Privacy Policy

Acronym

 

Term

Document Context

LCA

Lareau – Insurance Brokers Inc.

AMF

Autorité des marchés financiers

 

1.0 Introduction

 

LCA is an insurance brokerage firm headquartered in Napierville (province of Quebec), which focuses on providing personal and commercial insurance services.  

For more information about our services, please refer to our website: https://lareau.ca/. Your personal information is collected by LCA on its own behalf. 

LCA recognizes the importance of protecting your personal information. This Privacy Policy explains how LCA collects, uses, retains and discloses your personal information and applies to customers or prospective customers of LCA’s websites, web-based applications, marketing campaigns, social media accounts, services and products, but does not apply to LCA’s current or prospective employees or suppliers. LCA does not seek to collect personal information from individuals outside of Canada. However, if you believe that LCA is doing so, please let us know.  

We recognize that personal information privacy is an ongoing responsibility, and we may from time to time update this Privacy Policy or implement new personal information protection practices or policies. We therefore reserve the right to update this policy at any time and any such changes will be effective as of the date indicated in the change. Please check this Privacy Policy periodically for changes. LCA will consider that you have accepted the changes to this Privacy Policy if you continue to provide personal information to the LCA after the changes come into effect. 

Pursuant to applicable law, by providing your personal information to LCA after you have been informed of this Privacy Policy, you consent to the collection, use, retention and disclosure of your personal information in accordance with the terms of this Privacy Policy. Your consent may also be implied in certain cases, depending on your reasonable expectations. 

 

2.0 How is your personal information collected and what information is collected?  

 

2.1 Information you choose to provide to us

Your personal information is collected directly from you when you provide it to LCA.  

We may ask you to provide personal information when: 

  • You visit our website; 
  • You request a quotation from LCA or inquire about our services; 
  • When you purchase an insurance policy from LCA; 
  • When you are paying for our service; 
  • When you open a claim under your insurance policy; 
  • You refer any person or business to us; 
  • You connect with us directly via phone calls, video conferencing platforms or social media; 
  • You participate in a marketing/sales promotion; 
  • You participate in programs we may offer from time to time. 

If you choose to provide us with a third party’s personal information (the person’s name, email and company) when taking part in our referral program, you represent that you have the third party’s permission to do so.  

WHAT

Information collected may include but it is not limited to:

  • Name (first, middle and last name) 
  • Address (business or personal) 
  • Birthdate 
  • Marital status 
  • Gender 
  • Employment information 
  • Phone number 
  • E-mail address 
  • Policy type, number and renewal date 
  • Driver’s license number 
  • Accident/violation history 
  • Lien/leaseholders 
  • Vehicle information 
  • Loan and mortgagee details 
  • Property descriptions and addresses 
  • Payment and banking information 
  • Credit rating information 
  • Claims history 
  • Driving record 
  • Criminal record 
  • Educational information 
  • Your employee’s information (driver’s license number, birthdate, CV, driving record) 
  • Your company’s financial information 
  • Your company’s shareholders, directors’ and officers’ information 

2.2 Information we collect automatically

In operating its websites and applications, LCA may automatically collect online personal information provided through digital tools. These tools collect only a limited set of data including the Internet Protocol (IP) address used to access third-party websites, the date and time of the visit, the pages visited, the web browser type and version, and the operating system used, as well as the websites that the user accessed immediately before and after accessing LCA’s websites. LCA collects and obtains this online information when operating its websites. For example, when a user chooses to visit a website, web servers may automatically collect online information provided through the browser being used, stored in a cookie, or using a web beacon or any other digital marker.  

LCA uses online information to monitor the use of its websites and improve operations, personalize user experience by providing personalized ads or offers, carry out statistical analyses on all user characteristics and behaviour, measure demographic variables and user interest with regard to specific services, describe its services to third parties and potential business partners, and determine how and where LCA should allocate its resources in order to be most effective.  

Such online information is necessary so that LCA can record the number of visitors, the pages visited most frequently, the technology used by website users, referencing sites, and user location. 

LCA may use cookies. Cookies are fragments of information sent from a user’s computer when the user is visiting a website. They are temporarily or permanently stored on the user’s hard drive, leaving a record of the visit. When you visit a website, a cookie may be created and stored, allowing you to be recognized each time you visit the site. Such information may include the Internet Protocol address, the date and time of the visit, the pages visited, the domain used to access the site, the type and version of browser or operating system you are using, and the website you have just accessed and ill access in the future. Cookies may also improve online experience by enabling us to record your browsing preferences, analyze the operation of our websites, carry out statistical analyses and recommend content to you. 

For more information about the list of cookies, their functions, the provider names, and the terms and conditions used on our website, please refer to the Cookies Policy section on our website (Cookie Policy | Lareau Insurance Brokers), where all this information is collected and updated automatically. 

Many major websites use cookies. Most browsers are configured initially to accept cookies. If the user prefers, browser settings can be modified so that the user can be warned each time a cookie is received or so that the browser refuses to accept cookies. While users are not obligated to accept cookies, it is possible, however, that some website functions will not work correctly if a browser is set to refuse cookies. You can consult the following link for an overview of how to block or delete cookies on the most common browsers: https://youradchoices.ca/. 

Websites may contain electronic images called web beacons that allow LCA to record the number of people who have visited given pages. Web beacons are not used to access personal information. Web beacons only collect a limited data set, including a cookie number, the time and date the page was viewed, and a description of the page on which the web beacon is located. Websites may also contain web beacons that have been placed by advertisers or web analytics service providers to help LCA assess the effectiveness of promotional and sponsorship campaigns on the Internet. 

Websites may also use remarketing services that, using cookies or web beacons, identify users who have visited a website and reach them with online advertising once they have left the website, for the purposes of advertising based on prior browsing. 

Websites may contain hyperlinks to third-party sites that would lead users to leave the LCA websites. LCA provides these hyperlinks as a convenience. Third-party sites are not under the control of LCA, which therefore has no control over the practices of such third-party sites regarding privacy and confidentiality. As a result, any personal information sent through third-party sites is subject to the Privacy Policy of such third-party sites. It is the responsibility of users to review such policies to ensure that their information is protected. 

LCA may use social media (e.g., Facebook and LinkedIn) in addition to operating its websites. Third-party social media websites are not under the control of LCA. LCA therefore has no control over the privacy and confidentiality practices of third-party sites. Users who decide to interact with LCA on social media must therefore first read the terms of service and privacy policies of such third-party service providers and the applications used to access them. It is your responsibility to read them in order to ensure the protection of your personal information. 

Personal information provided to LCA through social media accounts is collected to capture conversations (e.g., questions and answers, comments, “likes,” retweets) between users and LCA. Such information may be used to respond to inquiries or for statistical, evaluation, or reporting purposes, or for any other purpose specified in this Privacy Policy. 

We may also collect information when you open email messages from us or click on links within those email messages. 

 

2.3 Information we may collect from third parties

Your personal information is also collected from third parties as provided in this Privacy Policy or as otherwise permitted by applicable law. LCA may collect personal information from its business partners or other third parties, provided that such third parties confirm that you have authorized them to disclose such information to LCA or that you expressly consent to such disclosure. 

We may combine the information we collect from you with information obtained through other third-party sources, such as insurance agents and brokers, government bodies, consumer reporting agencies, insurance adjusters, home contractors, auto shops, and other third parties who can provide information about or services related to you or your insured vehicle or property or company.  

The personal information collected includes your name, email address, business address, job title, company name and ownership, and telephone number, professional designation, educational background, driving record and claims history, credit information, accident reports and witness statements. 

2.4 Calls, online chats, and other communications

We may record calls, online chats and other communications between us to ensure quality customer service, confirm our discussions or agreements and your instructions, resolve complaints, and train our staff. If you do not want your communications recorded, you can do business with us by visiting one of our offices, or by writing or emailing us. 

2.5 Consenting for others

We may ask you for information about other persons covered by your insurance (for example, listed drivers, employees, kids, persons living under your roof or for whom you are responsible, etc.). The person concerned must consent to the collection. 

LCA intends to comply with applicable laws regarding the privacy of minors and advertising directed at them. We will not collect any personal information concerning a child under the age of 14 without the verified consent of their parents or legal guardians. However, if you believe that LCA is doing so, please let us know. In the event that LCA wishes to collect personal information from minors under the age of 14, it will obtain consent directly from parents or legal guardians, as required by applicable law. 

If you choose to provide us with a third party’s personal information when taking part in our referral program, the third party must consent to the collection. When you give us information about another person, you warrant that you have their permission to do this. 

2.6. Video Surveillance

For the safety of the public, LCA customers, and prospective customers, our premises may be outfitted with video surveillance systems. Video surveillance is collected strictly for security purposes and will not be disclosed to third parties unless required by law.   

 

2.7 Is it possible to refuse the collection of personal information? 

You may refuse the collection of your personal information. However, refusal of such consent may limit our ability to provide services or products to you. We will not refuse to fulfill your request for products or services if you refuse such consent, unless the collection is necessary for that purpose. Your consent to our use of your personal information for secondary purposes is therefore not required. 

The same rules apply if you withdraw your consent. 

 

2.8 Will we make decisions based exclusively on automated processing of your personal information? 

We do not intend to make decisions based exclusively on automated processing of your personal information

3.0 Purposes for the collection of personal information   

 

We collect personal information for the following purposes:  

  • To serve you better and communicate with you directly through emails, calls, chats, video conferencing; 
  • To provide services or information requested by you, including when you inquire about our insurance policies, request a quote, apply for insurance, make a payment, or open a claim under your insurance policy; 
  • To consider your application for insurance and offering you insurance; 
  • To verify your identity and property; 
  • To identify your needs and advise you appropriately; 
  • To solicit you for new insurance products or upon your renewal date; 
  • To understand your situation and analyze it for insurance purposes; 
  • To assess and underwrite insurance risks; 
  • To determine prices, fees, premiums and rebates; 
  • To investigate and adjust insurance claims; 
  • To settle or arrange for the settlement of insurance claims, including structured settlements; 
  • To collect of payments for purchased services; 
  • To send communications to you about the following, in accordance with applicable law including the Canadian Anti-Spam Legislation and with your express consent when required: 
    • our services and offerings  
    • event announcements  
    • product notices and changes to our terms and policies  
    • particular programs in which you have chosen to participate  
    • promotional offers and surveys 
    • scheduling demos and managing free trials 
  • To advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites; 
  • To carry out market research to understand how to improve our services and their delivery; 
  • For statistical and accounting purposes (in the latter case, personal information is aggregated and anonymized); 
  • To create and manage marketing campaigns; 
  • To generate sales leads and increase our market share; 
  • To analyze user clicks and usage of our website to improve user experience and maximize usage of our services; 
  • To manage our website in order to maintain and deliver the contracted functionality and services; 
  • To enforce our Website Terms and/or separate contracts (if applicable) with you; 
  • To detect and prevent fraud and other prohibited, unauthorized, or illegal activities; 
  • To share your information, with your consent and as provided herein, with third party service providers for external processing such as data or payment processing; 
  • To protect the security or integrity of the website, application, our business or services; 
  • If we have reasonable grounds to believe that the collection may be useful in the investigation of a contravention of federal, provincial or foreign law, or to protect or defend a legal interest; 
  • Otherwise, as disclosed to you at the point of collection or as required or permitted by law. 

If we wish to use your personal information that has been collected for a purpose not previously disclosed to you, we will seek your separate consent before using it, unless applicable law permits us to do so without your consent. 

We do not sell your information to any third party.  

At or before the time the information is collected, we will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties such as credit bureaus otherwise than as provided for in this Privacy Policy. 

4.0 How we share personal information

4.1 Within LCA

Only authorized LCA personnel who require access to your personal information in the course of their duties have access to it. Your personal information may therefore be viewed by our employees with need-to-know access privileges in order to provide requested products or services to you. 

Our employees are informed of their obligation to maintain the confidentiality of personal information and we make them aware of the importance of this obligation. Our employees may only use personal information in accordance with the terms of this policy. 

4.2 With Third Parties (including service providers) 

We will only disclose your personal information to third parties in the following cases: 

  • You have authorized us to disclose information to a third party for a specific purpose, such as with our insurance partners solely for the fulfillment of the requested services or products; 
  • Third parties act on behalf of LCA as agents or service providers (e.g. IT service providers, hosting providers or marketing solution providers), and information is disclosed to them only for this purpose, it being understood that such third parties must abide by strict contractual terms that require them to maintain the confidentiality of all information, to use it only for this purpose and not to retain the information once the contract has expired; 
  • If a person is acting as your representative, or if we reasonably believe that the person is acting under proper authority (e.g. guardian, parental authority, etc.), or is a person who holds a LCA service jointly with you; 
  • To meet legal requirements; 
  • If we are required to provide personal information in response to a valid court order, subpoena or governmental investigation, or as otherwise required by applicable law; 
  • If LCA ever sells its business or assets, in whole or in part, or merges, undergoes a change of control, as required by such transaction, as well as for due diligence purposes;  
  • As required or permitted by applicable law 

4.3 Where is personal information stored, and is it likely to be disclosed outside of Quebec? 

Depending on the nature of the personal information, it may be held at our offices, in various computer systems or in those our service providers, or in our storage facilities or in those of our service providers. 

Your personal information may be disclosed outside Quebec or Canada for the purposes described above, which may include collection, use, disclosure or retention. 

5.0 How we secure personal information

We maintain reasonable measures to protect the security of your personal information. 

Our measures include physical and electronical safeguards to protect your information from loss, unauthorized use and access or disclosure. The nature of the reasonable measures in place varies depending on the sensitivity of the personal information collected, the amount, distribution and format of the personal information, and the method of storage. We use encryption technologies to protect data at rest and in transit. When personal information is destroyed, we take care to prevent unauthorized persons from gaining access to it. 

6.0 Your rights and how you may exercise them 

You have the following rights, subject to the limits and according to the terms of the applicable laws: 

  • Access your personal information or request a copy. 

You have the right to submit a written request to obtain information about what personal information we collected on you and to obtain a copy of your personal information.  

We will respond to your written request within 30 days, in accordance with applicable laws. 

  • You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it. 

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly. 

  • Change or correct your personal information. 

You have the right to update and correct your personal information or to ask us to do it on your behalf by contacting your broker.  

We will respond to your written request within 30 days, in accordance with applicable laws. 

  • Delete or erase your personal information. 

You have the right to request deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you. 

  • Withdraw your consent at any time 

Withdrawal of consent binds us to the use of personal information based on that consent, but will not affect the use based on your consent prior to its withdrawal. You have the right to withdraw your consent to the use of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes. 

Even if you opt-out of receiving marketing communications, we may still communicate with you in connection with security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.  

  • Ask us to restrict the use of your personal information 

We mainly use your personal information for the primary purpose of placing insurance policies. If you withdraw your consent to the use of your personal information for such purposes and related purposes, we will be unfortunately unable to provide you with our services.  

  • Export your personal information. 

You have the right to request that we export to you in a machine-readable format all of the personal information we have about you. 

 

If you would like to exercise any of the rights described above, please contact LCA’s person in charge of the protection of personal information (see below). 

The request must contain sufficient information for us to be able to process it. We undertake to respond to requests within a reasonable time and, insofar as possible, within thirty (30) days, as provided for by applicable laws. However, we must first verify the identity of the person making the request. 

LCA will ensure that your personal information is as accurate, complete and as up-to-date as possible for the purposes for which it is to be used. It is, however, your responsibility to ensure that your personal information, such as contact information, is kept up to date with LCA. 

7.0 How long we keep your personal information

 

We retain personal information as long as it is necessary for the fulfillment of the purposes set forth in this Privacy Policy, for as long as it is reasonable to do so for customer service, legal or business purposes. The length of retention depends on the identified purposes and the nature of the information. At the end of this period, the information will be destroyed, deleted or anonymized. 

We may also retain personal information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law.  

The personal information we retain will be handled in accordance with this Privacy Policy and is kept in strict confidence.  

Personal information connected to you that is no longer necessary and relevant to provide our services may be anonymized or aggregated with other non-personal information in order to use it for serious, legitimate purposes and to provide insights which are commercially valuable to LCA, such as statistics of the use of the services.  

8.0 Other Important Information

 

  • Process for dealing with complaints 

For any complaints regarding this Privacy Policy or the protection of your personal information, you can write to our Privacy Officer by email at the coordinates below. LCA will acknowledge receipt of your complaints, investigate such complaints and will inform you of the findings of the investigation. 

If your complaint is justified, we will take appropriate measures to rectify the situation.  

If you are not satisfied with this internal review of your complaint, you can contact the Commission d’accès à l’information du Québec or the Office of the Privacy Commissioner of Canada, or any other relevant regulatory authority. 

You also have the right to lodge a complaint with the Autorité des marchés financiers at 1-877-525-0337 or www.lautorite.qc.ca. 

9.0 Contact Information

 

The person exercising the highest authority at LCA delegated the Privacy Officer the function of person in charge of the protection of personal information and Privacy Officer. You may contact the Privacy officer to exercise any of your rights or to ask for more information about your personal information and our privacy practices by email to [email protected].

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