WHAT IS PERSONAL INFORMATION
“Personal Information” is information about an identifiable individual. However, it generally does not include business contact information when used to contact a person in respect of their business role or function. Sometimes we will de-identify information in order to use and share that information for our business purposes in a way that does not identify you. For example, we may aggregate your personal information with other individuals to prepare claims statistics.
WHY WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
Personal information may be used for the following purposes:
- To determine eligibility and process applications for products and services and to provide information and services
- To understand and assess ongoing needs of Clients and potential Clients and offer products and services to meet those needs
- For communication, service, marketing, billing and administration
- For fraud detection and prevention
- For analytics purposes
- To develop proprietary tools and databases
- To provide consulting services to insurance companies
- To comply with legal, audit, security and regulatory requirements
- Other purposes disclosed in our terms of business or disclosed to you at the time of collection, use or disclosure.
WHAT INFORMATION WE COLLECT
Depending on the products or services you request, we may collect information that you provide on applications for products and services, such as your first name, last name, email address, company, company size, role, and phone number. To assess risk or if you make a claim, we may collect information from insurers, industry associations, claims adjusters, and consumer reporting agencies.
CONSENT TO USE PERSONAL INFORMATION
We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent can be verbal (in person or over the telephone), written or by electronic application (including email). Implied consent occurs when we can assume you have given consent by some other action you take or decide not to take. For example, if you request a specific product or service and provide us personal information in that regard, we infer that you consent to us using that personal information reasonably to provide this service.
If you need to provide personal information about other individuals (such as employees, dependents, etc.), you must obtain their consent for these purposes prior to your disclosure to us.
In certain circumstances, refusing to provide personal information or withdrawing consent will mean that you will not be entitled to insurance policy issuance or renewal, insurance underwriting or claims administration of existing policies. Additionally in certain circumstances, we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, for fraud detection or prevention, or if we must comply with a court order.
SHARING PERSONAL INFORMATION WITH OTHERS
SEB only discloses personal information as is required and described in this Policy or as otherwise required by law. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or agents who perform various functions for us. Such parties may be located in Canada, or in other jurisdictions outside of Canada. While your personal information is always subject to confidentiality obligations, while stored in another jurisdiction, it may be subject to the laws of that jurisdiction.
Depending on the products or services that we provide to you, we may disclose personal information to insurance companies, reinsurers and other parties who have a need for the information in order to make available insurance coverage and other products and services. We also share information with claims adjusters and insurers in order to settle claims. If we are legally entitled to do so, we may share information with consumer reporting agencies, insurance reporting agencies and governmental authorities when requested to do so or in order to protect our business. We may also be required by law or by rules of arbitration or rules of court to share information.
As SEB continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of client relationships, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets. We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves, our affiliates or reputable organizations selected by us. If you do not wish to receive these offers or such information, please contact our Privacy Officer as outlined below in the Contact Information section.
KEEPING INFORMATION ACCURATE
It is important that your personal information is accurate and complete. Having accurate information about you enables us to give you the best possible service. You have the right to access, verify and amend the information we have about you. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly. To keep personal information up-to-date, please inform us of any changes, such as a change of address, telephone number or any other circumstances by contacting your local office representative.
HOW WE SAFEGUARD PERSONAL INFORMATION
We will use reasonable efforts and security measures to protect Personal Information against loss or theft, as well as unauthorized access, use and disclosure. We have controls in place to maintain the security of our information and information systems. Files containing Personal Information are stored according to the sensitivity of the information contained therein and are backed up at offsite locations. Appropriate technological controls (such as passwords, encryption, firewalls) are placed on our computer systems and data processing procedures. Physical controls (such as locked filing cabinets, restricting access to offices, alarm systems) are in place as are organizational controls (such as staff training and access on a “need to know basis”).
We may store and process your Personal Information at our offices in Canada, or elsewhere, including outside Canada. To the extent we employ third-party service providers to store, access, handle or process Personal Information on our behalf; we will use contractual and other means in an attempt to provide a comparable level of protection. Service providers, however, may be located in various countries, so please be aware that authorized officials of governments in those countries may be lawfully able to access your Personal Information without your knowledge or consent pursuant to the laws of such countries.
Employees are governed by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.
In this policy we use the term “cookies” to refer to cookies and other similar technologies which can raise privacy concerns in electronic communications.
What is a cookie?
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Cookies are alphanumeric identifiers transmitted from a website to a visitor’s browser and IP address or web beacons that detect when you take actions on our websites).
“Cookies” are small text files that contain a unique identification number that allows our computers to identify your web browser (but not you) each time you visit our website.
This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit our website. This information is collected using “cookies” and might include the pages you visited, your IP (Internet Protocol) address and other site usage statistics. This anonymous information is used for research and analytical purposes only (like evaluating how many visitors our website receives, which pages are visited most often or to provide users with a customized online experience and to find ways to improve our site and marketing communications). It does not reveal any Personal Information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.
Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies. Further, users can delete cookies at any time.
SEB may collect user information from its websites.
What types of cookies do we use?
We use both first-party and third-party cookies on our website.
Third-party cookies belong to and are managed by other parties, such as our business partners or service providers. These cookies may be required to render certain forms, or to allow for some advertising outside of our website.
Session cookies are temporary cookies that are used to remember you during the course of your visit to our website, and they expire when you close the web browser.
Persistent cookies are used to remember your preferences within the website and remain on your desktop or mobile device even after you close your browser or restart your computer. We use these cookies to analyse user behavior to establish visit patterns so that we can improve our website functionality for you and others who visit our website(s). These cookies also allow us to serve you with targeted advertising and measure the effectiveness of our site functionality and advertising.
How are cookies used for advertising purposes?
Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable us to understand and improve the delivery of ads to you, and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.
How are third party cookies used?
How do I reject and delete cookies?
The following is a typical list of some common Cookie types that we use or intend to use in the future, with an explanation of their functionality:
- Google Analytics: We use Google Analytics to understand how our media campaigns work and how you interact with our website in order to improve the user experience.
- Google tracking cookies: Google tracking cookies enable us to understand if you complete certain actions on our website(s) after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our websites Google are able to deliver some targeted adverts across other Google partner websites.
- Facebook: Facebook helps you stay in touch with your network through their website/ mobile application. We make it easier for you to share any content of interest on Facebook and sometimes, we may present with some targeted adverts on Facebook based on your engagement with our website(s).
- LinkedIn: The LinkedIn insight tag allows us to perform campaign reporting and unlock valuable insights about website visitors that may come via the campaigns we run on LinkedIn.
- Twitter: Twitter provides real time updates from across the globe on the latest trending stories, ideas and opinions from the Twitter accounts or hashtags that you choose to follow. We make it easier for you to share our website content over Twitter. At times, we may present you with some ads on Twitter based on your engagement with our website(s).
- Youtube: We embed videos or insert links to videos from YouTube on our website(s). As a result, when you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from YouTube.
B. Other Information Sharing
SEB may send you commercial electronic messages to an email address or other electronic address that you have provided to us. We may ask for your express consent or we may rely on implied consent if you have made an inquiry, purchased a product or service from us, entered into a written agreement with us, or in other limited circumstances. If you do not wish to receive commercial electronic messages from us, you may withdraw your consent at any time using the unsubscribe link in the message or by contacting us as indicated below. Please note that you will still receive commercial electronic messages that we are required to send to you by law or for which consent is not required, such as confirmations of transactions or information about your account.
C. Third Party Sites
DOES SEB COLLECT INFORMATION FROM CHILDREN?
Our websites are not directed to children and we do not knowingly collect personal information from children on our websites. By using our website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have authority to submit any information submitted on behalf of any of your minor dependents.
ADDRESSING COMPLAINTS AND SUGGESTIONS
CHANGES TO THIS POLICY
This Policy was last updated on February 11, 2022.