“Axxima” means Axxima Holdings Limited, 3303128 Canada Inc. (d.b.a. Axxima Insurance Services and Alternative Risk Services) and Axxima Inc.
“Personal Information” means personally identifiable information that relates to a natural person and allows that person to be identified either directly or indirectly, that entails a high expectation of privacy. Personal Information does not, however, include business contact information such as name, title, business address, telephone number or email address that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession.
“Privacy Legislation” means applicable privacy legislation including the Act respecting the protection of personal information in the private sector, c.P-39.1 (the “Quebec Act”), Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31 (the “Ontario Act”) and Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 (“PIPEDA”) as each may be amended from time to time.
“Privacy Officer” means the person designated by Axxima responsible for ensuring that Axxima complies with the obligations imposed by Privacy Legislation and for addressing access to information requests, requests for the correction of Personal Information, and questions or complaints concerning the handling of Personal Information.
Protection of Personal Information
1. How Axxima Collects and Uses Personal Information
Axxima only collects and uses Personal Information for purposes that we believe would be considered reasonable in the circumstances and only such information that is required for the purposes of providing products, services or information to our clients.
Axxima’s use of Personal Information is limited to the purposes described in this Policy and Axxima will not sell, trade or barter Personal Information to another party for consideration.
2. When We May Disclose Personal Information
We may disclose Personal Information to our affiliates and partners for the purposes of providing or assisting us in providing products, services and information to our clients. We will not disclose Personal Information unless it is required in order to provide those clients with products or services or to administer and manage our products and services.
If we transfer or disclose Personal Information to third-party providers, we will require such third-party providers to use such Personal Information solely for the purposes of providing services to us or our clients and to have appropriate safeguards for the protection of such Personal Information.
There are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we may be obliged to disclose information without consent. Such circumstances may include:
- where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
- where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
- where the information is public, as permitted by law.
Where obliged or permitted to disclose Personal Information without consent, we will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected without first obtaining the consent of the individual concerned to the collection, use, disclosure, retention or dissemination of that information.
Individuals have the option, upon reasonable advance notice and subject to legal and contractual restrictions, to refuse or withdraw consent to the collection, use, disclosure or retention of Personal Information. It should be noted that in certain circumstances, products and services can only be offered if we are allowed to collect and continue to use Personal Information.
4. Accuracy and Retention of Personal Information
We endeavour to ensure that any Personal Information provided and in our possession is as accurate, current and complete as necessary for the purposes for which we use the information. If we become aware that Personal Information is inaccurate, incomplete, or out of date, we will revise the Personal Information.
We keep Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of our relationship but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date, in accordance with our document retention policies, and as required by law. When Personal Information is no longer required, we have procedures to securely destroy, delete, erase or convert it into an anonymous form.
5. Safeguarding Personal Information
We endeavour to maintain appropriate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
We use contracts and other measures with our partners, third-party providers or any other outside suppliers to maintain the confidentiality and security of Personal Information and to prevent it from being used for an unauthorized purpose.
6. Access to Personal Information
An individual can ask to review the Personal Information we have about them in our files. Requests must be made in writing and sent to us by letter to our physical address or through email, as provided below. We permit the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
We reserve the right to decline to provide access to Personal Information for reasons permitted by law. Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Contacting Us About Privacy Concerns
In the event of questions about:
- access to Personal Information;
- our collection, use, management or disclosure of Personal Information; or
please contact our Privacy Officer by sending an e-mail to firstname.lastname@example.org or calling 1.855.729.9462.