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Anti-Spam Policy

INTRODUCTION

In accordance with Canada’s Anti-Spam Legislation (CASL), Lussier Financial Services Firm Inc. (Lussier) has adopted an anti-spam policy to ensure transparent management of email addresses provided by our clients, partners, and potential clients (hereafter collectively referred to as “our audience”). This policy came into effect on July 1, 2014 and has been updated to consider the legislative restrictions of July 1, 2017.

This policy is intended to be read together with Lussier’s Confidentiality and Privacy Policy.

DEFINITIONS

For the purpose of this policy, the words and expressions below have the following meanings:

  • Spam: Unsolicited commercial electronic message.
  • Customer: An individual or company for whom Lussier holds a client file, whether as an active/inactive client or a potential client, in our internal databases.
  • Active client: A client who holds an active policy or contract with Lussier.
  • Inactive client: A client who no longer has an active policy or contract with Lussier.
  • Potential client: A client who is in "quote" or "proposal" status in our internal databases.
  • Contact: An individual or company solicited by Lussier, or with whom the firm has exchanged information, but for whom Lussier does not have a complete client file AND/OR who is not yet in "quote" or "proposal" status (memberships obtained through our website or in our social media, list provided by a partner).

TARGETED COMMUNICATIONS

The policy refers to commercial electronic messages sent by email or text message by Lussier to its audience, with the intent of encouraging participation in an unsolicited commercial activity.

For Lussier, the following communications are considered commercial electronic messages:

  • Promotional emails for a product, service, individual or contest;
  • Newsletters.

EXCLUDED COMMUNICATIONS

Transmission of the following electronic messages are authorized without obtaining consent:

a)    Emails with active clients, unless they have expressly refused;

b)    Emails between individuals with personal or family ties, regardless of the nature of the message;

c)    Email replies to requests from our audience, to the extent that they are limited to responding to same without adding promotions;

d)    Responses to complaint emails from our audience, to the extent that they are limited to replying to same without adding promotions;

e)    Emails or text messages between Lussier’s employees, representatives, suppliers and consultants;

f)    Emails or text messages sent to a prominent email address (displayed on a website, social media or a business card);

g)    Emails regarding a satisfaction survey.

5.    PARTICULAR CASES

In the following cases, Lussier’s representatives must ensure compliance with the defined framework:

QUOTE REQUESTS AND ONLINE QUOTES
  • An email response to a quote request or online quote is permitted, as long as it is limited to answering same.
  • During a telephone conversation following an online quote, a Lussier representative confirms the consents for subsequent use of the email address.
EMAIL REGARDING A SATISFACTION SURVEY
  • Survey emails are not governed by the anti-spam policy since they do not promote a Lussier product, service, individual or contest.
  • Emails of this nature are permitted as long as they include a method to unsubscribe and do not contain a promotion.
EMAIL SENT BY A REPRESENTATIVE REGULATED BY THE AUTORITÉ DES MARCHÉS FINANCIERS (AMF)
  • It is provided for by the Act respecting the distribution of financial products and services and the codes of ethics of damage insurance representatives and the Chambre de la sécurité financière to recommend all the protections that are adequate and adapted to the needs and circumstances of the contact or client.
  • Emails in which the representative performs his duties are accepted insofar as the message is sent following a request for information or quote, during a file follow-up or for renewing a contract, without adding a promotion.
EMAIL SENT THROUGH SOCIAL MEDIA

Lussier has a policy regarding the use of social media and invites its representatives to use same with caution.

Structured solicitation through social media is complex. Any practice or project of this nature must be approved and governed by Lussier's marketing and compliance departments.

EMAIL SENT FOLLOWING A REFERRAL FROM ONE OF LUSSIER’S CLIENTS, EMPLOYEES OR PARTNERS

As part of its internal referral policy, Lussier provides that a representative or employee may forward the email address of a potential client they wish to refer. The solicitation by email must respect the following framework:

a)     A single email can serve as an initial contact with the referred individual;

b)     The email must contain, at a minimum, the following information:

  • full name of the referrer (person who referred the potential client);
  • clear identification of Lussier's contact details;
  •  clear identification of the name and job title of the person who took charge of the file;
  • for any subsequent communication by email, consent must be confirmed.

TACIT OR EXPRESS CONSENT

For any commercial electronic communication issued by Lussier, we limit their transmission to people whose email address we already detain and from whom we have obtained consent.

EXPRESS CONSENT

The following are considered to have given express consent:

a)     Clients who have confirmed their consent, verbally or in writing. Consent must be traceable in their file.

b)     In the case of a voluntary subscription to Lussier's distribution lists through its website, social media or contests, a database of email addresses will be maintained separately from the customer databases and include the given consents.

c)     In the case of any other contact list, express consent for an email to be sent must be confirmed in writing to Lussier, whether by a partner association that sends us a list of prospects or by an external supplier, or by any other means that demonstrates that the consent of the recipients is obtained. Only one transmission will then be made, unless the authorization is expressly formulated otherwise.

IMPLIED CONSENT

Are considered as having implied consents:

a)     Potential clients who have received a quote or have requested information. The implied consent is valid for a period of 6 months following the request.

b)     Active clients with whom we have an ongoing business relationship. The implied consent is valid for a period of 2 years following the last transaction of purchase, issuance or modification to the policy or contract. If the policy or contract is renewed, then the implied consent extends continuously for an additional period of 2 years at each renewal.

c)     For inactive clients who were part of Lussier's databases before July 1, 2014, the implied consent ended on July 1, 2014. For inactive clients acquired after this date, the implied consent is valid for a period of 2 years following the last transaction of purchase, issuance or modification to the policy or contract.

d)     An email address published prominently without specifying that it should not be used to receive unsolicited commercial electronic messages (on a website, a social network, a business card, etc.).

e)     Contacts have no implied consent.

PROCESS FOR CONFIRMING OR WITHDRAWING CONSENT

COMMUNICATION PREFERENCES

In order to provide an optimal client experience, our databases host preferences for the following communication categories:

  • Promotion and advertising

These promotions and advertisements are varied and targeted according to the needs of our audience and the products or services they can benefit from. They also allow the possibility to stay abreast of Lussier’s offers and contests. The frequency of transmission varies between 5 to 6 times per year.

  • Newsletter

Our newsletters contain information, advice and various blogs regarding products or services offered by Lussier (insurance for individuals, businesses, individual insurance, savings and group plans, etc.). The frequency of transmission varies between 6 to 9 times per year.

  • Satisfaction survey

The questionnaires are designed to identify respondents’ satisfaction, needs or knowledge. The frequency of transmission varies according to the number of purchase transactions or claims.

  • Communication with a broker

This includes communications or documents exchanged between a broker and the client with regard to his contract, his insurance policies and his file in general. The frequency of transmission depends on the client’s needs and circumstances.

It is possible to confirm or withdraw consent at any time by clearly stating YES or NO for each of the above-mentioned communications: 

a)     Through our Subscribe and Unsubscribe page;
b)     By telephone with a Lussier representative;
c)     By emailing a Lussier representative;
d)     When participating in a contest (form filled out during an event, convention, etc.);
e)     Through the association, partner or supplier that communicated the information to Lussier;
f)     Through Lussier's written consent form (paper format).

Additionally, as required by law, all of our mass email communications provide a footer that contains:

a)     A link to Lussier’s Subscribe and Unsubscribe page;
b)     Lussier’s complete contact details and corporate name.

All our individual email communications include in the sender's email signature:

a)     The possibility of unsubscribing;
b)     The representative’s complete contact details and those of Lussier.

Confirmation and withdrawal of consent must be expressed clearly, verbally or in writing, by answering YES or NO to each of the aforementioned communication options.

If an unsubscribe request message is general (e.g. "please remove me from your list"), then we unsubscribe the email address from the communication list that generated the particular email. In doubt, we unsubscribe the client from the “Promotions” and “Newsletter” mailing lists as a precaution.

The confirmation or withdrawal of consent is recorded in our internal databases with the date it was given or withdrawn. Proof of subscription and/or unsubscription must be available at all times.

Lussier undertakes to activate a subscription or an unsubscription request within 10 business days. Transmission delays caused by an Internet network malfunction, a temporary server failure or any other superior force may delay the process.

Communications are directed toward the email address associated with a client’s file. When a consent is given to Lussier, it is associated by default with said address. If a client wishes to modify his information, he must advise a Lussier representative.

PUNCTUAL TRANSMISSIONS BY E-MAIL

Lussier sends its mass emails from secure and centralized email addresses.

Lussier applies the following rules when sending occasional mass emails:

  • Promotions and advertisements

a)     Contacts: having an express consent to YES only;
b)     Prospects: having an implied consent for a duration of 6 months following the request for a quote OR having an express consent to YES;
c)     Active clients: having an implied consent for a period of 2 years following the purchase transaction/implementation of a policy or contract OR having express consent to YES;
d)     Inactive clients: having an implied consent for a duration of 2 years following the purchase/implementation transaction of the last policy or contract that was active OR having an express consent to YES.

  • Newsletter

a)     Contacts: having an express consent to YES only;
b)     Prospects: having an implied consent for a duration of 6 months following the request for a quote OR having an express consent to YES;
c)     Active clients: having an implied consent for a period of 2 years following the purchase transaction/implementation of a policy or contract OR having an express consent to YES;
d)     Inactive clients: having an implied consent for a duration of 2 years following the purchase/implementation transaction of the last policy or contract that was active OR having an express consent to YES.

  • Surveys

a)     Contacts: no survey;
b)     Prospects: having an implied consent for a duration of 6 months following the request for a quote OR having an express consent to YES;
c)     Active clients: having an implied consent for a period of 2 years following the purchase transaction/implementation of a policy or contract OR having an express consent to YES;
d)     Inactive clients: having an implied consent for a duration of 2 years following the purchase/implementation transaction of the last policy or contract that was active OR having an express consent to YES.

  • Communication with a broker regarding the client’s file

a)     Contacts: no communication;
b)     Prospects: no communication;
c)     Active clients: having an implied consent for a period of 2 years following the purchase transaction/implementation of a policy or contract OR having an express consent to YES;
d)     Inactive customers: no communication.

In any event, an address having a consent to NO is excluded from the specific list.

COMPLAINTS AND QUESTIONS

If you have any questions, wish to file a complaint or report a non-compliance to this policy, please contact:

Louise Mathieu, Vice President – Business Practices and Compliance
LUSSIER FINANCIAL SERVICES FIRM INC.
1500 935 de la Gauchetiere St. West
Montreal, Quebec H3B 2M9
T. 514-282-1112 | TF: 1-877-587-7437 | F: 450-746-9008
Email: politiqueantipourriel@lussier.co

If you receive an unsolicited email that seems to have been issued by Lussier, please forward same to the above-mentioned address and an investigation will be conducted.
Copyright :

Ce document est la propriété de Lussier Cabinet de Services Financiers Inc. Toute reproduction, modification, distribution, transmission ou divulgation est strictement interdite sans autorisation préalable.

This document is the property of Lussier Financial Services Firm Inc. Any reproduction, modification, distribution, transmission or display is strictly prohibited without prior permission.

For more information on Canada’s anti-spam legislation (CASL), please visit the Government of Canada website.

EFFECTIVE DATE AND UPDATES

The present policy came into effect on July 1, 2014, was updated in May 2017 and April 2023.