Privacy policy

SAGE Insurance and group retirement's Privacy Policy

1. PURPOSE OF THE POLICY

At SAGE Insurance and group retirement, we are committed to protecting the privacy of our clients, employees, and representatives, as well as ensuring the confidentiality of personal information entrusted to us as part of our business activities.

Our Privacy Policy not only meets the requirements of the Personal Information Protection Act in the private sector, but it also describes our standards for the collection, use, disclosure, and retention of your personal information. This policy further explains how we protect your personal information and your right to access it.

This document is continually updated to ensure that you are informed of changes to our privacy practices, as well as to unify these practices and comply with applicable laws. We encourage you to review this policy regularly to stay up to date with updates.

2. SCOPE

In line with industry best practices, SAGE Insurance and group retirement affirms its commitment to comply with privacy laws and regulations and to protect all confidential information it holds. All employees of SAGE Insurance and group retirement who collect, use, or disclose personal information are required to follow this policy.

SAGE Insurance and group retirement's responsibility for the protection of personal information also extends to its agents, service providers, and partners, who must offer the same level of protection for your personal information.

3. PERSONAL INFORMATION

Personal information refers to any information about an individual that can identify them, such as financial, lifestyle, or health information. This information is confidential and cannot be disclosed without the consent of the individual concerned.

Personal information must be protected, regardless of its form or medium, whether written, graphical, audio, visual, computerized, or other.

4. PURPOSES OF INFORMATION COLLECTION

SAGE Insurance and group retirement collects personal information to provide you with high-quality services. The nature and sensitivity of the information we collect about you depend on the services we provide and the legal requirements we must comply with (such as your social insurance number if a product generates investment income).

Typically, the purposes for which we collect information are to provide the products or services you requested, confirm your identity, prevent fraud, or resolve issues related to our relationship.

The purposes for which we collect your personal information are determined before or at the time of collection. For example, information is collected when you submit a proposal, open an account, or file a claim.

If you have any questions or comments regarding the purposes for which we collect certain information, please contact us at the address below:

SAGE Insurance and group retirement, mutual insurance company
2500 rue Beaurevoir Entry A Office 350
Québec (Québec) G2C 0M4
Office 418-622-8550 | Toll-free 1 877-622-8550
info@sagedecision.com
sagedecision.com

5. CONSENT

When we collect personal information about you, we obtain your consent to use it for the purposes for which it was collected. SAGE Insurance and group retirement must obtain your consent to use your information for other purposes or to collect additional information about you.

Generally, we request your explicit written consent to collect, use, or disclose your personal information.

For less sensitive information, we may, in some cases, accept verbal consent. Occasionally, we may infer your implicit consent based on your actions or lack of actions.

Consent must be provided by you or by a duly authorized person, such as a guardian or representative.

You may withdraw your consent at any time, subject to legal or contractual restrictions. For example, your right to withdraw consent is limited if we need information to grant you a loan against a policy issued by us. We will inform you of the consequences of withdrawing your consent, including the possibility that we may be unable to provide a product or process your request. If you choose to withdraw your consent, we will record this in our files. Additionally, we ensure that the records we hold are up-to-date and accurate when used.

In certain situations, we may be required or authorized to collect, use, or disclose personal information without your consent. This may occur for legal, medical, or security reasons, where obtaining consent is difficult or impossible. For example, when information is collected to investigate a potential breach of contract, prevent or detect fraud, or enforce the law, obtaining consent may undermine the purpose of the information collection. In some cases, obtaining consent may be impractical if you are a minor, seriously ill, or incapacitated.

6. LIMITATION OF COLLECTION, USE, AND DISCLOSURE

We limit the collection of your personal information to what is necessary for the purposes that were explained to you. We collect personal information directly from you, unless you have consented to us collecting this information from third parties or the law allows us to do so.

We use your personal information only for the purposes for which it was collected. This means that we cannot use your personal information for any other purpose without your consent, except as required by law.

When necessary, with your consent or if permitted by law, we may disclose your personal information to authorized third parties for the proper management of your contract or to meet regulatory and/or legal requirements, including:

Your insurance representative
Any relevant reinsurer
Service providers and agents who need the information to carry out their contracts or mandates
Legal or judicial authorities when required by law, for example, in cases of fraud or criminal activity.

Despite the above, your personal information is only accessible to authorized individuals who require access to it in the course of their duties.

You have the right to know, upon request, to whom your information has been disclosed. We will only refuse to disclose this information in exceptional cases, and in compliance with the law. We maintain accurate records of who we have disclosed your information to and the reasons for the disclosure.

We may, in certain circumstances, use service providers outside Canada, including in the United States. We are responsible for ensuring that the service provider complies with our privacy protection policy and that their level of protection is comparable to ours.

7. RETENTION

We retain your personal information as long as necessary for the purposes for which it was collected. We must destroy this information in accordance with the law. At all times, employees take reasonable security measures to protect the personal information collected, used, disclosed, retained, or destroyed, considering the sensitivity, purpose, quantity, distribution, and medium of the information.

When we destroy your personal information, we take the necessary steps to ensure its confidentiality and to prevent unauthorized persons from accessing it during the destruction process.

8. USE OF PERSONAL INFORMATION FOR PROMOTIONAL PURPOSES

To offer you products and services that may meet your needs, provide you with exclusive offers and advice, and better serve you, SAGE Insurance and group retirement may use the contact information you have provided (e.g., name, address, phone number, email address) to contact you. SAGE Insurance and group retirement may also share its client contact lists with other companies within the SAGE Insurance and group retirement group. You may opt-out at any time by contacting us. This does not include communications about the product you hold or administrative communications necessary for managing your file.

To meet legal requirements, we must obtain your consent for SAGE Insurance and group retirement companies to use and share your personal information for promotional purposes within the group, to the extent of your expectations. Your information will be used to provide a personalized experience and to send you information, offers, and advice based on your personal situation and interests.

SAGE Insurance and group retirement will not share your information with other companies unless we have obtained your prior consent or unless required by law.

We will never use sensitive personal information, such as your health status, for promotional purposes without obtaining your specific prior consent.

You may at any time request that we stop using or sharing your personal information within the SAGE Insurance and group retirement companies for promotional purposes by sending a written request to the person responsible for privacy protection at the address and contact details provided at the end of this document.

If you do not consent to the collection, use, and sharing of your personal information, we may not be able to provide you with the requested products and services at the level you expect.

Please note that we do not sell our client lists to third parties.

9. ACCURACY AND ACCOUNTABILITY

We take all reasonable steps to ensure that your personal information is as accurate and complete as required for the purposes for which it was collected, used, or disclosed.

We are responsible for the personal information we hold or have custody of, including the information we entrust to third parties for processing. We require these third parties to maintain the confidentiality and security of this information.

We adhere to the principles outlined in the law and the rules we have established for protecting your privacy, including those set out in this privacy policy, our code of ethics (which applies to directors, officers, and employees), industry guidelines, and other applicable laws.

Our staff is informed and adequately trained on our policies and practices regarding personal information protection.

10. SECURITY MEASURES

We have implemented and continue to develop rigorous security measures to ensure that your personal information remains strictly confidential and protected from loss or theft, as well as from unauthorized access, disclosure, copying, use, or modification.

These security measures include:

Organizational measures (e.g., use of security certifications and restricted access to necessary information);
Physical measures (e.g., electronic access control to offices for employees, data backup and archiving via external systems);
Technological measures (e.g., use of passwords and encryption, frequent password changes, use of firewalls, and segmented access).

We recommend using strong and unique passwords for your online accounts and never sharing your passwords with anyone.

11. REQUEST FOR INFORMATION ACCESS AND RECTIFICATION

You have the right to know if we hold any personal information about you and to review this information. You also have the right to request details about how we collected your personal information, how it was used, and to whom it may have been disclosed.

This information will be provided to you within a reasonable time frame from the date we receive your written request.

In certain specific cases, we may refuse to provide the requested information. Exceptions to your right of access may include:

It would be extremely costly to provide the requested information;
The information refers to other individuals;
The information cannot be disclosed for legal, security, or commercial reasons;
The information was obtained as part of an investigation into a potential breach of contract or to prevent or detect fraud;
The information is protected by legal privilege or litigation privilege.

When we hold medical information about you, we may refuse to disclose it directly to you and instead ask that it be shared with a healthcare professional you designate to provide it to you.

You may verify the accuracy and completeness of your personal information and, if necessary, request its rectification. We will respond to any request for rectification within a reasonable time. Any request for information access must be submitted to the address provided at the end of this document.

12. SECURITY INCIDENT

In the event of a security incident involving personal information, SAGE Insurance and group retirement's compliance department will file an internal report on the incident (inspired by the report available on the Quebec Access to Information Commission's website).

Following this report, senior management will evaluate whether the nature of the incident requires a notification to the provincial or federal privacy protection authority.

13. LIMITATION OF LIABILITY

The use of technologies such as the Internet involves significant risks. Therefore, it is impossible to guarantee that the personal information you provide will be completely secure. However, rest assured that SAGE Insurance and group retirement takes all reasonable measures to protect your data.

Consequently, you acknowledge that SAGE Insurance and group retirement and its suppliers cannot be held responsible for any damages or harm arising directly or indirectly from a breach of confidentiality of data and/or information transmitted via the Internet to SAGE Insurance and group retirement.

14. TRANSPARENCY, CONCERNS, AND COMPLAINTS

Our employees can address your questions and concerns regarding the protection of your personal information.

To review your file, to file a complaint regarding non-compliance with personal information processing procedures, or to obtain more information about the Privacy Policy, please contact us.