At CAFO, privacy is protected. An important part of our commitment to service excellence is our commitment to the privacy of personal information entrusted to us.
Keeping that information in strict confidence is a cornerstone of our business. The range of products and services we offer continues to expand and the technology we use continues to change. But no matter how the business changes, we will protect the privacy of personal information.
Our policies and procedures, which we practice in order to protect this information, are in place across CAFO. In the following pages, we describe these policies and procedures.
PROTECTING PRIVACY MEANS:
Why We Need Information and How We Use It
CAFO may collect personal information when an individual finances its insurance premiums with us and enters into a Premium Installment Contract. In this policy, the words "you" and "your" refer to that individual. CAFO uses that information to carry out the functions associated with this contract. Examples of such information include:
Information we receive from you, such as your name, address, assets and income, as provided, for example, with a premium installment contract.
Information we receive from affiliates, credit reporting agencies and other third parties not affiliated with us, such as your creditworthiness and credit history.Personal information may be shared with affiliated companies or third parties who have been retained by CAFO to assist us in carrying out functions associated with your contract. The third parties with whom customer information may be shared include:
We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.
This policy applies whether your information is collected in paper, electronic or other form. CAFO does not collect any personal information from visitors browsing our website, although personal information may be requested via the website if a visitor chooses to respond to on-line surveys, send CAFO an e-mail message or use one of our website tools.
Information obtained when you finance insurance premiums and enter into a Premium Installment Contract is only disclosed to third parties with your consent.
There are some exceptions to the above rule. For example, we may collect, use and disclose information if we:
Use an outside company to process information.
At times, we may use the expertise of an outside company to do work involving some personal information. When we do, we select the company carefully and confirm that it uses standards comparable to ours.
Must disclose information for legal reasons.
We may be compelled to release information by legislation, a court of law, to a regulatory authority, or as part of a sale or reorganization of our business. If so, our policy is to release information only to the extent we have to.
Have to protect the interests of CAFO.
In certain circumstances, CAFO may have to collect, use or release information for our protection - for example, in collecting accounts or in the detection or prevention of fraud.
Where we have been appointed by you, we will only use personal information with consent.
Consent can be express or implied. Express consent can be verbal or written. For example, the Premium Installment Contract may contain a written consent for our use of your information to carry out the functions associated with your account. Or you might consent to release the information over the phone.
Consent is implied when we can reasonably conclude that you have given consent by an action you have taken or not taken, or where the context reasonably requires that we have and use information to carry out what you have asked us to do.
You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this. If you do not consent to certain uses of information or if you withdraw your consent, we may not be able to finance your insurance premiums. If so, we will explain the situation to you to help you with your decision.
WE PROTECT YOUR INFORMATION FROM ERROR, LOSS AND UNAUTHORIZED ACCESS
Our employees who have access to personal information are made aware that it is confidential. Each employee must certify annually that he or she has maintained the confidentiality of information entrusted to him or her.
Our computer security specialists build security into all our computer systems. This protects personal information while it is stored in data files and when employees are using it. Our systems also protect information when it is transmitted.
Information sent via the Internet, however, can be intercepted by a third party. It is relatively easy for a third party to intercept and read information sent via unencrypted e-mail. Where CAFO's website requests or accepts confidential information, we transmit that information with encryption.
YOUR INFORMATION IS DESTROYED WHEN IT IS NO LONGER NEEDED
We keep your information only so long as we need it for the products and services we have been hired to deliver or to meet legal requirements. We have standards that meet these requirements. We either destroy information or render it anonymous when it is no longer needed.
ACCESS TO AND ACCURACY OF PERSONAL INFORMATION
You can check your information to verify, update and correct it, and to have obsolete information removed. We will ask for the request in writing.
There is no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records or if special expense is involved in retrieving your information. We will advise of any charges in advance.
YOU CAN FIND OUT TO WHOM INFORMATION IS GIVEN
If you ask, we will let you know the names of outside companies or organizations we have given your information to. This will not include information given to outside companies used to do work for us. It also will not include disclosures to Canadian or provincial governments, and it will not include disclosures where we are prohibited by law from advising the individual of the disclosure.
WE RESPOND TO REQUESTS PROMPTLY
We will deal quickly with your request to see your information, and within 30 days. If we need to extend the time, or we have to refuse the request, we will tell you why (subject to any legal restrictions) and we will notify you of the reasons for the extension and your rights under applicable legislation with respect to the extension.
WE CORRECT THE INFORMATION
Whenever possible, we will correct any information we may have given to any other organization. If we have received the information from another party, we will let you know the name and address of the party so that you can ask them to correct it.
WE PROTECT OTHER PEOPLE'S PRIVACY WHEN WE MAKE INFORMATION AVAILABLE TO YOU
There may be files that include information about you and other people which is confidential to CAFO or our corporate clients, or which is the property of CAFO or such clients. Because we value everyone's confidentiality and legal rights we cannot make these files available outside of CAFO or our related companies. However, where we can separate your information from the information of others without affecting another's confidentiality or legal rights, we will make available to you the information contained in the files about you.
WE MONITOR OUR COMPLIANCE WITH THE CAFO PRIVACY POLICIES
We have procedures in place to assist our employees in the practice of the policies. Our internal auditors and Compliance Department monitor the adherence to these policies and report any findings to a committee of the Board of Directors of CAFO.
WE ARE COMMITTED TO UPHOLDING THE CAFO PRIVACY POLICIES
If there are any questions or complaints about our privacy policies, or about our living up to them, let us know right away.
RESOLVING CONCERNS IS IMPORTANT TO US
CAFO is committed to treating everyone with the greatest respect and consideration and to providing the highest level of service. Even so, from time to time there may be something wrong. There may be a misunderstanding, or someone may feel treated unjustly. Whatever the circumstances, our primary concern is resolving the problem.
How to Contact Us
Any questions or concerns regarding our policies or procedures on personal information can be directed to our Privacy Officer by any of the following means. We may ask for further documentation or information in order to verify your identity when you make your request.
By Mail: CAFO Privacy Officer
200 University Avenue, Suite 501
Toronto, Ontario M5H 3C6
By Phone: (416) 868-6777
By Fax: (416) 868-0125
Note: We may change this policy from time to time, and, if we do, the most current version can be obtained by contacting us as above.
USA Patriot Act Disclosure Notice
Some Premium Finance Agreements (PFAs) for insureds conducting business in the United States of America may include a “USA Patriot Act Customer Identification Program (CIP) Disclosure Notice” for compliance with U.S. Federal law (The USA Patriot Act), which requires CAFO and/or its affiliate AFCO to obtain, verify and record information about anybody, including insureds, who opens an account with AFCO/CAFO or establishes a relationship with our company. Such information may include the insured’s name, physical-location address (not merely the P.O. Box Number), Taxpayer Identification Number (TIN), Federal Employer Identification Number (FEIN), and/or Social Security Number (SSN) with date of birth for individual consumers or sole proprietors.
If this information is not provided or obtainable from readily available industry resources, there may be instances where AFCO/CAFO associates may contact insureds and/or their insurance agent directly to ensure compliance with the government-mandated requirements.