Respecting the privacy of our clients is an important part of our commitment to providing superior service. This policy sets out the manner in which our company collects, retains, uses, and discloses personal information in the course of our operations.
Lussier is subject to federal and provincial privacy legislation, including the Act respecting the protection of personal information in the private sector, the Personal Information Protection and Electronic Documents Act and the Canada’s anti-spam legislation. Our representatives certified with the Autorités des marchés financiers are bound by a code of ethics that includes a duty of confidentiality regarding all information they obtain in the course of their activities.
1. Definition of personal information
Personal information is information which relates to a natural person and directly or indirectly allows that person to be identified. Personal information includes, but is not limited to, the following:
- name, postal and email address, telephone number;
- date of birth;
- social insurance number, driver's license number;
- banking information.
2. Collection, use and retention of personal information
Personal information collected by our company is limited to that which is necessary to provide or administer financial services and products, respond to requests made to us, communicate with our clients and personalize our company’s offerings.
The collection of information is required to:
- conduct a complete analysis of the client’s needs;
- prepare a quote for the product(s) or service(s) requested;
- issue or renew an insurance contract;
- any other reason identified.
This information is collected in a variety of ways, including when requesting a quote, subscribing to our services, filling out forms online or at events, communicating with our representatives and subscribing to our publications.
Information is kept confidential at all times and access is limited to employees authorized to process a client's request. It is retained for as long as necessary to fulfill the purpose for which it was collected, or for any longer period required by legislation governing our activities.
3. Disclosure of personal information
At no time is personal information held by our company made public or sold.
We do not disclose personal information to third parties without the client's consent, unless this is required for the provision of services requested by the client, for example to partner insurers for the issuance of policies, to give effect to a court order or in cases provided for by law.
In the course of our operations, we are occasionally required to collect or transmit information to organizations or companies that are legally regulated and have a legitimate right to request or transmit such information. These organizations or companies depend on the financial products or services requested by the client and the province in which the client is located. They include, for example:
- insurance brokers or claims adjusters;
- insurers, reinsurers and financial institutions, or the organizations responsible for regulating them;
- the Fichier central des sinistres automobiles and the Société d’assurance automobile of Quebec or another province;
- credit, risk and claims data analysis agencies.
In all cases, we make every effort to ensure that privacy rights are respected.
Communication Outside Quebec
It is possible that personal information may be communicated outside Quebec, for example to a partner insurer or service provider. Prior to transmission, our company takes the necessary steps to ensure that the third party maintains a level of confidentiality equivalent to that of Quebec.
4. Quotations and telephone transactions
When we analyze a client's needs and prepare a quotation, offer of service or insurance contract over the telephone:
- It is understood that our interlocutor gives us his consent and that he has also obtained the consent of all persons interested or mentioned in the quote or insurance contract that affects him. This consent includes the collection, retention, use and disclosure of their personal information for the established purposes.
- If the quotation or insurance contract affects a person other than the interlocutor, the representative will ensure that he obtains the direct consent of said person, in compliance with the law.
For reasons of information integrity, training and client service quality control, telephone conversations may be recorded or listened to.
With regard to the use of e-mail addresses, Lussier's anti-spam policy stipulates that its employees ensure that consent is requested in a detailed and structured manner.
5. On-line quotations
When a client completes and sends a quote form through Lussier.co for various products:
- he automatically consents to our company using his personal information to analyze his needs and provide a quote for the financial product requested;
- he authorizes a Lussier representative to contact him by telephone, email or any other indicated means in order to discuss his file, provide him with the requested quote and promote the products and services offered by our company;
- he understands that the use of his email address will be made in accordance with Lussier’s anti-spam policy, i.e. only one, if necessary, and always for the purpose of responding to this request;
- he understands that, still in accordance with Lussier’s anti-spam policy, he will have the opportunity, during a telephone contact with the representative, to confirm or withdraw his consent for subsequent uses of his email address.
6. Use of our website
Anonymous and confidential information is collected by means of cookies and similar technologies (Google Analytics, etc.) via our website in order to analyze site traffic and improve the quality of services and information offered to users.
Users may, at any time, delete or deactivate cookies from their browser. Some cookies are essential to the operation of our site and therefore cannot be disabled.
7. Access to and correction of personal information
It is important that personal information held by our company be accurate, complete and up to date.
Any person wishing to verify the accuracy of his or her information or to modify it may contact the Privacy Officer, whose contact information is set out in section 14.
Should the Privacy Officer discover that an error mistakenly appears in a file despite our best efforts to prevent same, we will correct it as soon as possible and inform the person affected.
8. Client consent and right of withdrawal
Personal information is not collected, held, used or disclosed by our company without the client's consent.
To modify or withdraw consent, the person affected is invited to contact a Lussier representative. Please note that if consent is withdrawn, our company may not be able to provide a particular service. The representative will then explain the impact of the withdrawal to help in the decision-making process
9. On-line subscription and unsubscribing
In accordance with our anti-spam policy, consent to the use of an e-mail address may be confirmed or withdrawn at any time through our online subscription and unsubscribing page or by contacting one of our representatives.
10. Transmission of information by email
We recommend that our clients exercise great caution when transmitting personal information to us by unsecured email (e.g. policy number, address, etc.).
Lussier is not responsible for damages resulting from the interception, loss or modification of an e-mail sent to us.
11. Security and privacy
We implement physical, technical and organizational security measures to protect personal information against unauthorized access.
Any confidentiality or security incident must be reported without delay to our Privacy Officer (section 14).
12. Work environment at Lussier
Lussier is committed to protecting the personal information of its representatives, employees and candidates for employment. Legislative provisions designed to protect the privacy of individuals are applied in full to foster a healthy work environment.
13. Process for handling complains relating to the protection of personal information
Any complaint concerning non-compliance with this policy may be addressed to the Privacy Officer (section 14).
The complaint handling process remains confidential.
14. Privacy Officer
The person designated for the application of this policy within our company is:
Privacy Officer
Ms. Louise Mathieu, Vice President - Business Practices and Compliance
Lussier Financial Services Firm Inc.
1500-935, De La Gauchetiere Street West, Montreal (Quebec) H3B 2M9
confidentialite@lussier.co
The person in charge ensures that Lussier's representatives and employees are aware of this policy and that they are trained in its proper application.
In accordance with the law, she ensures the creation, maintenance and updating of a register of confidentiality incidents, and upon request by the Commission d'accès à l'information transmits a declaration of this register
15. Policy information
If you have any questions or comments regarding this policy, please contact our Privacy Officer (section 14).
Copyright
This document is the property of Lussier Financial Services Firm Inc. Any reproduction, modification, distribution, transmission or disclosure is strictly prohibited without prior authorization.