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Policies & Agreements

Agreements

Privacy Policy

This Privacy Policy applies to the personal information (“personal information”) that Privilege Underwriters Reciprocal Exchange, Canadian Branch (“PURE”, “we” or “our”) collects, uses or discloses in the course of our insurance business, including information collected about you (a) on our website, (b) offline or when you contact us via email or through our service and claims centers, and (c) from third parties.

Personal information means information about an identifiable individual. Personal information includes information that does not directly identify you by name or include your contact information, but which may be used to identify a specific computer or device that has accessed our website and which, if combined with certain other information, could be used to identify you. Personal information does not include the name, title, business address or telephone number of an employee of an organization where that information is used to communicate with the employee about their employment.

This Privacy Policy does not apply to information about our employees or to information that is not personal information.

We may update this Privacy Policy from time to time. The most current version will be posted on our website at www.pureinsurance.ca. You should periodically check our website for any changes to the Privacy Policy. By using our website or sending us any personal information after the effective date indicated, you will be deemed to be bound by the Privacy Policy in effect as of the date of such use.

Collection of Personal Information

We collect, use and disclose your personal information for insurance purposes, including:

  • to review applications for insurance submitted to us for underwriting consideration;
  • to verify information provided to us;
  • to assess and underwrite risks;
  • to rate, bind, issue and administer insurance policies;
  • to investigate, adjust, process and pay insurance claims;
  • to communicate with you or your broker;
  • to analyze business results and compile statistics;
  • to meet legal and regulatory requirements, including responding to court orders and legal investigations;
  • to prevent and detect fraud or illegal activities;
  • to offer products and services to you; and
  • as may be required or permitted by law.

We may also collect personal information about third parties with respect to claims made against our members.

Types of personal information collected by PURE

PURE collects only the information necessary to underwrite insurance policies, adjust claims, perform the other functions necessary to provide you with the products and services we offer and improve our website, products and services. The type of personal information we collect depends on the product or service you have with us. This information could include:

  • information that identifies you, including your full name; date of birth; work and home email address and physical address; work, mobile and home telephone numbers; user name; driver’s license number; and any other personal information you may provide when contacting us or submitting an inquiry;
  • vehicle information, motor vehicle and claims history; vehicle operators’ information; mortgages and lien or lease holder information;
  • credit card information;
  • credit reporting information such as credit scores, where permitted by applicable law;
  • your occupation;
  • whether you own or rent your residence; information about your property; and our products or services you have purchased, obtained or considered; and
  • Internet or other electronic network activity information: Internet Protocol (IP) address and cookie data (including third-party cookies and related data).

How PURE collects personal information

Most of the personal information we collect is provided to us by our members or their insurance brokers. If an insurance broker tells us that it has a person’s consent to collect and disclose their personal information, we will rely on that statement. We obtain personal information from applications or as otherwise submitted to us by an applicant, an insured, or their insurance broker or authorized representatives.

We collect personal information from you, for example, when you:

  • apply for insurance, file a claim or contact us for information or with questions;
  • send us emails or other correspondence;
  • communicate with us by telephone (we may record or monitor the call); or
  • visit or interact with our website and online services (such as our member portal).

We may also obtain personal information from other sources such as consumer reporting agencies; other institutions or information services providers; employers; other insurers or insurance industry sources and databases; and insurance adjusters and private investigators in connection with claims.

How PURE uses personal information

We use your personal information for the following purposes:

  • if you apply for insurance or file a claim with us, we use your personal information to determine coverage, issue and administer your policy, process payment, adjudicate claims, and contact you regarding your policy and claims.
  • if you use our member portal or your broker logged on to PURE online, we use your personal information (including username and password) as necessary to register, maintain and secure your account (including to identify you at sign-in and prohibit others from accessing your account) and communicate with you.
  • if you e-mail us or otherwise submit an inquiry or request, we use your personal information as necessary to respond to you and provide you with the information requested.
  • subject to applicable law, a credit report or other consumer report may be used to develop an insurance score for you. An insurance score uses information from your credit and/or consumer report to help predict how often you are likely to file claims and how expensive those claims will be. Insurance score information may be used to determine whether we will issue insurance to you and how much we will charge for insurance. Items from a credit report that could affect an insurance score include payment history, number of revolving accounts, number of new accounts, and the presence of collection accounts, bankruptcies and foreclosures. We will use information provided by TransUnion or an equivalent third-party vendor in connection with the development of your insurance score. You can check your credit report and credit score through TransUnion at https://www.transunion.ca/assistance/credit-report-disputes. If you believe that your credit information has resulted in adverse action by us, and your credit information has been adversely impacted by an extraordinary life event such as an identity theft or a catastrophic event, you may write to us describing the extraordinary event and providing supporting documentation verifying how your credit history was adversely affected and request that we review our decision to use your credit information. We will then review our decision and advise you as to whether we will grant an exception such that we do not use your credit history in determining whether to issue insurance to you and how much we will charge you for insurance.
  • for any other purpose for which you provide consent.

How PURE shares personal information

We may share your personal information with:

  • our affiliates, reinsurers, other insurers and your insurance broker;
  • third parties to detect and prevent fraud or illegal activities;
  • parties to whom you have provided consent to us sharing your personal information;
  • the transferee of our business, if we reorganize or transfer our business; and
  • parties with whom we are legally permitted to share such information.

We may exchange personal information with third party service providers who perform services on our behalf. For example, we may use service providers to perform services including investigating, adjusting and processing claims; printing, mail and email distribution; information technology; data storage; administration; and marketing. Our providers are required by contract to keep all personal information confidential and secure and have privacy policies and security standards with respect to personal information that are comparable to ours. Our service providers are only given the information they need to perform their designated functions, and they are not authorized to use or disclose personal information for their own purposes.

Use of personal information for optional marketing purposes

We may use your personal information to offer you additional products and services that we provide. The collection, use and disclosure of your personal information for such marketing purposes is entirely optional and is not required as a condition of doing business with us. You may withdraw your consent to the use of your personal information for optional marketing purposes at any time by contacting us at [email protected].

We do not sell, trade or disclose our customer lists for marketing purposes.

Consent

Personal information is collected, used and disclosed with the consent of the individual to whom the information relates, or as otherwise permitted by law.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. You will be advised of the implications of such withdrawal, which may include the termination of a policy or the inability to process or defend you in a claim.

Protection of personal information

Personal information recorded in paper documents is securely stored in our offices in Canada or in secure off-site storage facilities. Electronically recorded information is stored on computer systems maintained by us, our affiliates and our service providers. Your personal information may be processed and stored in countries other than Canada, and may be accessible to the governments, courts or law enforcement or regulatory agencies of such countries.

We have adopted physical, organizational and technological security safeguards to protect personal information against unauthorized access, loss or theft that are appropriate to the sensitivity of the information. Our computer systems and the information stored in them are protected by electronic security systems. We restrict access to personal information to our employees, reinsurers, administrators and consultants who need to know the information to provide insurance products and related services. Our employees receive training on how to protect personal information and they are required to comply with this Privacy Policy and all applicable privacy laws.

While we strive to protect your personal information to the extent possible, we cannot guarantee or warrant the security of any information you transmit to us or from our website. We also cannot be responsible for criminal acts of third parties, such as hackers, who may seek to compromise our security measures through unlawful means. Therefore we do not promise, and you should not expect, that your personal information provided through our website will always remain private.

Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with our regulatory obligations and obligations under applicable law. When personal information is no longer necessary, we destroy, erase or anonymize such information. In view of the ongoing exposure to potential claims, where necessary, some of the personal information collected for insurance purposes may be kept indefinitely.

Access to Personal Information

Access to personal information held by PURE

You may request to be informed of the existence, use and disclosure of personal information we hold relating to you. Subject to satisfactory proof of identity, we will provide appropriate access to such information.

In certain situations, we may not be legally permitted to provide access to all personal information we hold relating to you. For example, we cannot provide access to personal information relating to other people or personal information protected by legal privilege. Exceptions to the access requirement will be limited and specific, and we will provide you with the reason for denying access.

Correction of personal information held by PURE

If you ask us to amend or delete information about you and provide evidence that the personal information we hold is incorrect, we will correct, amend or delete the personal information in dispute or notify you of the action we will take along with the reason for our decision. You can submit your request for additional information or your request to amend your information to:

Privacy Officer
[email protected]

If the information you ask us to modify is from another source such as a credit reporting entity, we will not be able to change their information and you will need to work directly with that provider.

We try to ensure and maintain the accuracy of the personal information we collect and use. However, we rely on individuals who provide personal information to us to advise us of any changes to that information.

Cookies and Analytics

Cookies

We use session cookies to ensure that your computer displays our website effectively and to track anonymously the usage of our website. We do this to improve your experience while using the website and directly advertise related products and services. We may also share with or allow third parties to utilize cookies for marketing or advertising customized to your apparent interests or needs. A session cookie is a small data file which is temporarily stored on your computer’s hard disk or website server and does not collect any personal information. You have the ability to accept or decline cookies using your web browser settings. If you choose to not accept cookies from our website, you may not be able to take full advantage of its features or to receive some of the services that it provides. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the following websites:
https://youradchoices.ca.

We currently do not have technology that would respond to web browser “Do Not Track” signals.

Analytics Services

We may allow third parties to collect information about the users of our website. Such third parties may collect personal information about your online activities over time and across different websites when you use our website. We do not control these third parties, who may engage in practices that differ from those described in this Privacy Policy.

For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect information about how you use the website in order to improve the website experience and our services. Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use the website and how you use the website. Google Analytics does not collect or store information that will identify you. Your IP address is anonymized prior to being stored on Google’s servers in order to help safeguard your privacy. For more information on Google Analytics go here - https://www.google.com/policies/privacy/partners. You may block the use of Google Analytics by installing the opt-out tool found here - https://tools.google.com/dlpage/gaoptout. By using the website, you consent to the processing of data about you by Google as described here and in Google's privacy policy.

Children

Our services are not intended for use by children. We do not knowingly collect personal information from children under the age of 16 years. Please contact us if you believe we may have unknowingly collected information about a child under 16 years of age, and we will delete any such personal information.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

[email protected]

Complaints Resolution Process

PURE aims to deliver an exceptional member experience at every touch point. If you are ever unhappy with your experience, whether it is related to our claims handling, products, service, processes, or anything else we want to hear about it. To assist you in reaching a resolution please follow the following steps:

Step 1: Voice your complaint

To share your complaint, you can:

Contact PURE Directly
Contact our Member Services team at: 833.936.7873 or [email protected]

Contact your Broker
As your trusted advisor, your broker can also be a resource to help resolve issues and communicate with PURE on your behalf.

Step 2: Escalate your complaint

Need to escalate the matter? Contact the PURE Complaints Resolution Team

If after speaking with a PURE representative and/or your broker working with their contact at PURE, your complaint is still not resolved to your satisfaction, you can contact the PURE Complaints Resolution Team (PCRT) by emailing: [email protected].

Your letter should set out a summary of your complaint, the reasons you feel your complaint has not been resolved, all relevant supporting documentation, and your desired outcome.

Upon receiving your written complaint, the PCRT will conduct an impartial review of your complaint and contact you if additional information is required. Upon completion of the investigation, the PCRT will send you a written response setting out their decision and the reasons for it. Once the PCRT provides a final decision, your file will be considered closed. To reopen the file, you will be required to provide new information and/or relevant documentation for further consideration.

Step 3: Escalation outside PURE

If you are not satisfied with the decision of the PCRT and would like to have the matter reviewed externally, you can contact the General Insurance OmbudService (GIO), an independent third party that helps resolve disputes between consumers and their home and auto insurers:

General Insurance OmbudService (GIO)Dispute resolution service

4711 Yonge Street, 10th Floor,
Toronto, ON, M2N 6K8
1-877-225-0446 | www.giocanada.org

If you have a regulatory complaint, you can also contact the

Financial Consumer Agency of Canada (FCAC) - Supervises federally regulated financial institutions to ensure compliance with federal consumer protection laws.

FCAC, 427 Laurier Ave. West
6th Floor, Ottawa, Ontario K1R 1B9
1-866-461-3222 (English) or 1-866-461-2232 (French) | www.fcac-acfc.gc.ca