1. Personal information is any information that is identifiable with you. This information may include, but is not limited to, your name, mailing address, phone numbers, email address, identification numbers, credit card numbers, banking information, and creditor information. Personal information however, generally does not include your name, business title, business address or business telephone number in your capacity as an employee of an organization. 

2. The purposes for which Toole Peet collects, uses and discloses your personal information include:

(a) To provide services to you, including the following:

i. To enable us to quote, acquire or renew your insurance policies, including disclosure of personal information to companies which may supply you with insurance or other related financial products;
ii.To assist you in assessing your ongoing insurance needs;
iii. To assess your need for other related products such as financial products;
iv. To investigate and pay claims;
v. To ensure that your information in our possession is accurate and up to date; and
vi. To assess and facilitate the payment of premiums;

(b) To complete a transaction with you when you purchase a product or service from us;
(c) To advise you of products or services that may be of interest to you; and
(d) To respond to inquiries you submit.

As part of obtaining the consent discussed below, we will specifically seek your consent to disclosure and use of your personal information for this purpose. Toole Peet may also use your personal information as otherwise permitted or required by law, including particularly the Personal Information Protection Act and as more particularly described below in this policy.

3. Note that without your consent to the collection, use and disclosure of your personal information as more fully detailed in this Privacy Policy, Toole Peet may be partially or completely unable to provide you with the services that you may request. In some cases, Toole Peet is subject to other regulatory requirements on the information we are required to know in order to assist you with your insurance and other financial product needs. In other cases, the information we are requesting and are disclosing is necessary and reasonable for Toole Peet to provide the most useful and appropriate products and services for you.

4. Toole Peet has:

a. established and put into effect policies and procedures aimed at properly protecting personal information;
b. educated its staff regarding its privacy policy and their role and responsibilities in keeping personal information private; and
c. appointed a Privacy Officer to oversee privacy issues at Toole Peet.

This policy may change without other notice to you, and so we encourage you to review this policy and the consents provided for herein on each occasion on which you provide personal information to Toole Peet.

5. Toole Peet takes measures to ensure that agencies and third parties who are engaged to perform services on our behalf and are provided with personal information are required by contract to observe the intent of this Privacy Policy, except in the case of those agencies which have informed us that in their view, the Federal or Provincial privacy legislation is not applicable to them. Some of the entities which we may disclose your information and which have advised us that they do not believe Federal or Provincial privacy legislation is applicable to them. If you wish to receive more information in this regard, please contact Toole Peet’s Privacy Officer.

Collection of Personal Information

6. Toole Peet will obtain your consent before collecting personal information from you, unless Toole Peet is permitted or obligated to obtain such personal information without consent.

7. Toole Peet’s policy is to always try to inform its customers and employee of purpose for which it is collecting personal information from you before it is collected. Such consent is intended to be informed after an explanation to the person whose information we are collecting as to the purposes and intended uses or disclosure of such information.

8. We will always collect your personal information by fair and lawful means (for example, when you complete an application form or purchase a product or service from us). We may collect personal information about you from third parties, such as the Provincial Institutes and other institutions and organizations.

9. We may also collect personal information where we have not obtained consent if we are permitted or required by law to do so. For example, the Personal Information Protection Act allows collection of personal information to facilitate certain business transactions. Such circumstances are likely to be extraordinary and only done upon careful review and reflection by Toole Peet.

Disclosure of Personal Information

10. Toole Peet discloses your personal Information only for purposes for which it has consent, or as permitted or required by law. Toole Peet retains personal information only as long as necessary to fulfill those purposes.

11. Where possible, we identify to whom, and for what purposes, we will disclose your personal information, at or prior to the time we collect such information from you. However, in some circumstances a particular disclosure may not be apparent at the time of collection and, in those circumstances, we may obtain your consent after we collect personal information from you but before we disclose such information. For example, we may disclose your personal information to your insurer and you will usually provide that consent prior to us collecting personal information.

12. We may disclose personal information without consent if we are required or permitted to do so by law and in accordance with the Personal Information Protection Act. For example, Toole Peet may be obligated and authorized to disclose certain information to to assist in an investigation. Such circumstances are likely to be extraordinary and such disclosure will only be made upon careful review and reflection by Toole Peet.

13. We will ensure that your personal information is kept as accurate, complete and up-to-date as possible based on information provided to us by you or any agency. We expect you from time to time, to supply us with written updates to your personal information, if applicable.

Use of Personal Information

14. Toole Peet uses your personal Information only for purposes for which it has consent, or as permitted or required by law.

15. Where possible, we identify to whom, and for what purposes, we will use your personal information, at or prior to the time we collect such information from you. However, in some circumstances a particular use may not be apparent at the time of collection and, in those circumstances, we may obtain your consent after we collect personal information from you but before we use such information. For example, we may use your personal information to contact you to advise of insurance policy renewals that are upcoming.

16. We may use personal information without consent if we are required or permitted to do so by law and in accordance with the Personal Information Protection Act. For example, Toole Peet may be authorized to use certain information if the use of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way. Such circumstances are likely to be extraordinary and such use will only be made upon careful review and reflection by Toole Peet.

Policies Specific to Toole Peet’s Website

17. You can visit our website without telling us who you are or revealing any information about yourself including your email address. However, our web server may collect the IP address and domain you used to access our website, the type and version of web browser and operating system you are using, the number duration and frequency of visits to our website and the website you came from and visited next. This anonymous information cannot be traced to a specific individual user, it is used by us simply to measure the number of visits, average time spent, page views, most popular preferences and other statistics about visitors to the website and to determine the characteristics in which users use our Web Site and services. Toole Peet may use this data to monitor website performance for systems administration purposes, to make our Web Site easier and more convenient to use, to improve our services and to track information in aggregate form, for example how many visitors use the website.

18. If a user of Toole Peet’s website is accessing portions of the website that require authentication, Toole Peet uses cookies, that is, small files that your web browser places on your computer’s hard drive, to remember a user’s code, password and preferences while the user is using our website and to facilitate navigating different pages on the website.

19. Our website contains security mechanisms that protect against loss, misuse and the modification of information under our control.

20. Our website links to third party websites. Our Privacy Policy does not extend to these third party websites and it is recommended that users read the privacy policies of these websites. We are not responsible for the content of, or the privacy practices employed by, third party websites.

21. Similarly, if Toole Peet makes a disclosure of personal information to one of our insurance providers, and such disclosure has been made in compliance with this Privacy Policy, Toole Peet has no control over, and is not responsible for, the use or disclosure of your personal information by those third party partners. Note that some of Toole Peet’s insurance providers that we deal with may provide information to individuals or organizations located outside of Canada and which may be subject to the respective laws regarding the protection of personal information in the jurisdiction in which they operate, which may be more or less restrictive than those of the Province of Alberta. If you have concerns about the disclosure of your personal information to any particular jurisdiction outside the Province of Alberta, please contact Toole Peet’s Privacy Officer as described below.

Records and Security

22. We will ensure that your personal information is kept as accurate, complete and up-to-date as possible based on information provided to us by you or any agency. We expect you from time to time, to supply us with written updates to your personal information, if applicable.

23. We may keep a record of your personal information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law.

24. Toole Peet endeavors to keep accurate, complete, and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.

25. Toole Peet protects the privacy information in its possession or control by using safeguards appropriate to the sensitivity of the information.

26. Toole Peet has implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification.

27. Toole Peet responds on a timely basis to requests from customers about their personal information which Toole Peet possesses or controls.

28. We will generally make available to you any personal information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law. We will make sure information available to you in a form that is generally understandable, including explaining any abbreviations or codes.

29. You can at any time, challenge the accuracy or completeness of the personal information we have which is related to you. Once we have validated your identity, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information.

30. We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit.

31. We encourage you to direct any comments, questions, concerns or complaints regarding your personal information or our Privacy Statement and Practices, should be forwarded to our Privacy Officer as follows:

In writing:

Toole Peet Insurance
Attn: Privacy Officer
PO Box 4650, Station C
1135 – 17th Avenue SW
Calgary, Alberta  T2T 5R5

Email:
privacy@toolepeet.com

We will inform you of the relevant procedures when you make an inquiry or lodge a challenge or complaint.

If you are not satisfied, you may contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner (Calgary)
Suite 2460, 801 6 Avenue SW
Calgary, AB  T2P 3W2
Phone: (403) 297-2728
Fax: (403) 297-2711
Toll-Free: (888) 878-4044
Email: generalinfo@oipc.ab.ca
Website: www.oipc.ab.ca.