Our Privacy Statement and Commitment
HUB International Limited values your business and we thank you for your confidence in choosing our firm as your source of advice and products. As our client, you trust us with your personal information. We respect that trust and want you to be aware of our commitment to protect the information you share in the course of doing business with us. This document outlines our practice with respect to the collection, use and disclosure of your personal information.
What we will not do with your information
We do not sell or share client information with organizations outside of our relationship with you that would use it to contact you about their own products or services.
HUB International Canadian Privacy Statement
The subsidiaries and operating divisions of Hub International listed below (collectively “Hub”, “we”, “us” or “our”) take steps intended to meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this statement is to inform our customers and other individuals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This Privacy Statement applies to our collection, use and disclosure of personal information in Canada. This Privacy Statement does not apply to information about our employees or to information that is not personal information.
Hub Entities Providing this Privacy Statement We are providing this Privacy Statement on behalf of Hub’s Canadian entities and operating divisions, including those listed below:
- Beacon Underwriting Ltd.
- Cross Border Underwriting Services Inc.
- Daystar Alberta Financial Inc.
- Gamble & Associates Insurance Limited
- Groupe Gestionnaire Assurances Totten Ltée
- HKMB Capital Solutions Corp.
- Horizon Insurance Life Inc.
- Hub Capital Inc.
- Hub Financial Inc.
- Hub International Atlantic Limited
- Hub International Barton Insurance Brokers
- Hub International Canada West ULC
- Hub International HKMB Limited
- Hub International Insurance Brokers
- Hub International Manitoba Limited
- Hub International Ontario Limited
- Hub International Quebec Limited
- Hub International (Brentwood) Ltd.
- Hub International (Richmond Auto Mall) Ltd.
- Hub International Sinclair Cockburn Limited
- National Brokerage Services S.C.N.
- Progressive Home Warranty Ltd.
- Strata Benefits Consulting Inc.
- Totten Insurance Group Inc.
We Collect Hub and its agents and representatives collect personal information in a number of circumstances in the course of conducting our business. Personal information we may collect includes:
- name, address, email address, telephone number, and other contact information;
- age, birth date, social insurance number, ID numbers, gender, credit card numbers or license plate numbers;
- information about your preferences, income, assets or personal finances;
- medical records, credit records, loan records, driving record, employment records, insurance or transaction history;
- information about your insurance claims or claims history; and
- such other information we may collect with your consent or as permitted or required by law.
We generally collect personal information directly from you, for example, from application forms that you fill out for our insurance products and services, or when you communicate with us by telephone, email or in person. We may also collect personal information about you from other sources, such as other insurance brokers, insurance companies, consumer reporting agencies, industry associations and data banks, investment product suppliers, marketing agencies, government agencies, claims adjusters, employers and inspectors.
Use of Personal Information
Hub generally uses personal information to manage and administer our business, including to understand your insurance needs, communicate with you effectively and to provide you with the products and services you request. For example, Hub may use your personal information to:
- determine your eligibility for, offer and/or provide you with insurance products and services that you request; HUB International Canadian Privacy Statement Page 2 November 2015
- evaluate credit worthiness and monitor, collect premiums and fees;
- verify your identity;
- determine prices, fees and premiums including by evaluating your coverage needs and assessing risk;
- maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services;
- update credit bureau reports
- investigate and settle claims;
- determine your eligibility for and offer and provide other products or services that may be of interest to you, such as investment or retirement products or group benefits, unless you ask us not to;
- detect and protect against error or fraud;
- compile statistics and conduct market research;
- maintain business records for reasonable periods;
- meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and
- otherwise with consent or as permitted or required by law.
Disclosure of Your Personal Information
As necessary to carry out the purposes for which Hub collects and uses your personal information, Hub may disclose your personal information to third parties, such as other insurance brokers, insurers, consumer reporting agencies, claims adjusters, government, regulatory and self-regulatory agencies, lawyers, financial institutions, benefits providers and medical professionals, and others involved in the claims handling process in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance brokerage and insurance practices. Hub may also disclose your personal information with your consent or as permitted or required by law.
Disclosure to Affiliates. Personal information may be disclosed to our affiliates (including outside of Canada) for internal audit, management, billing or administrative purposes. We may also disclose personal information to our affiliates so that they may send you information about their products and services. However, if you do not want your personal information disclosed for these marketing purposes, you may contact us at any time as described further below.
Service Providers. Hub may transfer personal information to outside agents or service providers (including affiliates of Hub acting in this capacity) that perform services on our behalf. The services that may be performed by our agents or service providers consist of data processing, data warehousing or administrative services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Some of these service providers or affiliates may be located outside of Canada, including specifically in the United States and Brazil, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada, the United States and other foreign countries applicable to our affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.
Business Transactions. Personal information may be used by Hub and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Hub or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
- permitting those parties to determine whether to proceed or continue with the transaction; and
- fulfilling reporting, inspection or audit requirements or obligations to those parties.
Assignees or successors of Hub or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.
Hub collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection.
If you obtain insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her personal information for the purposes described above.
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. There may be consequences to failing to provide or withdrawing your consent, such as your inability to acquire or renew an insurance policy and/or cancellation of a policy. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and foreign government entities as required to comply with laws).
We take reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized employees, agents and mandataries of Hub who require access to your personal information in order to fulfil their job requirements will have access to your personal information.
Access, Correction and Contacting Us
Hub may establish and maintain a file of your personal information for the purposes described above, which will be located at the applicable Hub office set out below. Subject to applicable legal restrictions, you may request to have access to the file containing your personal information and the correction of your personal information by writing to one of the addresses below. We may take reasonable steps to verify your identity before granting access or making corrections. In addition, if you wish to make inquiries or complaints, obtain information on how to access and rectify the files held by personal information agents we consulted or have other concerns about our personal information practices (including our use of service providers located outside of Canada), you may write to one of the addresses below. Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request correctly.
Hub International Limited
300 North LaSalle Street, 17th Floor
Chicago, IL 60654
Attention: Chief Legal Officer
Privacy Statement Changes
This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of Personal Information or use of our products or services following any changes to this Privacy Statement constitutes your acceptance of any such changes. This Privacy Statement is effective as of May 1, 2012.