Privacy Notice
This privacy notice explains how, and for what purposes, we, Europ Assistance S.A. Canada Branch (operating as “Europ Assistance Canada”) and our service providers and/or affiliates, as applicable to collect, use and disclose your personal information. Please read it carefully. We may amend and update this privacy notice from time to time. The most current version will be posted on our website at www.europ-assistance.ca
This privacy notice applies to the personal information of our clients or potential clients from who we collect personal information, whether directly or indirectly. It does not apply to information about our employees or to information that is not personal information.
Which legal entity will use your personal information?
Your insurer Europ Assistance Canada will collect, use, and disclose your personal information in the course of its business in Canada. Europ Assistance Canada and its affiliates, which provides emergency assistance and claims administration services related to your travel insurance, will also collect, use, and disclose your personal information.
How do we collect, use, and disclose your personal information?
We collect, use, and disclose your personal information for insurance purposes, including:
- To execute and fulfill your contract, we collect, use, and disclose your personal information to:
- underwrite insurance and manage related risks,
- perform eligibility checks,
- provide you with an insurance quote,
- process your payments,
- administer your insurance policy,
- provide you with travel insurance services,
- investigate and administer your travel insurance claims, and
- respond to your inquiries and complaints.
- To fulfil our legitimate interests, we may also collect, use and disclose your personal information to:
- perform fraud prevention and management,
- conduct and manage customer satisfaction surveys and checks, and
- continuously improve the efficiency and the rapidity of our claim management system (e.g., perform analytics, improve the user experience; debug and conduct research; provide customer service and training).
- To comply with our legal obligations, we may collect, use, and disclose your personal information to:
- fight against money laundering,
- fight against the financing of terrorism,
- comply with Canadian and international economic and financial sanctions, and
- comply with other laws applicable to us.
Why do we need your personal information?
We need your personal information to provide travel insurance services to you. If you choose not to provide us with personal information, we will not be able to go ahead with the contract and provide the relevant travel insurance services to you.
What personal information do we collect?
We only collect personal information that is strictly needed for the above purposes. In particular, we will collect:
- your name, contact details, date of birth and identification documents (for example, passport),
- your banking and/or payment details,
- your health and medical information, if applicable,
- your travel-related information, including information about other people who are travelling with you, and
- information contained in any document you provide to us to handle your claim or complaint.
Personal information does not include business contact information about an employee of an organization when that information is used to communicate with the employee about their employment, or aggregated information that is anonymized so that it cannot be associated with a specific person.
Do we collect personal information without consent?
We will only collect, use, and disclose your personal information with your consent, unless otherwise permitted by law.
Your consent may be express or, in certain conditions, implied (for example, if you request a service and then provide the personal information necessary for that service). In determining the appropriate form of consent, we will take into account the sensitivity of the personal information and your reasonable expectations. When collecting sensitive information, such as health information, we will require your express consent. Your consent may be provided directly to us by you or given by an authorized representative acting on your behalf or to a third party acting on our behalf, to be provided to us.
Do we collect personal information about you from third parties?
In most cases, we collect personal information directly from you. However, we may also collect personal information from other organizations and persons who have information about you, including licensed physicians, medical practitioners, hospital clinics or other medical or medically related facilities, other insurance companies, government health insurance plans, your travel companions, insurance agents/brokers, your travel service provider, and our service providers.
We may also collect personal information from you about other people who are travelling with you. By providing information to us about the people travelling with you, you confirm that you have the consent of those other people to the collection, use and disclosure of their personal information as outlined in this privacy notice.
Who do we share your personal information with?
We may share your personal information with other Europ Assistance and Generali Group subsidiaries and external organizations such as our auditors, reinsurers, co-insurers, claims handlers, agents, and distributors that from time to time need to provide the services covered by your policy, and other organizations that carry out technical, organizational, and operational activities supporting the insurance.
We may also disclose your personal information in connection with an actual or prospective business transaction, including a sale of Europ Assistance S.A. or any affiliate or a corporate reorganization, provided that the personal information we disclose may only be used by the other party to evaluate the possible transaction, or, on completion of any such transaction, for the purposes set out in this privacy notice.
We may also share certain relevant information about your complaint (e.g., complaint status, type, reason) with your travel services provider to the extent that such information is needed to adequately perform the contract travel services provider has with you.
How do we protect your personal information?
We have internal practices that govern the collection, use, disclosure, protection, retention, and destruction of personal information.
Personal information recorded in paper documents is securely stored in our offices in Canada or in secure off-site storage facilities in Canada. Electronically recorded information is stored on computer systems maintained by us, our affiliates, and our service providers. Your personal information may be disclosed outside of your province of residence and may be processed and stored in countries other than Canada and may be subject to the laws of those countries. For example, personal information processed or stored outside Canada may be accessible to the governments, courts, law enforcement or regulatory agencies of those countries through their local laws.
We will establish a file from which your personal information will be used to provide you with travel insurance services, and process claims. We will protect your personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction by security safeguards appropriate to the sensitivity of the information. Such controls include physical, technological, and organizational safeguards. Only our employees and contractors who need to access the information to perform their duties are granted access to your personal information, and they are required to protect the confidentiality of personal information and to comply with all applicable privacy laws.
Our contracts with our service providers require that our service providers keep all personal information confidential and secure and have privacy policies and security standards with respect to personal information that are comparable to ours.
What are your rights regarding your personal information?
You can exercise the following rights regarding your personal information:
Access – you may request access to your personal information. This includes the right to be informed of the source of any personal information about you that we collect from third parties.
Rectify – you may ask us to correct personal information that is inaccurate or incomplete.
Withdraw consent – you may ask to withdraw your consent at any time for the collection, use or disclosure of your personal information for which you have previously provided consent by giving us reasonable notice, subject to certain exceptions. If you withdraw your consent, we may be unable to continue to provide insurance services to you. You may contact us for more information regarding the implications of withdrawing consent.
You can exercise your rights by contacting our Chief Privacy Officer at:
privacycompliance@europ-assistance.ca
Subject to satisfactory proof of your identity, you will be provided with appropriate access to your personal information. In certain situations, we may not be legally permitted to provide access to all of your personal information. For example, we cannot provide access to personal information relating to other people or personal information protected by legal privilege. If we deny your request for access to your personal information, we will provide you with the reason for denying access.
You may exercise your access rights free of charge. However, we may charge a reasonable fee for copying or transmitting your personal information. We will advise you of any charges in advance.
What are your rights if we use automated decision-making processes?
To handle your claim and respond to you more rapidly, we may use a claim management system that scans and analyses the content of your claim and the supporting documents. The assessment of your claim is therefore fully automated and there is no human intervention in the decision-making process. Based on the reading and interpretation of the supporting documents you provided, the claim management system will assess whether your claim meets the terms and conditions of your policy and whether to accept or reject your claim, in full or in part.
We regularly audit our claim management system to ensure it remains fair, effective, and accurate.
In all cases, you have the right to obtain an explanation of the decision regarding your claim, challenge it and request that one of our operators reviews the decision manually. To do so, you can send an email to privacycompliance@europ-assistance.ca,as you can always do for manual claims handling.
We will also use your personal information to continuously improve the efficiency and the rapidity of our claim management system. You have the right to ask us not to use your personal information for this specific purpose.
DO WE USE YOUR PERSONAL INFORMATION TO OFFER OTHER PRODUCTS AND SERVICES?
Where the law allows it, we may use the personal information you provide to communicate with you to offer you other products and services. The collection, use and disclosure of your personal information for such marketing purposes is optional, and is not required as a condition for doing business with us. You may withdraw your consent to these optional uses at any time by contacting us at privacycompliance@europ-assistance.ca
We do not sell, trade, or disclose our customer lists for marketing purposes.
How long do we retain your personal information?
We will retain your personal information for as long as is necessary for the purposes set out above, or for as long as the law requires. Depending on the circumstances, where personal information has been used to make a decision about you, we shall retain, for a period of time that is reasonably sufficient to allow for access by you, either the actual information or the rationale for making the decision.
When personal information is no longer necessary, we destroy or anonymize such information. In view of the ongoing exposure to potential insurance claims, where necessary, some of the personal information collected for insurance purpose may be kept indefinitely.
Who do you contact with questions or complaints about our privacy practices?
If you have any questions, concerns, or complaints about our privacy practices, you can contact our Chief Privacy Officer, who is responsible for the protection of personal information, at:
Chief Privacy Officer
Europ Assistance S.A. (Canadian Branch)
privacycompliance@europ-assistance.ca
We will investigate all complaints about our privacy practices and will inform you of the outcome of the investigation regarding your complaint. If a complaint is found to be justified, we shall take appropriate measures to resolve the complaint including, if necessary, amending our policies and procedures.