Canada
Last Updated: July 31, 2024
WALNUT INSURANCE INC., WALNUT SERVICES INC. WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) respect your privacy and are committed to protecting it through our compliance with this policy.
*For the specific purposes of the application of this policy in the province of Quebec only, LAPOINTE FINANCIAL GROUP INC., WALNUT SERVICES INC, WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) 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 users of our website, gowalnut.com ("you"). “Personal Information” consists of information through which a person is identifiable or may be identified through the use of the information alone or in combination with other information.
This policy describes the types of Personal Information we may collect from you or that you may provide when you visit the website, gowalnut.com, or our application (our "Website") or when you communicate with us by email, text, and other electronic messages on a voluntary basis with regards to any services offered by the Company, and describes our practices for collecting, using, protecting, and disclosing that Personal 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.
This policy applies to Personal Information we collect, use, or disclose about our customers and Website users:
· On this Website;
· In email, text, and other electronic messages; between you and this Website.
· Through mobile and desktop applications you download from this Website, as applicable, which provide dedicated non-browser-based interaction between you and this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy does not apply to Personal Information collected by:
· Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries, as applicable).
· 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
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, or the site’s Terms of Use, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the collection, use and disclosure of your Personal Information as described in this policy and this site’s Terms of Use.
In order to provide you with the services you request and depending on the type of service we assist you with, we may collect the following Personal Information:
Directly from you:
· Information that we can reasonably use to directly or indirectly identify you, such as your name, address, e-mail address, telephone number, age, birth date, social insurance number,driver’s licence number, gender, credit card numbers, information about your assets, income, or personal finances, medical records, height, weight, credit records, loan records, driving record, employment history, insurance and transaction history, Internet protocol (IP) address used to connect your computer to the Internet, geolocation, user name or other similar identifier, billing, payment, and account information, and any other identifier we may use to contact you online or offline.
· Information about any product associated with your request, such as product numbers, manufacturer, purchase information, warranty information;
· Information in any correspondence between you and us;
· Any responses to surveys that we might ask you to complete for our own internal purposes;
From other sources, such as partners, (e.g. other insurance brokers, insurance companies, consumer reporting agencies, investment product suppliers, financial technology companies, retailers, reward programs, banks and credit unions, utilities, manufacturers):
· With your consent, some of our partners may share your contact information with us (such as your name, email address, phone number), for example, if you have requested certain services that we offer or if you requested information or offers from us;
· With your prior express consent, we may collect credit report information, employment information and insurance history information.
Automatically, via automated technologies or interactions (through cookies, web beacons, and other tracking technologies, as applicable), as you navigate through our Website.:
· Technical information, including your login information, browser type and version, time zone setting, your device location, 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.
· Information 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.
As mentioned above, when you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· 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.
· 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:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
You can manage and disable cookies at any time by changing your browser settings. Depending on the browser you use, different instructions may apply. Click on your browser to find out how you can manage cookies:
o Safari
o Opera
· 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).
· Geolocation Features. Online services may collect precise information concerning the location of your devices. These geolocation feature, if you consent to the collection of this data, collect geolocation in the background (i.e. when the application is active, but reduced or invisible on the screen), but only with your authorization when you activate these features. This technology is not activated by default when the application is downloaded.
You may make the following choices regarding these automated technologies:
· Tracking Technologies and Advertising. As described above, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
· 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 privacy@gowalnut.com.
· Targeted Advertising. If you do not want us to use Personal 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 Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal 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.
Third-party links
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website, service or mobile app you visit.
Third-party marketing emails and communications
You may have the opportunity to receive information or marketing offers directly from unaffiliated third parties. If you agree to receive the communications, your Personal Information will be disclosed to those third parties and all Personal Information you disclose will be subject to their privacy policies and practices. We do not endorse and are not responsible for the privacy policies and practices of those third parties. You should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Third-party use of tracking technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
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 section “Information we collect through cookies and other automatic data collection technologies”
We may use Personal Information that we collect about you or that you provide to us, including any Personal information:
· To present our Website and its contents to you.
· To determine your eligibility for, offer and/or provide you with insurance products, memberships and other services that you request from us, including where you have been referred to us by third party organizations (with your consent).
· To evaluate credit worthiness and monitor, collect premiums and fees;
· To verify your identity;
· To determine prices, fees and premiums, including by evaluating your coverage needs and assessing risk, including where you have been referred to us by third party organizations (with your consent). ;
· To maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services;
· To update credit bureau reports
· To investigate and settle claims;
· To determine your eligibility for and offer and provide other products or services that may be of interest to you, such as investment or retirement products or group benefits, unless you ask us not to, including where you have been referred to us by third party organizations (with your consent). ;
· To detect and protect against error or fraud;
· To compile statistics and conduct market research;
· To maintain business records for reasonable periods;
· To meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and
· To fulfill the purposes for which you provided the Personal Information or that were described when it was collected, or any other purpose for which you provide it.
· 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.
· To notify you about changes to our Website or any products or services we offer or provide though it;
· To contact you about any service or information you may have requested and/or to contact you with marketing and promotional offers;
· To improve our Website, products or services, marketing, or customer relationships and experiences;
· To allow you to participate in interactive features, social media, or similar features on our Website;
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
· In any other way we may describe when you provide the Personal Information;
· For any other purpose with your consent.
Note that we may aggregate, de-identify and/or anonymize Personal Information in order to use such data for purposes such as to generate statistics about our services or to identify trends.
This information does not directly or indirectly reveal your identity or relate to an identified individual, and can include 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.
We may disclose aggregated information about our customers or Website visitors, and information that does not identify, directly or indirectly, any individual, without restriction.
Unless explicitly mentioned in the table below or through a clear notice to that effect, Personal Information collected by the Company is not sold, distributed, rented or communicated to other persons or organizations. The Company only communicates your Personal Information to certain types of third parties when it is necessary. We may disclose Personal Information that we collect or you provide as described in this privacy policy:
Subsidiaries and affiliates, as applicable
Personal Information collected by the Company is accessible by subsidiaries and affiliates who must access it as part of their duties and in accordance with the intended purposes set out in this policy. They are bound by this policy and agree to use Personal Information collected by the Company only in accordance with this policy.
Corporate event
In accordance with applicable law, we may communicate Personal Information 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 the Company, whether as a going concern or as part of bankruptcy, liquidation, investment, or similar proceeding., in which Personal Information held by the Company. about our customers and users is among the securities or assets transferred
Advertisers and advertising networks
We may communicate Personal Information to advertisers and advertising networks that require some 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.
Contractors, service providers, and other third parties
We may communicate Personal Information to contractors, service providers, and other third parties we use to support our business (service providers such as those assisting us with analytics and search engine providers for Website improvement and optimization) or that perform services on our behalf such as data processing, data warehousing or administrative services. Note that these third-party service providers and contractors 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.
Third party organizations who disclosed your Personal Information to us
We may communicate Personal Information to third party organizations who disclosed your Personal Information to us (with your consent) as part of a referral to (a) allow the third party to provide services to you (for example, where a mortgage provider refers you to us for insurance, we will inform them if you buy insurance from us so that they can confirm the mortgage), (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
Third party partners
We may communicate Personal Information to third party organizations who partnered with us to (a) allow the third party to provide services to you, (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
For example, if you are located in Quebec, we may disclose Personal Information you provide to us to the licenced broker Groupe Financier Lapointe Inc., in order to provide you with services you request. You may consult Groupe Financier Lapointe’s privacy policy here, https://lapointefinancialgroup.com/terms-policies, for Information on how your Personal Information will be handled once it is disclosed.
Third parties whose services are included in your Walnut membership
We may communicate Personal Information to third parties whose services are included in your Walnut membership. If your membership to Walnut includes services offered by third parties, the use of your Personal Information by those third parties to perform those services will be subject to their privacy policies, which you should review prior to signing up for a membership or adding the services to an existing membership.
We may disclose Personal Information that we collect or you provide as described in this privacy policy to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the Personal Information, and when you provide us your consent.
We may also disclose your Personal Information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
· To enforce or apply our terms of use www.gowalnut.com/terms-of-use and other agreements, including for billing and collection purposes, such as identifying and contacting user who violate our terms of use or engage in prohibited activities, processing payments, invoicing, resolving billing disputes and recovering outstanding debts or fess owed to the Company. Information could be communicated to payment processors, collection agencies, legal and regulatory authorities, professional advisors and partners and affiliates;
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes sharing Personal Information with law enforcement agencies or legal authorities in cases of suspected fraud, identity theft, or other criminal activities, providing necessary information to third-party service providers, such as credit reporting agencies, for the purpose of fraud protection and credit risk reduction and exchanging information with trusted partners or organizations to investigate and prevent potential security threats or violations of our policies; and
· In other circumstances for which we have your prior consent.
We, or our service providers, may process, store, and transfer your Personal Information in Canada and the United States, which may have different privacy laws that may or may not be as comprehensive as Canadian law.
We will take steps to ensure your Personal Information is adequately protected in accordance with applicable privacy and data protection laws while outside of your province of residence. However, please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is processed, including lawful access, for example, your Personal Information may be still accessible to law enforcement agencies, government agencies, courts, and national security authorities of the foreign jurisdiction
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See ”Contact Us” below for more information.
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 Personal 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 Personal 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. Some third parties may process your Personal Information nationally and internationally, which means that your Personal Information may be transferred outside Quebec. 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, or to meet any legal or regulatory requirements. At the end of this period, the Personal Information is destroyed or anonymized, in which case it will only be used for serious and legitimate purposes.
We do not target or knowingly collect Personal Information about children. Please contact our Privacy Officer at the contact information below under section “Contact Us” if you believe we have collected Personal Information about a child, and we will delete that information.
We make reasonable efforts to ensure that the Personal Information we have on file about individuals is accurate, complete and up-to-date as necessary for the purposes for which it is to be used, including Personal Information that is shared with third parties and Personal Information that is used to make a decision about an individual. Please keep us informed if your Personal Information changes and must be updated.
Depending on where you reside, you may have one or more of the following rights relating to your Personal Information:
• Right to opt-out: Subject to certain exceptions, you may “opt-out” or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your Personal Information. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to provide you with a particular product or service.
• Rights of access, correction and erasure: You may request access to and obtain a copy of any of your Personal Information that we hold, to request the correction of any inaccurate, outdated or incomplete information related to you or to request the deletion of your Personal Information under certain circumstances. You also have the right to know the types of Personal Information that is being collected. You can access your Personal Information by logging into the Website and visiting your account profile page. You may correct or update your Personal Information or withdraw your consent to the use and/or disclosure of your Personal Information at any time.
• Unsubscribe from marketing materials. You may unsubscribe from marketing materials to which you have subscribed by selecting the “unsubscribe” link in any marketing email or commercial electronic message we have sent you. You can also send us a request at the information under the section “Contact Us”. Please note that if you unsubscribe from marketing communications or the like, you will still receive transactional and other necessary communications from us.
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:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their Personal Information or confidential commercial information.
If you are a resident of Quebec, you also have the right to receive computerized Personal Information collected in a structured, commonly used and technological format and to have this information transferred directly to any person or body authorized by law to collect such information.
If you are concerned about our response or would like to correct the Personal Information provided, you may contact the Privacy officer at the Company at: privacy@gowalnut.com
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use www.gowalnut.com/terms-of-use.
The Company collects, uses and discloses your Personal Information for specific purposes. Your consent is valid for the time required to fulfill these purposes. If we wish to use or disclose your Personal Information for other purposes, we will seek your consent (unless otherwise permitted or required by law). Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide Personal Information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). By accessing and/or using any of our Website, you consent to the collection, use and disclosure of your Personal Information as described in this privacy policy. In the event that you do not consent to the collection, use or disclosure of such Personal Information as described in this Policy, you have the choice not to interact with the Company. Generally, by providing us with Personal Information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or de-scribed in this Privacy Policy, if applicable, or otherwise at the time of collection.
If you obtain insurance for a family member or other third party or otherwise provide Personal Information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her Personal Information for the purposes described above.
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 the Privacy officer at the Company at: privacy@gowalnut.com. 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.
We may make changes to this privacy policy at any time in order to reflect our practices. It is our policy to post any changes we make to our privacy policy on this page. We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact the Privacy officer at the Company at: privacy@gowalnut.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 us using the contact information listed above.
Canada
Last Updated: July 31, 2024
WALNUT INSURANCE INC., WALNUT SERVICES INC. WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) respect your privacy and are committed to protecting it through our compliance with this policy.
*For the specific purposes of the application of this policy in the province of Quebec only, LAPOINTE FINANCIAL GROUP INC., WALNUT SERVICES INC, WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) 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 users of our website, gowalnut.com ("you"). “Personal Information” consists of information through which a person is identifiable or may be identified through the use of the information alone or in combination with other information.
This policy describes the types of Personal Information we may collect from you or that you may provide when you visit the website, gowalnut.com, or our application (our "Website") or when you communicate with us by email, text, and other electronic messages on a voluntary basis with regards to any services offered by the Company, and describes our practices for collecting, using, protecting, and disclosing that Personal 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.
This policy applies to Personal Information we collect, use, or disclose about our customers and Website users:
· On this Website;
· In email, text, and other electronic messages; between you and this Website.
· Through mobile and desktop applications you download from this Website, as applicable, which provide dedicated non-browser-based interaction between you and this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy does not apply to Personal Information collected by:
· Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries, as applicable).
· 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
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, or the site’s Terms of Use, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the collection, use and disclosure of your Personal Information as described in this policy and this site’s Terms of Use.
In order to provide you with the services you request and depending on the type of service we assist you with, we may collect the following Personal Information:
Directly from you:
· Information that we can reasonably use to directly or indirectly identify you, such as your name, address, e-mail address, telephone number, age, birth date, social insurance number,driver’s licence number, gender, credit card numbers, information about your assets, income, or personal finances, medical records, height, weight, credit records, loan records, driving record, employment history, insurance and transaction history, Internet protocol (IP) address used to connect your computer to the Internet, geolocation, user name or other similar identifier, billing, payment, and account information, and any other identifier we may use to contact you online or offline.
· Information about any product associated with your request, such as product numbers, manufacturer, purchase information, warranty information;
· Information in any correspondence between you and us;
· Any responses to surveys that we might ask you to complete for our own internal purposes;
From other sources, such as partners, (e.g. other insurance brokers, insurance companies, consumer reporting agencies, investment product suppliers, financial technology companies, retailers, reward programs, banks and credit unions, utilities, manufacturers):
· With your consent, some of our partners may share your contact information with us (such as your name, email address, phone number), for example, if you have requested certain services that we offer or if you requested information or offers from us;
· With your prior express consent, we may collect credit report information, employment information and insurance history information.
Automatically, via automated technologies or interactions (through cookies, web beacons, and other tracking technologies, as applicable), as you navigate through our Website.:
· Technical information, including your login information, browser type and version, time zone setting, your device location, 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.
· Information 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.
As mentioned above, when you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· 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.
· 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:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
You can manage and disable cookies at any time by changing your browser settings. Depending on the browser you use, different instructions may apply. Click on your browser to find out how you can manage cookies:
o Safari
o Opera
· 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).
· Geolocation Features. Online services may collect precise information concerning the location of your devices. These geolocation feature, if you consent to the collection of this data, collect geolocation in the background (i.e. when the application is active, but reduced or invisible on the screen), but only with your authorization when you activate these features. This technology is not activated by default when the application is downloaded.
You may make the following choices regarding these automated technologies:
· Tracking Technologies and Advertising. As described above, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
· 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 privacy@gowalnut.com.
· Targeted Advertising. If you do not want us to use Personal 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 Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal 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.
Third-party links
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website, service or mobile app you visit.
Third-party marketing emails and communications
You may have the opportunity to receive information or marketing offers directly from unaffiliated third parties. If you agree to receive the communications, your Personal Information will be disclosed to those third parties and all Personal Information you disclose will be subject to their privacy policies and practices. We do not endorse and are not responsible for the privacy policies and practices of those third parties. You should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Third-party use of tracking technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
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 section “Information we collect through cookies and other automatic data collection technologies”
We may use Personal Information that we collect about you or that you provide to us, including any Personal information:
· To present our Website and its contents to you.
· To determine your eligibility for, offer and/or provide you with insurance products, memberships and other services that you request from us, including where you have been referred to us by third party organizations (with your consent).
· To evaluate credit worthiness and monitor, collect premiums and fees;
· To verify your identity;
· To determine prices, fees and premiums, including by evaluating your coverage needs and assessing risk, including where you have been referred to us by third party organizations (with your consent). ;
· To maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services;
· To update credit bureau reports
· To investigate and settle claims;
· To determine your eligibility for and offer and provide other products or services that may be of interest to you, such as investment or retirement products or group benefits, unless you ask us not to, including where you have been referred to us by third party organizations (with your consent). ;
· To detect and protect against error or fraud;
· To compile statistics and conduct market research;
· To maintain business records for reasonable periods;
· To meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and
· To fulfill the purposes for which you provided the Personal Information or that were described when it was collected, or any other purpose for which you provide it.
· 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.
· To notify you about changes to our Website or any products or services we offer or provide though it;
· To contact you about any service or information you may have requested and/or to contact you with marketing and promotional offers;
· To improve our Website, products or services, marketing, or customer relationships and experiences;
· To allow you to participate in interactive features, social media, or similar features on our Website;
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
· In any other way we may describe when you provide the Personal Information;
· For any other purpose with your consent.
Note that we may aggregate, de-identify and/or anonymize Personal Information in order to use such data for purposes such as to generate statistics about our services or to identify trends.
This information does not directly or indirectly reveal your identity or relate to an identified individual, and can include 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.
We may disclose aggregated information about our customers or Website visitors, and information that does not identify, directly or indirectly, any individual, without restriction.
Unless explicitly mentioned in the table below or through a clear notice to that effect, Personal Information collected by the Company is not sold, distributed, rented or communicated to other persons or organizations. The Company only communicates your Personal Information to certain types of third parties when it is necessary. We may disclose Personal Information that we collect or you provide as described in this privacy policy:
Subsidiaries and affiliates, as applicable
Personal Information collected by the Company is accessible by subsidiaries and affiliates who must access it as part of their duties and in accordance with the intended purposes set out in this policy. They are bound by this policy and agree to use Personal Information collected by the Company only in accordance with this policy.
Corporate event
In accordance with applicable law, we may communicate Personal Information 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 the Company, whether as a going concern or as part of bankruptcy, liquidation, investment, or similar proceeding., in which Personal Information held by the Company. about our customers and users is among the securities or assets transferred
Advertisers and advertising networks
We may communicate Personal Information to advertisers and advertising networks that require some 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.
Contractors, service providers, and other third parties
We may communicate Personal Information to contractors, service providers, and other third parties we use to support our business (service providers such as those assisting us with analytics and search engine providers for Website improvement and optimization) or that perform services on our behalf such as data processing, data warehousing or administrative services. Note that these third-party service providers and contractors 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.
Third party organizations who disclosed your Personal Information to us
We may communicate Personal Information to third party organizations who disclosed your Personal Information to us (with your consent) as part of a referral to (a) allow the third party to provide services to you (for example, where a mortgage provider refers you to us for insurance, we will inform them if you buy insurance from us so that they can confirm the mortgage), (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
Third party partners
We may communicate Personal Information to third party organizations who partnered with us to (a) allow the third party to provide services to you, (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
For example, if you are located in Quebec, we may disclose Personal Information you provide to us to the licenced broker Groupe Financier Lapointe Inc., in order to provide you with services you request. You may consult Groupe Financier Lapointe’s privacy policy here, https://lapointefinancialgroup.com/terms-policies, for Information on how your Personal Information will be handled once it is disclosed.
Third parties whose services are included in your Walnut membership
We may communicate Personal Information to third parties whose services are included in your Walnut membership. If your membership to Walnut includes services offered by third parties, the use of your Personal Information by those third parties to perform those services will be subject to their privacy policies, which you should review prior to signing up for a membership or adding the services to an existing membership.
We may disclose Personal Information that we collect or you provide as described in this privacy policy to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the Personal Information, and when you provide us your consent.
We may also disclose your Personal Information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
· To enforce or apply our terms of use www.gowalnut.com/terms-of-use and other agreements, including for billing and collection purposes, such as identifying and contacting user who violate our terms of use or engage in prohibited activities, processing payments, invoicing, resolving billing disputes and recovering outstanding debts or fess owed to the Company. Information could be communicated to payment processors, collection agencies, legal and regulatory authorities, professional advisors and partners and affiliates;
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes sharing Personal Information with law enforcement agencies or legal authorities in cases of suspected fraud, identity theft, or other criminal activities, providing necessary information to third-party service providers, such as credit reporting agencies, for the purpose of fraud protection and credit risk reduction and exchanging information with trusted partners or organizations to investigate and prevent potential security threats or violations of our policies; and
· In other circumstances for which we have your prior consent.
We, or our service providers, may process, store, and transfer your Personal Information in Canada and the United States, which may have different privacy laws that may or may not be as comprehensive as Canadian law.
We will take steps to ensure your Personal Information is adequately protected in accordance with applicable privacy and data protection laws while outside of your province of residence. However, please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is processed, including lawful access, for example, your Personal Information may be still accessible to law enforcement agencies, government agencies, courts, and national security authorities of the foreign jurisdiction
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See ”Contact Us” below for more information.
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 Personal 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 Personal 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. Some third parties may process your Personal Information nationally and internationally, which means that your Personal Information may be transferred outside Quebec. 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, or to meet any legal or regulatory requirements. At the end of this period, the Personal Information is destroyed or anonymized, in which case it will only be used for serious and legitimate purposes.
We do not target or knowingly collect Personal Information about children. Please contact our Privacy Officer at the contact information below under section “Contact Us” if you believe we have collected Personal Information about a child, and we will delete that information.
We make reasonable efforts to ensure that the Personal Information we have on file about individuals is accurate, complete and up-to-date as necessary for the purposes for which it is to be used, including Personal Information that is shared with third parties and Personal Information that is used to make a decision about an individual. Please keep us informed if your Personal Information changes and must be updated.
Depending on where you reside, you may have one or more of the following rights relating to your Personal Information:
• Right to opt-out: Subject to certain exceptions, you may “opt-out” or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your Personal Information. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to provide you with a particular product or service.
• Rights of access, correction and erasure: You may request access to and obtain a copy of any of your Personal Information that we hold, to request the correction of any inaccurate, outdated or incomplete information related to you or to request the deletion of your Personal Information under certain circumstances. You also have the right to know the types of Personal Information that is being collected. You can access your Personal Information by logging into the Website and visiting your account profile page. You may correct or update your Personal Information or withdraw your consent to the use and/or disclosure of your Personal Information at any time.
• Unsubscribe from marketing materials. You may unsubscribe from marketing materials to which you have subscribed by selecting the “unsubscribe” link in any marketing email or commercial electronic message we have sent you. You can also send us a request at the information under the section “Contact Us”. Please note that if you unsubscribe from marketing communications or the like, you will still receive transactional and other necessary communications from us.
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:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their Personal Information or confidential commercial information.
If you are a resident of Quebec, you also have the right to receive computerized Personal Information collected in a structured, commonly used and technological format and to have this information transferred directly to any person or body authorized by law to collect such information.
If you are concerned about our response or would like to correct the Personal Information provided, you may contact the Privacy officer at the Company at: privacy@gowalnut.com
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use www.gowalnut.com/terms-of-use.
The Company collects, uses and discloses your Personal Information for specific purposes. Your consent is valid for the time required to fulfill these purposes. If we wish to use or disclose your Personal Information for other purposes, we will seek your consent (unless otherwise permitted or required by law). Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide Personal Information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). By accessing and/or using any of our Website, you consent to the collection, use and disclosure of your Personal Information as described in this privacy policy. In the event that you do not consent to the collection, use or disclosure of such Personal Information as described in this Policy, you have the choice not to interact with the Company. Generally, by providing us with Personal Information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or de-scribed in this Privacy Policy, if applicable, or otherwise at the time of collection.
If you obtain insurance for a family member or other third party or otherwise provide Personal Information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her Personal Information for the purposes described above.
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 the Privacy officer at the Company at: privacy@gowalnut.com. 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.
We may make changes to this privacy policy at any time in order to reflect our practices. It is our policy to post any changes we make to our privacy policy on this page. We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact the Privacy officer at the Company at: privacy@gowalnut.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 us using the contact information listed above.
Canada
Last Updated: July 31, 2024
WALNUT INSURANCE INC., WALNUT SERVICES INC. WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) respect your privacy and are committed to protecting it through our compliance with this policy.
*For the specific purposes of the application of this policy in the province of Quebec only, LAPOINTE FINANCIAL GROUP INC., WALNUT SERVICES INC, WALNUT MARKETING SERVICES INC., 2678562 Ontario Inc., and our affiliates and subsidiaries, as applicable ("Company", “Walnut”, "we", “us”, “our”) 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 users of our website, gowalnut.com ("you"). “Personal Information” consists of information through which a person is identifiable or may be identified through the use of the information alone or in combination with other information.
This policy describes the types of Personal Information we may collect from you or that you may provide when you visit the website, gowalnut.com, or our application (our "Website") or when you communicate with us by email, text, and other electronic messages on a voluntary basis with regards to any services offered by the Company, and describes our practices for collecting, using, protecting, and disclosing that Personal 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.
This policy applies to Personal Information we collect, use, or disclose about our customers and Website users:
· On this Website;
· In email, text, and other electronic messages; between you and this Website.
· Through mobile and desktop applications you download from this Website, as applicable, which provide dedicated non-browser-based interaction between you and this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy does not apply to Personal Information collected by:
· Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries, as applicable).
· 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
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, or the site’s Terms of Use, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the collection, use and disclosure of your Personal Information as described in this policy and this site’s Terms of Use.
In order to provide you with the services you request and depending on the type of service we assist you with, we may collect the following Personal Information:
Directly from you:
· Information that we can reasonably use to directly or indirectly identify you, such as your name, address, e-mail address, telephone number, age, birth date, social insurance number,driver’s licence number, gender, credit card numbers, information about your assets, income, or personal finances, medical records, height, weight, credit records, loan records, driving record, employment history, insurance and transaction history, Internet protocol (IP) address used to connect your computer to the Internet, geolocation, user name or other similar identifier, billing, payment, and account information, and any other identifier we may use to contact you online or offline.
· Information about any product associated with your request, such as product numbers, manufacturer, purchase information, warranty information;
· Information in any correspondence between you and us;
· Any responses to surveys that we might ask you to complete for our own internal purposes;
From other sources, such as partners, (e.g. other insurance brokers, insurance companies, consumer reporting agencies, investment product suppliers, financial technology companies, retailers, reward programs, banks and credit unions, utilities, manufacturers):
· With your consent, some of our partners may share your contact information with us (such as your name, email address, phone number), for example, if you have requested certain services that we offer or if you requested information or offers from us;
· With your prior express consent, we may collect credit report information, employment information and insurance history information.
Automatically, via automated technologies or interactions (through cookies, web beacons, and other tracking technologies, as applicable), as you navigate through our Website.:
· Technical information, including your login information, browser type and version, time zone setting, your device location, 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.
· Information 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.
As mentioned above, when you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· 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.
· 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:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
You can manage and disable cookies at any time by changing your browser settings. Depending on the browser you use, different instructions may apply. Click on your browser to find out how you can manage cookies:
o Safari
o Opera
· 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).
· Geolocation Features. Online services may collect precise information concerning the location of your devices. These geolocation feature, if you consent to the collection of this data, collect geolocation in the background (i.e. when the application is active, but reduced or invisible on the screen), but only with your authorization when you activate these features. This technology is not activated by default when the application is downloaded.
You may make the following choices regarding these automated technologies:
· Tracking Technologies and Advertising. As described above, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
· 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 privacy@gowalnut.com.
· Targeted Advertising. If you do not want us to use Personal 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 Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal 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.
Third-party links
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website, service or mobile app you visit.
Third-party marketing emails and communications
You may have the opportunity to receive information or marketing offers directly from unaffiliated third parties. If you agree to receive the communications, your Personal Information will be disclosed to those third parties and all Personal Information you disclose will be subject to their privacy policies and practices. We do not endorse and are not responsible for the privacy policies and practices of those third parties. You should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Third-party use of tracking technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
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 section “Information we collect through cookies and other automatic data collection technologies”
We may use Personal Information that we collect about you or that you provide to us, including any Personal information:
· To present our Website and its contents to you.
· To determine your eligibility for, offer and/or provide you with insurance products, memberships and other services that you request from us, including where you have been referred to us by third party organizations (with your consent).
· To evaluate credit worthiness and monitor, collect premiums and fees;
· To verify your identity;
· To determine prices, fees and premiums, including by evaluating your coverage needs and assessing risk, including where you have been referred to us by third party organizations (with your consent). ;
· To maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products and services;
· To update credit bureau reports
· To investigate and settle claims;
· To determine your eligibility for and offer and provide other products or services that may be of interest to you, such as investment or retirement products or group benefits, unless you ask us not to, including where you have been referred to us by third party organizations (with your consent). ;
· To detect and protect against error or fraud;
· To compile statistics and conduct market research;
· To maintain business records for reasonable periods;
· To meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and
· To fulfill the purposes for which you provided the Personal Information or that were described when it was collected, or any other purpose for which you provide it.
· 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.
· To notify you about changes to our Website or any products or services we offer or provide though it;
· To contact you about any service or information you may have requested and/or to contact you with marketing and promotional offers;
· To improve our Website, products or services, marketing, or customer relationships and experiences;
· To allow you to participate in interactive features, social media, or similar features on our Website;
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
· In any other way we may describe when you provide the Personal Information;
· For any other purpose with your consent.
Note that we may aggregate, de-identify and/or anonymize Personal Information in order to use such data for purposes such as to generate statistics about our services or to identify trends.
This information does not directly or indirectly reveal your identity or relate to an identified individual, and can include 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.
We may disclose aggregated information about our customers or Website visitors, and information that does not identify, directly or indirectly, any individual, without restriction.
Unless explicitly mentioned in the table below or through a clear notice to that effect, Personal Information collected by the Company is not sold, distributed, rented or communicated to other persons or organizations. The Company only communicates your Personal Information to certain types of third parties when it is necessary. We may disclose Personal Information that we collect or you provide as described in this privacy policy:
Subsidiaries and affiliates, as applicable
Personal Information collected by the Company is accessible by subsidiaries and affiliates who must access it as part of their duties and in accordance with the intended purposes set out in this policy. They are bound by this policy and agree to use Personal Information collected by the Company only in accordance with this policy.
Corporate event
In accordance with applicable law, we may communicate Personal Information 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 the Company, whether as a going concern or as part of bankruptcy, liquidation, investment, or similar proceeding., in which Personal Information held by the Company. about our customers and users is among the securities or assets transferred
Advertisers and advertising networks
We may communicate Personal Information to advertisers and advertising networks that require some 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.
Contractors, service providers, and other third parties
We may communicate Personal Information to contractors, service providers, and other third parties we use to support our business (service providers such as those assisting us with analytics and search engine providers for Website improvement and optimization) or that perform services on our behalf such as data processing, data warehousing or administrative services. Note that these third-party service providers and contractors 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.
Third party organizations who disclosed your Personal Information to us
We may communicate Personal Information to third party organizations who disclosed your Personal Information to us (with your consent) as part of a referral to (a) allow the third party to provide services to you (for example, where a mortgage provider refers you to us for insurance, we will inform them if you buy insurance from us so that they can confirm the mortgage), (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
Third party partners
We may communicate Personal Information to third party organizations who partnered with us to (a) allow the third party to provide services to you, (b) allow the third party to track referral conversion rates, (c) allow the third party to assist us with Website improvement and optimization
For example, if you are located in Quebec, we may disclose Personal Information you provide to us to the licenced broker Groupe Financier Lapointe Inc., in order to provide you with services you request. You may consult Groupe Financier Lapointe’s privacy policy here, https://lapointefinancialgroup.com/terms-policies, for Information on how your Personal Information will be handled once it is disclosed.
Third parties whose services are included in your Walnut membership
We may communicate Personal Information to third parties whose services are included in your Walnut membership. If your membership to Walnut includes services offered by third parties, the use of your Personal Information by those third parties to perform those services will be subject to their privacy policies, which you should review prior to signing up for a membership or adding the services to an existing membership.
We may disclose Personal Information that we collect or you provide as described in this privacy policy to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the Personal Information, and when you provide us your consent.
We may also disclose your Personal Information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
· To enforce or apply our terms of use www.gowalnut.com/terms-of-use and other agreements, including for billing and collection purposes, such as identifying and contacting user who violate our terms of use or engage in prohibited activities, processing payments, invoicing, resolving billing disputes and recovering outstanding debts or fess owed to the Company. Information could be communicated to payment processors, collection agencies, legal and regulatory authorities, professional advisors and partners and affiliates;
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes sharing Personal Information with law enforcement agencies or legal authorities in cases of suspected fraud, identity theft, or other criminal activities, providing necessary information to third-party service providers, such as credit reporting agencies, for the purpose of fraud protection and credit risk reduction and exchanging information with trusted partners or organizations to investigate and prevent potential security threats or violations of our policies; and
· In other circumstances for which we have your prior consent.
We, or our service providers, may process, store, and transfer your Personal Information in Canada and the United States, which may have different privacy laws that may or may not be as comprehensive as Canadian law.
We will take steps to ensure your Personal Information is adequately protected in accordance with applicable privacy and data protection laws while outside of your province of residence. However, please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is processed, including lawful access, for example, your Personal Information may be still accessible to law enforcement agencies, government agencies, courts, and national security authorities of the foreign jurisdiction
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See ”Contact Us” below for more information.
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 Personal 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 Personal 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. Some third parties may process your Personal Information nationally and internationally, which means that your Personal Information may be transferred outside Quebec. 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, or to meet any legal or regulatory requirements. At the end of this period, the Personal Information is destroyed or anonymized, in which case it will only be used for serious and legitimate purposes.
We do not target or knowingly collect Personal Information about children. Please contact our Privacy Officer at the contact information below under section “Contact Us” if you believe we have collected Personal Information about a child, and we will delete that information.
We make reasonable efforts to ensure that the Personal Information we have on file about individuals is accurate, complete and up-to-date as necessary for the purposes for which it is to be used, including Personal Information that is shared with third parties and Personal Information that is used to make a decision about an individual. Please keep us informed if your Personal Information changes and must be updated.
Depending on where you reside, you may have one or more of the following rights relating to your Personal Information:
• Right to opt-out: Subject to certain exceptions, you may “opt-out” or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your Personal Information. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to provide you with a particular product or service.
• Rights of access, correction and erasure: You may request access to and obtain a copy of any of your Personal Information that we hold, to request the correction of any inaccurate, outdated or incomplete information related to you or to request the deletion of your Personal Information under certain circumstances. You also have the right to know the types of Personal Information that is being collected. You can access your Personal Information by logging into the Website and visiting your account profile page. You may correct or update your Personal Information or withdraw your consent to the use and/or disclosure of your Personal Information at any time.
• Unsubscribe from marketing materials. You may unsubscribe from marketing materials to which you have subscribed by selecting the “unsubscribe” link in any marketing email or commercial electronic message we have sent you. You can also send us a request at the information under the section “Contact Us”. Please note that if you unsubscribe from marketing communications or the like, you will still receive transactional and other necessary communications from us.
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:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their Personal Information or confidential commercial information.
If you are a resident of Quebec, you also have the right to receive computerized Personal Information collected in a structured, commonly used and technological format and to have this information transferred directly to any person or body authorized by law to collect such information.
If you are concerned about our response or would like to correct the Personal Information provided, you may contact the Privacy officer at the Company at: privacy@gowalnut.com
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use www.gowalnut.com/terms-of-use.
The Company collects, uses and discloses your Personal Information for specific purposes. Your consent is valid for the time required to fulfill these purposes. If we wish to use or disclose your Personal Information for other purposes, we will seek your consent (unless otherwise permitted or required by law). Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide Personal Information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). By accessing and/or using any of our Website, you consent to the collection, use and disclosure of your Personal Information as described in this privacy policy. In the event that you do not consent to the collection, use or disclosure of such Personal Information as described in this Policy, you have the choice not to interact with the Company. Generally, by providing us with Personal Information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or de-scribed in this Privacy Policy, if applicable, or otherwise at the time of collection.
If you obtain insurance for a family member or other third party or otherwise provide Personal Information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her Personal Information for the purposes described above.
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 the Privacy officer at the Company at: privacy@gowalnut.com. 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.
We may make changes to this privacy policy at any time in order to reflect our practices. It is our policy to post any changes we make to our privacy policy on this page. We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact the Privacy officer at the Company at: privacy@gowalnut.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 us using the contact information listed above.