personal information to

We may disclose your personal information to others where necessary and appropriate, but only if we need to for the purposes that you have consented to. We may disclose your personal information to the following:

• third parties who provide services to us or perform services on our behalf, including, but not limited to, payment processors, marketing agencies, social media and other advertising platforms, electronic signature processors, data processors, electronic storage providers, voice verification services, investigators, engineers, and disaster recovery service providers
• our independent financial advisors and brokers, and their respective staff
• our sales distributors, such as credit unions, banks, group policy holders and plan administrators
• third parties as needed to provide you with the product or service you have requested from us, including, but not limited to, provincial driving and motor vehicle licensing authorities, property valuators, appraisers etc.
• third parties who are providing services to you as part of your claim, including, but not limited to, medical professionals, other medical service providers, pharmacies, non-medical benefit providers and administrators, financial institutions, vehicle repair shops and contractors
• witnesses as needed for the purposes of dispute resolution
• credit reporting agencies
• operators of insurance industry databases (for example to analyze and verify information you have provided, such as previous policies and claims, against information contained in insurance industry databases)
• fraud detection & prevention organizations (including Équité Association)
• insurance eligibility and risk assessment organizations (for example Medical Information Bureau Inc.)
• other companies within the Co-operators group of companies
• parties involved in the sale, acquisition, disposition, merger, or amalgamation of companies or as part of other business arrangements, such as joint ventures
• government agencies, as required by law (for example for periodic regulatory filing, reporting in accordance with anti-money laundering or unclaimed property requirements or under other lawful authorities, and for income tax purposes), police
• external auditors, legal counsel and other professionals
• parties with an insurable interest (e.g. lessees, lienholders, mortgagees)
• any other parties you authorize

Automated Decision Making (Québec Only)

To achieve our business purpose of providing financial security for Canadians and our communities, we may use technologies that incorporate automated decision making, while keeping your personal information safe. For example, we may use automated decision making to accelerate our underwriting process, which in turn may simplify and accelerate your insurance purchasing experience.

We will inform you if we make a decision based exclusively on automated processing of your personal information, no later than at the time we inform you of such decision.

Where we are making a decision based exclusively on automated decision making, at your request, we will explain the personal information used in such automated decision making process to make such decision, and the reasons, principal factors and parameters that led to the automated decision.

Where we are making a decision based exclusively on automated decision making, you can contact us by e-mail at privacy@cooperators.ca to correct any personal information used to render such decision.

Profiling and Cookies

We may use technology that includes functionality that, if activated, would allow us to identify, locate or profile you. If we do so, and you are located in the Province of Québec, we will provide you with the means to activate such functionality.

For information on how we use cookies and how you can control them, go to Profiling and Cookies..

You have a choice

We want you to know that you can always:

• decline to provide us with some of your personal information. If you do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.
• withdraw your consent at any time by contacting us, and, subject to any applicable legal or contractual restrictions which we must fulfill, we will cease to collect, use, retain and disclose your personal information after the withdrawal of your consent. If you withdraw your consent, or do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.
• update your marketing permissions and contact preferences at any time by contacting us at customer.services@cumis.com.

Credit information we may obtain and exchange with credit reporting agencies

Where applicable and permitted by law, we may ask for your consent to collect, use and disclose your credit file information (including your credit score). This is a common practice in the Canadian insurance industry. To access your credit file information from credit reporting agencies, we will need to share limited personal information with them to identify you, such as your name, address and date of birth.

At CUMIS, we may use your credit file information in combination with other personal information in the assessment of risk of insurability associated with your application or policy, as well as to perform other risk analysis and data analytics. Typical items from a credit report that could affect a credit score include, but are not limited to, payment history, number of loans and credit cards, age of loans and credit cards, the presence of accounts that have been referred to collection agencies, and the presence of bankruptcies and foreclosures. For detailed information about which credit reporting agency we access, please contact us at customer.services@cumis.com.

Our insurance risk assessment allows us to:

• accurately determine the appropriate premium for the policy you have applied for
• determine your eligibility for automatic payment plans
• analyze and cede risks to our reinsurers and risk sharing pool, as needed

Our credit inquiries do not impact your credit score and your credit report will generally identify which companies have requested your credit file information.

We may also use your credit file information to confirm your identity and verify information about you, such as your current address, to detect fraud and misrepresentation.

We may retrieve your credit file information from time to time to ensure that we have the most accurate credit file information. You can revoke your consent at any time by contacting us in writing.

Only authorized personnel with a need to know may have access to your credit file information. For general information on this topic click this link Credit report and score basics by the Government of Canada.

Retention of Information

We retain personal information only as long as is necessary to fulfill the purposes for which it was collected, unless authorized or obligated by applicable laws to retain personal information for a longer period.

Safeguards

We are committed to protecting your personal information. We take the security and confidentiality of your information very seriously. Find out more about our security practices.

All our employees must abide by our Code of Ethics and Business Conduct and annually attest to doing so. In addition, we have developed and implemented privacy guidelines and practices which are reviewed, monitored and audited periodically.

Your personal information may be accessed by our employees and other authorized personnel who need to use it to perform their duties. This may include third party service providers, including those that are located outside of Canada. If your personal information was collected, used or disclosed within the province of Québec, it may be communicated outside Québec. In all cases, our employees and other authorized personnel, whether or not they are in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy and practices, as well as with Canada's privacy laws and regulations. They could also be required by law to give your personal information to courts, governments or regulators, both inside and outside of Canada. If your personal information is transferred outside of Canada, your personal information may be subject to the laws of other countries. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with third party service providers.

Accuracy

We make every effort to ensure that the personal information we collect is accurate, complete, and as up to date as possible to properly satisfy the purposes for which it is to be used. It is important that you promptly notify us of any change to your contact information. If we are unable to verify your personal information or contact you, we may be limited in our ability to provide you with our products and services.

Your Rights

Access to & Correction of Personal Information

Upon written request, and confirmation of your identity, we will provide you with access to the personal information that we have obtained about you while doing business with you. However, there may be instances where we may, in accordance with applicable privacy laws, restrict access to your personal information, including where such information is subject to legal privilege, contains confidential commercial information, or relates to other individuals. If applicable, we will advise of the reasons for restricting access and inform you of any recourse that you may have. A response to your request will be provided within 30 days after we receive a written request and we have sufficient information to permit us to identify the existence of the personal information. In Alberta, a response will be provided within 45 days after receipt of a written request, and sufficient information to permit us to identify the existence of the personal information. Where permitted by applicable law, if we need more time to fulfill your request, we will notify you of such delay. There may be instances where medical information obtained about you from a third party can only be released to you through a physician.

Effective September 22, 2024, for individuals living in the province of Québec: You can request a copy of your computerized personal information that we have collected about you. This computerized information will be transferred in a structured and commonly used technological format either to you or to a person or organization designated by you and who is authorized by law to collect such information.

If you exercise these access rights, we may charge you a reasonable fee for the transcription, reproduction or for the transmission of the personal information.

If you believe that the information in our files is inaccurate or incomplete, you have the right to ask us to correct it. We will review your request and, if we agree, will promptly make the necessary corrections.

To request access to or rectify your information contained in our file, contact us at privacy@cooperators.ca. If you authorize a third party to make a request on your behalf, we need your written consent to release your personal information to the third party.

Register a privacy concern

Our goal is to help you meet your needs and provide the best service we possibly can. If you ever have a privacy-related concern, do not hesitate to contact us at privacy@cooperators.ca to discuss it. We take your privacy concerns seriously and we will investigate all privacy-related complaints, and where necessary we will take appropriate measures to address your complaint. Should you remain unsatisfied with our complaint process, we will inform you of what other complaint procedures are available to you.

Update this Privacy Policy

We may review this Privacy Policy periodically to reflect changes in privacy regulations and in our practices. We will post a notice of any relevant and material changes to this Privacy Policy when they occur.