The Canadian Life Insurance Standards Association (CLIEDIS)
The Canadian Life Insurance Standards Association (“CLIEDIS”, “we”, “us” or “our”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you (e.g. name, phone number, e-mail address).
1. What Personal Information do we collect?
Personal information means any information about an identifiable individual. The types of personal information that we may collect include, but is not limited to:
- personal phone numbers;
- personal addresses;
- personal e-mail addresses; and
- personal information you give us that we did not request (such as personal information you voluntarily put into an email to us).
2. Purposes for Collecting Your Personal Information
CLIEDIS collects your personal information for the following purposes:
- To support our mission to promote the advancement of data exchange within the Canadian life and health insurance industry;
- To send you invoices with respect to your membership dues;
- To provide you with information about webinars and events for which you have registered;
- To keep you well-informed of industry changes, meetings, membership-related activities and CLIEDIS initiatives;
- To respond to your questions that you send by email, by telephone or through our Site;
- To contact you with respect to any marketing and advertising of CLIEDIS, provided that you have consented to receive such commercial electronic messages or telephone calls;
- To provide you with our Services; and
- To meet any legal or regulatory requirements.
If you provide us with business contact information such as your work email address, work address or work phone number, we are permitted to and may use or disclose this information to communicate with you or facilitate communication with you in relation to your business or profession.
3. When Do We Collect Personal Information?
We may collect your personal information when you voluntarily provide it to us by using our Services. For example, we may ask you to provide personal information if you:
- send a question or comment by email to CLIEDIS or CLIEDIS staff;
- contact CLIEDIS or CLIEDIS staff by phone;
- create a membership login account on our Site; and
- otherwise participate in features of our Site that ask for personal information.
4. Limiting Collection of Personal Information
5. Use, Disclosure and Retention of Personal Information
Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws. From time to time, we may wish to use personal information for new or additional purposes, in which case we will obtain your consent to use your personal information for such new or additional purposes before doing so. We may also use and disclose your personal information to third parties under the following limited circumstances:
- when necessary to protect the safety, property or other rights of CLIEDIS, its members, its staff and users of the Site, including to detect and protect fraud;
- with your consent; or
- when otherwise required or permitted by law.
We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected and to comply with our legal obligations, after which we will dispose of the personal information in accordance with our data destruction policy.
6. Contact information of CLIEDIS Members and CLIEDIS Executive Committee Members
We may make the business contact information of our members available on our Site. If you choose to contact a CLIEDIS executive committee member or CLIEDIS member using the business contact information that we provide on our Site, we are not responsible for the protection of the personal information that you may disclose to this CLIEDIS executive committee member or CLIEDIS member on your own time.
7. Data Processors in Other Country
To provide you with our Services, we may use service providers, data processors and other third parties (“Third Parties”) to perform services on our behalf. These Third Parties may store, process and transfer personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, including the United States of America. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on personal information that are equivalent to those that apply in Canada.
8. Links to Other Sites
9. Cookies and Other Similar Technology
As you interact with this Site, we may use automatic data collection technology and services that record and collect information that identifies your computer and your login information. This data collection technology may include cookies and other similar devices on this Site to enhance functionality and navigation for our visitors.
A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a site. Being able to access our cookies allows us to improve your experience at this Site.
You can reject or disable cookies by managing your browser settings and following the directions provided in your Internet provider’s help file. Please note that if you disable cookies, you may be unable to access some customized features on this Site. Cookies do not collect or contain your personal information.
10. Google Analytics
This Site uses Google Analytics, a web analytics service of Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files stored on your computer, to analyze how you use the Site. The information generated by the cookie about your use of this Site (including your IP address) is sent to a Google server in the U.S. and stored there. Google will use this information to evaluate your use of the Site, compile reports on Site activity for the Site operators and to provide other site activity related internet services. Additionally, Google may transfer this information to a third party when required by law or in the case of a third-party processing information on Google's behalf. In no case will Google use your IP Address in connection with any other information held by Google. You can set your internet browser to prohibit the installation of cookies, although we must point out that some features and functions of the Site will then be unusable. By using this Site, you consent to the processing of data about you collected by Google in the manner described and for the above mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Given the debate concerning the use of analytical tools using full IP addresses, we wish to point out that this Site uses the "Anonymize IP" function of Google Analytics which works with a shortened form of IP addresses to avoid direct personal identification.
You can set your Internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies which are already stored on your hard disk at any time. You will find more details on how to do this in the operating guide for your Internet browser program.
We maintain security safeguards to protect your personal information against loss, theft and unauthorized access. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
We take reasonable steps to verify your identity before granting you access to your account on our Site, however, you are solely responsible for maintaining the secrecy of your username, password and any other membership account information. We also take reasonable steps to ensure that CLIEDIS staff is aware of the importance of maintaining the confidentiality of personal information and that unauthorized persons do not gain access to personal information that we have disposed of or destroyed.
12. Individual Access and Accuracy of Personal Information
You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.
You may request to update and change your personal information at the contact information set forth below. We shall endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information.
13. Children’s Privacy
We are committed to protecting the privacy of children and we do not knowingly solicit personal information from children under the age of 13. If a child has already provided us with personal information, his or her parent or guardian may contact us for the purpose of deleting this information.
14. E-mail Communications
CLIEDIS complies with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law. Our Site provides instructions to non-members as to how they may opt-in and expressly consent to receiving electronic communications. Members of CLIEIDS will also be required to opt-in and expressly consent to receiving electronic communications from CLIEDIS in compliance with CASL.
We will ensure that each e-mail includes an opt-out feature and instructions on how to un-subscribe if you no longer wish to receive future e-mails from us. You may also contact us at CLIEDIS, PO Box 87553, 300 John Street, Thornhill, ON, L3T 7R3 to stop receiving them or can unsubscribe using the link included in the e-mail or by sending an e-mail to firstname.lastname@example.org or by telephoning us at 416-830-3161. If you do not expressly consent to receiving electronic communications, we will only communicate with you for the limited purposes permitted under CASL.
Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain purposes identified herein at any time by contacting us at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that CLIEDIS may not be able to provide you with certain information which may be of value to you, such as providing you with details about events and industry changes.
17. How to Contact Us
- By email: email@example.com;
- By mail ; CLIEDIS, PO Box 87553, 300 John Street, Thornhill, ON, L3T 7R3, Attention: Chief Privacy Officer; or
- By telephone: 416-830-3161 and ask to speak with our Chief Privacy Officer.
18. Effective Date