YOUR PRIVACY. WE’RE COMMITTED.

Protecting the confidentiality of your personal information is an important part of what we do at The Commonwell Mutual Insurance Group. Helping you find the perfect policy to fit your life, with all of its little differences, is one thing. It’s the start of everything. Ensuring your privacy is a focus too, from that start, through to processing a claim. To do that, we’ve adopted a privacy code in following with the IBC (Insurance Bureau of Canada) model. This code sets out how and why we collect and use personal information about our customers. It also explains the circumstances under which we may need or be required to disclose it.

The Commonwell Mutual Insurance Group
Privacy Statement

The Commonwell Mutual Insurance Group (“Commonwell”, the “Company” or “we”) is a mutual insurance company, incorporated under the laws of Ontario and owned by its policyholders. We offer property, liability, automobile, farm and marine insurance in Ontario. In the course of its activities, the Company receives personal information. This Privacy Statement explains how Commonwell processes the information you share in doing business with the Company and how you may obtain further details about our management of personal information.

The Company is subject to the Personal Information Protection and Electronic Documents Act. For the purposes of this Statement, “Personal Information” means any information about an individual that is, or can reasonably be, associated with that individual.

The Personal Information We Collect

Commonwell collects information, including Personal Information, from prospective or current policyholders (individuals and sole proprietorships), Commonwell also collects information, including Personal Information, from prospective or current brokers and agents as well as third party service providers.

For prospective and current policyholders, such information collection occurs at initial quotation, renewal and, if necessary, where policy amendments are requested. This information consists of application/renewal or policy change information as well as claim information:

APPLICATION/RENEWAL INFORMATION

• Property insurance and farm insurance: name, mailing address, telephone number, date of birth, property address and coverage information, banking or credit card information (for payment purposes) and consumer credit reporting information. Additional information is collected for farm insurance purposes but such information relates to farm business operation only.
• Automobile insurance: name, mailing address, telephone number, household and driver information, date of birth, vehicle and coverage information, banking or credit card information (for payment purposes) and Registry of Motor Vehicle information (e.g. vehicle ownership records; driving history records; records regarding the identity or existence of lienholders, leaseholders, and mortgage holders).
• Marine insurance: name, mailing address, telephone number, date of birth, boat and coverage information and banking or credit card information (for payment purposes).
• Liability insurance (builder’s risk and commercial general liability): name, mailing and risk location address(es), banking or credit information (for payment purposes), type of operation, number of employees, business revenue.

CLAIMS INFORMATION

• Claims information generally consists of identifying information of the claimant/policyholder along with information about the claim or accident, information about the occupants of the other vehicle(s)/boats (if applicable) and the names of witnesses and their contact information. Information on the claimant/policyholder/third party includes drivers licence numbers, social insurance numbers and information income information to allow for the determination of the amounts of income replacement and other benefits payable under the policy or for a Third Party.
• For accident benefit claims, medical information and employment information is also collected.

For brokerage applications (partnerships or proprietorships), Commonwell collects name, mailing and location address(es), telephone number, Internet address, brokerage licence number(s), years of experience, banking information (for payment purposes) and E&O insurance information.

For third party service providers who are individuals, Commonwell generally collects contact and banking information to facilitate the procurement and provision of, as well as payment for, services to Commonwell.

Commonwell operates a community grants program – C.A.R.E. (Create a Ripple Effect) – and may collect name and address information from individuals making applications on behalf of community groups.

Commonwell periodically holds events and may collect contact information (name, email address & phone number) at such events.

How Commonwell Uses Personal Information

The personal information collected by Commonwell is used to:

• Communicate with prospective and current policyholders, agents and brokers, which includes responding to enquiries and soliciting feedback on service.
• Assess insurance applications, including the underwriting and pricing of policies.
• Confirm information provided by prospective and current policyholders, agents and brokers.
• Administer insurance policies, including the processing of payments.
• Evaluate, process and settle claims.
• Assess information from prospective agents or brokers.
• Evaluate applications for funding and process grants through Commonwell’s C.A.R.E. (Create a Ripple Effect) Program.
• Investigate, detect, prevent and, if necessary, prosecute fraud.
• Administer our business operations.
• Maintain information security.
• Analyze risk and business results.
• Analyze marketing and communications needs and results.
• Provide accurate pricing tools for agents or brokers.
• Provide educational opportunities for agents or brokers.
• Meet our responsibilities to regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities.
  Achieve a specific purpose where we have obtained appropriate consent to collect or use your information for that purpose.

Where Commonwell collects Personal Health Information, as that term is defined in law – whether directly (from you) or indirectly (from a third party) – such information is used for the management of a claim. Commonwell does not use Personal Health Information for any purpose other than in connection to a claim made by you.

We may occasionally use your personal information to tell you about other services and products, tools or opportunities that we believe may be of interest to you. If you would rather not receive this type of communication, please let us know through our Privacy Officer as indicated below.

How Commonwell Shares Personal Information

Commonwell, in the course of conducting its business activities, may share Personal Information with:

• Other insurance companies.
• Consumer reporting agencies.
• Insurance industry databanks.
• Vehicle history databanks.
• Government bodies.
• Benefit providers, contractors, and repair services.
• Adjusting, claims support, and legal service providers.
• Law enforcement agencies and/or bodies.
• Information technology support service providers.
• Payment processing providers.

Commonwell does not sell customer information to anyone. We only disclose such Personal Information as is necessary for the purpose of the disclosure. In the event of a legal requirement to disclose Personal Information, Commonwell will disclose Personal Information only when and to the extent legally required.

Our Use of Internet Technology

Cookies. Our site may use cookies, which are small text files stored on your computer or device when users access a website. We use cookies to remember you and your preferences and help us understand how users engage with our sites. By continuing to use our site, you consent to the placement of relevant cookies on your computer or device. For example, when you interact with our website, we will receive technical information such as your internet protocol address, your computer’s operating system and browser type, the address of a referring website, if any, the path you take through our web pages, and system activities.
Commonwell uses this information to understand usage on our site, determine any difficulties users have with our sites, and tell us whether our communication efforts are effective. For further details, please see our Cookies Policy at https://thecommonwell.ca/privacy-policy/.

Consent

Consent. Unless permitted by law, Commonwell will not collect Personal Information without first obtaining your consent. In the event the Company wants to use the information for a new or different purpose and believes consent is required, we will seek your further consent to use and disclose your personal information.

Commonwell will usually seek your express consent. However, there may be situations where your consent is implied by your actions. For example, by providing your contact information to us at a Company event. By providing your Personal Information to Commonwell in any manner, you agree that we may collect, use, disclose or otherwise process your personal information in accordance with this Privacy Statement.

Withdrawing Your Consent. Generally, you may withdraw your consent to our use of your Personal Information. If you do so, this may prevent Commonwell from providing you with information or our products or services. If you withdraw your consent, we will inform you of any consequences in doing so. Please note that, depending on the product or service, there may be circumstances where you cannot withdraw your consent because of legal, regulatory or contractual requirements. To withdraw your consent, you can contact us as described below in “Answering Your Privacy Questions”.
Please note that Canadian law permits or requires the use or disclosure of Personal Information without consent in specific circumstances. These circumstances include situations when required by law or necessary to protect the Company, our employees or others. Should Commonwell believe it appropriate to disclose Personal Information without consent, it will limit the disclosure of information to what is necessary.

Safeguards, Accuracy & Retention

How We Protect Your Information. Commonwell endeavours to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information in our custody. Our safeguards also apply to our disposal or destruction of such information.

We also endeavour to ensure that any Personal Information in our custody is as accurate, current and complete as necessary for the purposes for which the Company uses that information.

Where We Keep Your Information. Personal Information may be used, accessed, or stored in servers outside of Canada, including in the United States. Where Personal Information is located outside of Canada, it is subject to the laws of that jurisdiction.

How Long We Keep Your Information. Commonwell retains and destroys your Personal Information in accordance with federal and provincial laws. Depending on the nature of the information and the purpose for which it was collected, this length of time may vary.

Access

Commonwell provides a reasonable right of access and correction and will endeavour to provide the personal information in question within a reasonable time. You may be asked for identification so that we may verify your identity before providing you with your personal information. If you require the documents in an alternative format, the Company will make reasonable efforts to provide you with your personal information in that format. If there will be charges for us to retrieve and provide you with specific information that you have requested, we will advise you of the charges and obtain your authorization before proceeding.

We may decline access to Personal Information in certain circumstances. These include where the information requested would reveal confidential information or personal information about someone else or if we are permitted or prohibited by legal requirements from disclosing such information.

Answering your Privacy Questions

If you have any questions or concerns about how Commonwell manages or uses your Personal Information, please contact Commonwell’s Privacy Officer:

By email
privacyoffice@thecommonwell.ca

By mail
The Commonwell Mutual Insurance Group
Attn: Privacy Office
336 Angeline Street South,
Lindsay, ON
K9V 0J8

By telephone
Phone: 705-324-2146
Toll Free: 1-855-436-5883

If the Company is unable to resolve a particular matter to your satisfaction, you may bring it to the attention of the Office of the Privacy Commissioner of Canada. 

Specific to our use of Google Analytics:

1. We may use Google Advertising Features. This allows us to better track, understand and change our content to better suit the interests of our site visitors, policyholders and brokers alike. These Advertising Features require Google Analytics to collect data via advertising cookies and identifiers. The Features that we may employ are:
   • Remarketing with Google Analytics
   • Google Display Network Impression Reporting
   • Google Analytics Demographics and Interest Reporting
   • Integrated services that require Google Analytics to collect data via advertising cookies and identifiers
2. We may use Google UserID also. This adheres to the secured Broker Site within thecommonwell.ca. It allows us to track who is logging into the broker portion of our site but nothing personally identifiable is uploaded to Google with this tool.

We assume your implied consent for the collection, use and disclosure of this information in an appropriate manner for all of the above reasons. See ‘Your privacy choices’ below for further information.

What we will not do with your information:

We do not upload any data that allows Google to personally identify you as an individual. That sort of data includes your name, email address, or any similar information that is clearly a marker of you and you alone. We also don’t share data that permanently identifies a particular device.

We do not sell customer information to anyone. Nor do we share customer information with organizations other than our affiliates that would use it to contact you about their own products or services, as mentioned above in ‘How we collect, use and disclose your information’.

Protection of your personal information:

All personal information is safeguarded with appropriate security measures.

Your privacy choices:

Your information, your choice. If you don’t wish for your data to be collected with the Google Analytics features that we use at The Commonwell, you can install the Google Analytics opt-out browser add-on. The add-on instructs the Google Analytics script running on websites to prohibit sending information to Google Analytics. To opt-out of Analytics for the web, visit Google Analytics’ opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser. Or read more about the Google Analytics opt-out browser.

We may occasionally use your personal information to tell you about other services and products, tools or opportunities that we believe may be of interest to you. If you would rather not receive this type of communication, please let us know through our Privacy Officer at our corporate office.

If you need more information:

For more specific information about our privacy code, contact our Privacy Officer at our corporate office.

Cookie Policy

Any cookies used on the Website of The Commonwell Mutual Insurance Group and its affiliates (collectively, “The Commonwell”) will not contain personally identifiable information about you. The cookies that we use may fall in 3 category types, namely, (i) Session Cookies (ii) Persistent Cookies and (iii) Third-Party Cookies.

Session cookies remain in your website during your browsing session of The Commonwell website. Session cookies are not stored on your computer and they expire when you terminate your browser session. Session cookies enables you to carry information across pages of our site and avoid having to re-enter information.

Persistent Cookies are used to help us recognise you as a unique visitor (using a number, you cannot be identified personally) when you return to our website. It allows us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly. And also, to compile statistics (done anonymously) that allows The Commonwell to understand how users use our site and to help us improve the structure of our website.

Third-Party cookies enable The Commonwell to recognize repeat visitors to the Website by matching an anonymous, randomly generated identifier that cannot identify you personally. We are able to record specific browsing information such as how you arrive at the Website, the pages you view, options you select, and the path you take through the site. With these types of monitoring parameters, we’re able to make improvements to our Website so that we can serve you better.

Pixel-Tags: We may also use “pixel tags,” that enables us to monitor the use of our websites by using small graphic files. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL (Uniform Resource Locator) of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, we may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our e-mail. 

General Terms of Use:

By using this website, you acknowledge and accept the following terms and conditions of use without limitation or qualification. You should review these terms and conditions regularly. These conditions may be revised at any time by updating this posting. Please read these conditions carefully before using this website. You agree to review these terms of use on a regular basis and agree to be bound by any changes made to these terms of use.

DISCLAIMER All the materials and information on this website are provided as is and without warranties of any kind, either expressed or implied. The Commonwell Mutual Insurance Group and its affiliates (collectively, “The Commonwell”) disclaim all warranties, expressed or implied, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose OR NON-INFRINGEMENT.

The Commonwell shall not be liable (whether in negligence or otherwise) to any person for any error, omission or incompleteness in the information, or reliance on the information on the website, nor shall The Commonwell be under any obligation to advise any person of any error therein. In no event shall The Commonwell be liable for any direct, indirect, incidental, consequential or special damages, losses, claims or expenses whatsoever arising out of the use of or inability to use the website or the information thereon, even if The Commonwell has been advised of the possibility of such damages. Because some jurisdictions prohibit the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you.

The information and descriptions contained herein are not necessarily intended to be complete descriptions of all applicable terms, exclusions and conditions and are provided solely for general informational purposes. Please refer to the actual policy or the relevant product or services agreement.

THIRD PARTY CONTENT
This website may be linked to other websites which are not maintained by The Commonwell. The Commonwell is not responsible for the content of such websites. The inclusion of any link to such websites does not imply The Commonwell’s approval or endorsement of such sites or the content thereof. The Commonwell cannot guarantee that the links set out on our website will be accurate at the time of your access. Moreover, the sites pointed at by links have been independently developed and possibly maintained by person(s) over whom The Commonwell has no control. The Commonwell cannot and does not monitor the sites linked to its pages on the Internet or any transmission made through the respective web pages and news groups. Accordingly, The Commonwell assumes no responsibility for the content of any site referenced to by any hyperlink or otherwise. The Commonwell believes that our making available links to publicly accessible web pages is legally permissible and consistent with the common, customary expectations of those who make use of the Internet.

LIMITATION OF LIABILITY
While The Commonwell uses reasonable efforts to include accurate and up-to-date information on this website, errors or omissions sometimes occur. To the fullest extent permissible pursuant to applicable law, The Commonwell makes no warranties or representations as to the accuracy of the content of this website and under no circumstances, including, but not limited to, negligence, shall The Commonwell or any party involved in creating, producing, or delivering this website be liable to you for any direct, incidental, consequential, indirect, or punitive damages that result from the use of, or the inability to use, the materials on this website, even if The Commonwell or a The Commonwell authorized representative has been advised of the possibility of such damages. In no event shall The Commonwell’s total liability to you for all damages, losses, and causes of action exceed the amount paid by you, if any, for accessing this website. The Commonwell also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect, your computer equipment or other property as a result of your access to, use of, or browsing in this website or your downloading of any materials, data, text, images, video, or audio from this website.

RESTRICTIONS ON USE OF MATERIALS
The Commonwell Mutual Insurance Group own’s and operates this website. No materials from this website may be copied, reproduced, republished, uploaded, posted, transmitted, or distributed in any way except as otherwise expressly permitted by The Commonwell Mutual Insurance Group. You may download material displayed on this website for your use only, provided that you also retain all copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, repost, or use the content of this website for public or commercial purposes, including the text, images, audio, and video without taking prior permission from The Commonwell. Even then The Commonwell doesn’t  warrant and/or represent that your use of materials displayed on this website will not infringe the rights of third parties.

JURISDICTIONAL ISSUES
The use and access to this Website and these terms of use are governed by the laws of the Province of Ontario and the laws of Canada applicable therein, without resort to conflict of law provisions. Any legal action or proceeding relating to your access to, or use of, this Website or these terms of use shall be instituted only in a court located in Toronto, Ontario. You and The Commonwell agree to submit to the jurisdiction of, and agree that venue is proper in, these courts in any such legal action or proceeding.

Unless otherwise expressly set forth herein, The Commonwell makes no representation that materials on this website are appropriate or available for use in any location. Those who choose to access this website do so by their own initiative and are responsible for compliance with local laws.

OWNERSHIP OF INFORMATION
Any information, other than personal data or information you transmit to The Commonwell via this website, by electronic mail or otherwise, including data, questions, comments, or suggestions, will be treated as non-confidential and non-proprietary and will become the property of The Commonwell. Such information, other than personal data or information, may be used for any purpose, including, but not limited to, reproduction, solicitations, disclosure, transmission, publication, broadcast, and posting. The Commonwell is free to use any ideas, concepts, know-how, or techniques contained in any communication you send to The Commonwell via this website or by any other means for any purpose whatsoever, including, but not limited to, developing and marketing products using such information.

Personal information submitted during the completion of an ‘Insurance IQ’ farm, commercial, seasonal, automobile, watercraft or residential quiz such as one’s name, email address and phone number will be purged from The Commonwell’s system after 60 days. When completing one such quiz, The Commonwell and its broker partners and agents will only contact you if consent is expressly granted via the ‘checkbox’ located beside the personal information fields beneath the quiz questions.

TRADEMARKS AND COPYRIGHTS
All trademarks, service marks, trade names, logos, and icons are proprietary to The Commonwell. Nothing contained on this website should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark displayed on this website without the written permission of The Commonwell. Your use of the trademarks displayed on this website, or any other content on this website, except as provided herein, is strictly prohibited. Images displayed on this website are either the property of, or used with the permission of The Commonwell. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically permitted by The Commonwell. Any unauthorized use of images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

UPDATES
The Commonwell reserves the right to change these Terms of Use in order to address future developments of The Commonwell, the website or changes in industry or legal trends.