Privacy Policy

Our privacy policy describes in clear language how NAL Insurance Inc. (NAL) ensures the protection of the personal information you entrust to us.

Please read this document carefully, not because anything in it is hard to understand, but because we want you to know that NAL protects your personal information. As you read you will come across certain specialized words, Industry Terms. We have underlined these words and provided definitions to make sure everything is perfectly clear. Simply go to the back and look under our "Industry Terms, and what they mean".

We view our Privacy Policy as if it were an NAL product, not just a legal obligation. And as you know, we believe in superior products.

When you became an NAL customer, you shared important personal information with us. You did this so we could serve you better and knowing we would honor and respect your privacy. Your trust was not misplaced. At NAL we are committed to offering you superior products and services, so it should come as no surprise that we are also committed to meeting the privacy standards applicable to you.

What is "personal information"?
"Personal information" is information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

What information are we responsible for protecting?
NAL is responsible for protecting your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third party in the course of commercial activities for processing or other purposes for which you have consented.

Collecting, using and disclosing your personal information. Why do we do it?
We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your insurance and financial needs, communicate effectively with you and provide you with the services and products you need and want.

More specifically, we collect, use and disclose your personal information to:

• Verify your identity;
• Determine your eligibility for NAL insurance products and services and for products and services that may be of interest to you and to offer these products and services to you;
• Assess and underwrite insurance risks;
• Determine prices, fees and premiums;
• Investigate and settle claims;
• Detect and prevent fraud;
• Compile statistics, conduct market research and report to regulatory and industry agencies;
• Comply with the law; and
• Comply with tax requirements.

 

Personal information may be collected, used or disclosed for any of the "Identified Purposes" set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you.

How do we gather your personal information?
The collection, use and disclosure of your personal information depend on how you do business with us. We may gather information from the following sources:

• From you, on applications for our insurance products and services, or on other forms filled out through telephone, e-mail or face-to-face interviews;
• From licensed agents, insurance brokers, intermediaries and service representatives with whom you have a relationship, as well as adjusters and inspectors;
• From your interactions with us; for example through your underwriting;
• From government and other entities; for example your driving record.

 

What you are committing to when you share personal information with us.
If you provide personal information to us or through any of the previously mention sources, you do so with the understanding that your personal information may be used or disclosed for the Identified Purposes.

Your consent
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation or in situations otherwise permitted by law. If any of the personal information that we collect is sensitive, such as health information, we will obtain additional written or oral consent from you before collecting or disclosing the information.

How do you provide us with your consent?
We accept any of the following as your consent for NAL's existing use and future collection, use and disclosure of your personal information for the Identified Purposes:

• Your receipt of this Privacy Policy, unless you advice NAL in writing that you do not agree with the terms stated in this Policy and that you wish to opt out of all or portions of it;
• Your unrestricted provision of information to NAL, either directly or through licensed agents, insurance brokers, adjusters or service representatives;
• Your express written consent as obtained through an application process; or
• Your consent as provided by your authorized representative, such as a legal guardian or power of attorney.

 

In some circumstance, your consent may be implied. For instance:

• If you obtain insurance for your family, or anyone else, you represent that you have obtained from them, even though they might not be present during the application process, their consent to the collection, use and disclosure of their personal information for the Identified Purposes.
• If you have an existing insurance policy with us and you request amendments to the policy, it is assumed that the consent that you gave us when buying the original policy remains in effect.

 

You have the power to say no. How you can withdraw your consent.
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive. To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed.

How long do we keep your personal information?
Your personal information is retained only as long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. NAL shall use care when storing or destroying you personal information in order to prevent unauthorized access.

How do we protect your personal information?
Whether in electronic or paper-based format, NAL maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information we take as much care to destroy it as we do when storing it.

In the event that we transfer your personal information to a third party (for example settling claims), we contractually require any person or organization providing products and services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.

Your right to access your personal information
You have a right to access your personal information that we have in our possession or control. You also have a right to know which third parties have received your information from NAL.

Please make your request in writing to NAL's Privacy Officer, stating as specifically as possible which personal information you are requesting. We will try to respond to such requests as soon as possible and will advise you if for some reason we cannot respond right away. NAL may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.

In providing you with a list of the organizations to whom we have disclosed any of your information, we will try to be as precise as possible. When it is not possible to provide an exact list of such organizations to which we have actually disclosed your personal information, NAL shall provide a list of organizations to which we may have disclosed the information.

NAL has the right to refuse your request for access to personal information if:

• The information is protected by solicitor-client privilege;
• Granting access would reveal confidential commercial information;
• Doing so would reasonably be expected to threaten the life or security of another individual;
• The information was collected for purposes related to the detection and prevention of fraud;
• The information was generated in the course of a formal dispute resolution process; or
• The information would likely reveal personal information about another individual.

Keeping your information accurate
NAL strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. NAL shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavour to advise other parties having access to the information in question.

How to contact us
For more information, to file a complaint, to make inquiries, or to opt out of all or parts of this Policy, please contact:

NAL Privacy Officer
Address	210-700 Richmond Street
	London, Ontario
	N6A 5C7
	P.O. Box 2880
	London, Ontario
	N6A 4H9
Telephone	1 888 NAL-PATH (625-7284)
Fax	519 434-5220
E-mail	privacy@nalinsurance.com
Website	www.nalinsurance.com

If you have a complaint related to this Privacy Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the necessary steps to resolve the issue, including amending our Policy and practices, if necessary.

If we are not able to resolve your concern, or if you have other concerns about NAL's Privacy Policy and procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial Privacy Commissioner. NAL's Privacy Office will provide you with the contact information upon request.

Industry Terms and their definitions

Adjuster	a representative of an insurance company who is authorized to investigate claims
Power of attorney	the authority given to one person or corporation to act on behalf of another person or corporation in legal and financial matters
Underwrite	to determine on what terms the insurance company will provide insurance

About this document
This Privacy Policy spells out the responsibilities of NAL Insurance Inc. ("NAL", "we", "our", "us") and your rights as our applicant, customer, former customer or claimant ("you" or "your") regarding the collection, use and disclosure of your personal information. This Privacy Policy is subject to amendments that will be posted on NAL's website, www.nal-path.com.