WALNUT INSURANCE INC., and our affiliates and subsidiaries, as applicable ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes how we collect, use, disclose, and protect the personal information of our individual customers and website users ("you"), describes the types of information we may collect from you or that you may provide when you visit the website www.gowalnut.com or our application (our "Website"), and our practices for collecting, using, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about our customers and Website users:
o On this Website.
o In email, text, and other electronic messages between you and this Website.
o Through mobile and desktop applications you download from this Website, as applicable, which provide dedicated non-browser-based interaction between you and this Website.
o When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
This policy does not apply to information collected by:
o Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries, as applicable).
o Any third party (including our affiliates and subsidiaries, as applicable), through any application or content (including advertising) that may link to or be accessible from or on the Website.
We collect and use several types of information from and about you including:
o Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you online or offline ("personal information").
o Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
o Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
o Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
We use different methods to collect your information, including through:
o Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
o User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.
o Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as applicable.
o Third parties or publicly available sources, for example, our business partners.
The information we collect directly from you on or through our Website may include:
o Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, through a chat bot, and/or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
o Records and copies of your correspondence (including email addresses), if you contact us.
o Your responses to surveys that we might ask you to complete for research purposes.
o Details of transactions you carry out through our Website, if applicable, and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
o Your search queries on the Website.
o Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
o Information about your computer and internet connection, including your IP address, operating system, and browser type.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
o Estimate our audience size and usage patterns.
o Store information about your preferences, allowing us to customize our Website according to your individual interests.
o Speed up your searches.
o Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
o Web Beacons. Pages of our Website and any of our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
We use information that we collect about you or that you provide to us, including any personal information:
o To present our Website and its contents to you.
o To provide you with information, products, or services that you request from us.
o To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
o To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
o To notify you about changes to our Website or any products or services we offer or provide though it.
o To improve our Website, products or services, marketing, or customer relationships and experiences.
o To allow you to participate in interactive features, social media, or similar features on our Website.
o To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
o In any other way we may describe when you provide the information. For any other purpose with your consent.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
o To our subsidiaries and affiliates, as applicable.
o In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the securities or assets of WALNUT INSURANCE INC., whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by WALNUT INSURANCE INC. about our customers and users is among the securities or assets transferred.
o To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers' advertisement to that target audience.
o To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
o To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
o For any other purpose disclosed by us when you provide the information.
o With your consent.
We may also disclose your personal information:
o To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
o If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of WALNUT INSURANCE INC., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
o Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out through the following method:
You can also opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com.
o Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by using the method outlined in the paragraph above. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
o Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by using the method outlined in the Third Party Advertising paragraph above. For this opt-out mechanism to function, you must have your browser set to accept browser cookies.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
The security of your personal information is very important to us. We use
physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases
through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
You can review and change your personal information by logging into the Website and visiting your account profile page.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
o Information protected by solicitor-client privilege.
o Information that is part of a formal dispute resolution process.
o Information that is about another individual that would reveal their personal information or confidential commercial information.
o Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact:
Privacy Officer, at email@example.com
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at firstname.lastname@example.org. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
Privacy Officer, at email@example.com
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.