Privacy
Our Privacy Statement and Commitment
Swell Private Wealth values you and your business. As our client or prospective client, you trust us with your personal information; we respect that trust and want you to know our commitment to protect the personal information you share with us. We thank you for your confidence in our office and for choosing us as your source of tailored advice and products. This document outlines our practices with respect to the collection, use, and disclosure of your personal information.
What we will not do with your information
We do not sell or share client information with organizations outside of our relationship with you that would use it to contact you about their own products or services.
Privacy Statement
The purpose of this statement is to inform our clients and other individuals we deal with (“you” or “your”) as to how we collect, use, retain, disclose and protect your personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This Privacy Statement does not apply to information about our employees or to information that is not personal information.
Personal Information We Collect & Retain
Our office and its agents and representatives collect personal information in a number of circumstances in the course of conducting our business. Personal information we may collect and retain includes:
name, address, email address, telephone number, social media, and other contact information;
age, birth date, social insurance number, ID numbers, gender;
information about your preferences, income, assets, or personal finances;
medical records & information, records such as credit, loan, driving & employment, insurance or transaction history;
information about your insurance claims or claims history; and
such other information we may collect with your written or verbal consent or as permitted or required by law.
We generally collect personal information directly from you, for example, from application forms that you fill out for our insurance products and services, or when you communicate with us by telephone, electronically, or in person. We may also collect personal information about you from other sources, such as but not limited to other insurance brokers, insurance companies, investment product suppliers, claims adjusters, your accountant, your lawyer, or your doctor or medical facility.
Use of Personal Information
Our office generally uses personal information to manage and administer our business, including to understand your insurance needs, communicate with you effectively, and providing you with information regarding current and future products.
For example, our office may use your personal information to:
determine your eligibility for, offer and/or provide you with insurance products, investments, and services that you request;
establish your account, execute your transactions, and maintain your account information;
evaluate credit worthiness and monitor, collect premiums and fees;
verify your identity;
ensure your personal information is accurate and up-to-date;
determine prices, fees, and premiums including by evaluating your coverage needs and assessing risk;
maintain, administer, collect, service, and renew your account(s) and assess your ongoing needs for insurance products, investments, and services;
investigate and settle claims;
determine your eligibility for and offer and provide other products or services that may be of interest to you, such as insurance, investment or retirement products or group benefits, unless you ask us not to;
detect and protect against error or fraud;
maintain business records for reasonable periods;
meet legal, regulatory, self-regulatory, insurance, security, and processing requirements; and
otherwise with consent or as permitted or required by law.
Disclosure of Your Personal Information
As necessary to carry out the purposes for which our office collects and uses your personal information, our office may disclose your personal information to third parties. This may include our wholesale organizations known as Managing General Agencies (MGA), and others such as other insurance brokers, insurers, claims adjusters, government, regulatory and self-regulatory agencies, lawyers, accountants, bookkeepers, financial institutions, benefits providers and medical professionals, and others involved in the claims handling process in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance brokerage and insurance practices. Our office may also disclose your personal information with your consent or as permitted or required by law.
Your Consent
Our office collects, uses, and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
Consent to the collection, use, and disclosure of personal information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt-out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having power of attorney). Generally, by providing us with personal information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters, or your employer, we will assume that you consent to our collection, use, and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection.
If you obtain insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use, and disclosure of his/her personal information for the purposes described above.
You may withdraw your consent to our collection, use, and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. There may be consequences to failing to provide or withdrawing your consent, such as your inability to acquire or renew an insurance policy and/or cancellation of a policy. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and foreign government entities as required to comply with laws).
Security
We take reasonable physical, organizational, and technological security measures, such as locked filing cabinets, confidential shredding, and a security system to safeguard the personal information in our custody or control. These safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized employees or agents of our office who require access to your personal information in order to fulfill their job requirements will have access to your personal information.
Access, Correction, and Contacting Us
Our office may establish and maintain a file of your personal information for the purposes described above. Subject to applicable legal restrictions, you may request to have access to the file containing your personal information and the correction of your personal information by writing to the address below. We may take reasonable steps to verify your identity before granting access or making corrections. In addition, if you wish to make inquiries or complaints, obtain information on how to access and rectify the files held by personal information agents we consulted, have other concerns about our personal information practices, or report a breach of privacy, you may write to the address below. Please include your name, address, telephone number, and email address whenever you contact us, including by email. This helps us handle your request correctly.
Swell Private Wealth Ltd.
201 – 462 4th St S.E., T1A 0K6
Attention: Privacy Officer Steve Meldrum
steve@swellwealth.com
If you feel your concern has not been addressed correctly, you may contact the product provider directly or the Privacy Commissioner of Canada for assistance between the hours of 8:30 a.m. to 4:30 p.m. EST, at 1-800-282-1376 or online at http://www.priv.gc.ca.
Privacy Statement Changes
This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this statement. We urge you to visit our website to obtain the current version and review this Privacy Statement frequently. Your continued provision of Personal Information or use of our products or services following any changes to this Privacy Statement constitutes your acceptance of any such changes. This Privacy Statement is effective as of 20 July 2017.