Privacy Notice

GENERAL TERMS AND CONDITIONS

PERSONAL INFORMATION

Personal information is any information concerning a natural person that allows, directly or indirectly, to identify that person, such as name and address as well as financial situation, lifestyle or health information. 

Personal information must be protected regardless of the nature of its medium and regardless of its form: written, graphic, audio, visual, computerized or otherwise.

YOUR CONSENT

We must obtain your consent for the collection, use, retention or disclosure of your personal information, unless required or permitted by law. We ask for your consent in writing, verbally or electronically. Your consent may also, in certain circumstances, be implied. Providing certain personal information for the purpose of obtaining a product or service is equivalent to your consent to have it collected, used, retained or shared for the purposes set out in this notice or as required or permitted by Law.

COLLECTION

Most of the personal information we collect is transmitted to us either directly by you or through your broker or your insurance company whom you have authorized to transmit this information to us. You may also have been asked for personal information about other individuals, such as other family members, in which case we will assume that you have obtained their permission to share such personal information with us. This notice also pertains to the personal information of these individuals. We recommend that you read it to them to ensure they comprehend the principles outlined in this notice.

The information collected is that which is necessary in order to be able to offer you the products and services requested.  This information may include, but is not limited to:

• Your name
• Your contact details
• Your date of birth
• Your civil status
• Information about your work

Depending on the products or services offered to you, you may be asked for additional personal information. Please see the Additional Terms and Conditions for Certain Group Companies for more details.

USE

We only collect personal information that is necessary to provide the products and services you have requested, to confirm your identity, for sound management of records or as required by applicable regulations and legislation (the "Law"), including for the following purposes:

• Communicate with you. 
• Confirm that your information is accurate, complete, and up-to-date.
• Analyse and optimize our customer service.
• Improve your experience by providing you with relevant information and offers.
• Perform actuarial analysis.
• Compile statistics and conduct market trends analysis.
• Handle complaints or conduct investigations.
• Share your information to our affiliates, suppliers or agents in order to provide you with the products and services you have requested.
• Protect against error and criminal activity, including the prevention, detection and investigation of fraud, money laundering, cyber threats and other such risks and threats.
• Enforce and comply with the existing provisions of the Law, which includes responding to audits, assessments, applications or regulatory requirements.

Depending on the products or services offered to you, other uses of your personal information may be necessary. Please see the Additional Terms and Conditions for Certain Group Companies for further details.

DISCLOSURE

Under no circumstances do we sell your personal information to anyone.

Furthermore, we do not give our customer lists or information about them to other companies or third parties for purposes other than those described in this notice.

We however have the right to disclose information about you to government agencies, entities or regulators in order to comply with the Law.

We may share your personal information from time to time with certain suppliers or agents in order to provide you with the products and services you have requested from us. Our suppliers may only collect, use, retain or disclose your personal information for the purposes we authorize.  We ensure that our suppliers act in a manner that complies with our Privacy Policy and the Law. Our suppliers are required to protect their systems from unauthorized access and to maintain high security standards that are at least equivalent to ours.

TRANSFERS OUTSIDE CANADA OR BETWEEN PROVINCES

We may need to transfer personal information outside of Quebec, including from one province to another, or outside of Canada. In such cases, we take steps to ensure that the transfer is made in a manner that protects the personal information and ensures that adequate safeguards are in place, including through contractual obligations with the party to whom the information is transferred. International jurisdictions in which personal information may be collected, used, disclosed and stored outside of Canada include, but are not limited to, the European Union and the United States. Personal information may be governed by the laws of that country and accessible by the courts, governments, law enforcement and national security agencies of that country. To obtain further details about our policies and procedures concerning the transfer of personal information to foreign jurisdictions, please contact the Privacy Officer mentioned below.

AUTOMATED PROCESSES

In some cases, we may use processes that are solely automated or involve a significant level of automation to analyze a case, respond to requests to us, or make decisions. For more information about our use of automated processes, please contact the Privacy Officer mentioned below.

CONSERVATION

We will retain personal information only as long as required for the purposes for which it was collected, as well as to meet legal, tax or accounting requirements, or to comply with applicable requirements of the Law, even after our business relationship with you has ended.  Thereafter, personal information is either destroyed or anonymized in compliance with relevant regulations to ensure that it can no longer be used to identify you.

When the time comes to destroy your personal information, we take the necessary steps to ensure its confidentiality and that no unauthorized person can access it during the destruction process.

PROTECTION OF PERSONAL INFORMATION

Your personal information is kept in the strictest confidence. We maintain physical, electronic and procedural safeguards to protect your information against unauthorized access, loss or destruction.

Only employees who need access to your personal information in the course of their duties have access to it in order to provide you with the products and services requested.  All our employees receive periodic training on information security, privacy and their code of conduct.

YOUR RIGHTS

In accordance with the Law, you have several rights regarding your personal information, including:

• The right to access your personal information;
• The right to rectification of any inaccurate data;
• The right to request the deletion of personal information under specific conditions;
• The right to restrict or object to the processing of your personal information;
• The right to portability of personal information, where applicable.

If you wish to exercise these rights, or if you have any questions about the protection of your personal information, please contact the Privacy Officer at the contact information below.

INTERNET

Like other modes of communication, unprotected email messages run the risk of being lost, altered, modified, and even intercepted.  We will not be liable to you or anyone else for any damages resulting from your electronic transmission of a message to a Group company or from us to you. We remind you that you can use other secure means of communication to send us your personal information when you deem it necessary.

COOKIE 

Group uses cookies to improve its websites (the “Websites”) and your browsing experience. Cookies are small text files that are stored by the browser and filed on the terminal device. They do not cause any harm on the terminal device and do not contain any viruses.

We can only store cookies on your device if they are strictly necessary for the operation of the Websites. For all other types of cookies, we need your permission. At any time, you can change or withdraw your consent regarding the use of cookies. You can also delete the cookies at any time in the security settings of your browser. Please note, however, that you may not be able to use all the functionalities of the Websites.

The Websites use “persistent cookies” that are automatically deleted after a predetermined period, which may differ, depending on the cookie. It also uses “third-party cookies” that are placed by third-party providers, for example, for the tracking of websites statistics.

Strictly Necessary Cookies 
Strictly necessary cookies enable basic website functionalities such as user login and account management. The website cannot be used properly without strictly necessary cookies.

1. Cookie name: USE_COOKIE_CONSENT_STATE
   Provider: Optimum Group
   Expiry: 6 months
   Purpose: Used to store whether a user has consented to the activation/deactivation of the web tracking. In case of deactivation, no web tracking takes place.
2. Cookie name: _GRECAPTCHA
   Provider: Google
   Expiry: 6 months
   Purpose: Google reCAPTCHA sets a necessary cookie when it is executed for the purpose of providing its risk analysis.

Statistic Cookies 
Statistic cookies are used to see how visitors use the website, such as analytics cookies. These cookies cannot be used to directly identify a specific visitor.

1. Cookie name: _GA
   Provider: Google
   Expiry: 2 years
   Purpose: Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit.
2. Cookie name: _GA_<CONTAINER-ID>
   Provider: Google
   Expiry: 2 years
   Purpose: Used to persist the state of the session.
3. Cookie name: _GA_(MEASUREMENT ID)
   Provider: Google
   Expiry: 2 years
   Purpose: Used to store the anonymized user so that Google Analytics can recognize the user as a returning user.

Preference Cookies 
Preference cookies are used to remember information that changes the way websites behave or look, like your preferred language or the region that you are in.

We do not currently use Preference Cookies.

Marketing Cookies 
Marketing cookies are used to track visitors across websites to display relevant and engaging ads for the individual user. They are valuable for publishers and third-party advertisers.

1. Cookie name: YSC
   Provider: YouTube
   Expiry: session
   Purpose: YouTube sets this cookie to track the views of embedded videos on YouTube pages.
2. Cookie name: VISITOR_INFO1_LIVE
   Provider: YouTube
   Expiry: 6 months
   Purpose: YouTube sets this cookie to measure bandwidth, determine whether the user gets the new or old player interface.

WITHDRAWAL OF CONSENT

Subject to any legal requirements or contractual constraints, you may change or withdraw your consent to the collection, use, storage and disclosure of your personal information at any time by contacting us in writing.

Please note, however, that by withdrawing your consent, we may no longer be able to provide you with our products and services or offer you certain benefits or discounts. 

ACCURACY AND ACCESSIBILITY

We make every effort to ensure that your personal information is accurate, complete and up to date for the purposes for which it was collected, used, retained or disclosed.

Upon request, we will provide you with access to the personal information we have on file. You may also ask us how this information is used, ensure that it is accurate and complete, and have it updated as necessary, to the extent permitted by Law.  Any request for modification will be processed within a reasonable time.

PRIVACY OFFICER

Any request for access or to amend your personal information may be sent in writing to the address below: 

Privacy officer
Legal Department
Optimum Group
425 de Maisonneuve Blvd West
Suite 1700
Montréal (Québec) H3A 3G5, CANADA

Email : [email protected]   

Please include in your request your name and contact information, the nature of your request, the name of the department or person with whom you have already communicated, and any other relevant information.

You can also contact the competent privacy agency in your jurisdiction of residence.

PERSONAL INFORMATION COMPLAINT PROCESS

Any complaint regarding non-compliance with this notice must be addressed to the Privacy Officer, whose contact information can be found above. The complaint handling process remains confidential at all times.

UPDATE OF THIS PRIVACY NOTICE

Any additions, modifications, or deletions to this notice that we deem appropriate will be incorporated immediately.