Legal

This policy was last updated: September 2021

What’s New:

We have recently updated our privacy policy to:

• Clarify the scope of its application
• Explain how we may collect and use personal information when you interact with us on our website(s), portals or social media
• Clarify when we may need to seek your consent

Introduction

The Independent Order of Foresters and its subsidiaries, including Canada Protection Plan Inc. and affiliates (collectively Foresters) maintain the privacy and security of individuals’ personal information while collecting, using and disclosing personal information. We support the rights of individuals or their authorized representatives to access, correct or delete their personal information in our control, as required by applicable laws. We will not collect, use or disclose personal information except as described to you in this privacy policy, where you provide your consent, or where we are otherwise permitted by law to do so. Personal information is information about or that relates to you and that can identify you, as set out in Canadian privacy laws.

This Privacy Policy applies to all of our operations in Canada, unless we have provided you with a separate privacy statement for a particular service or activity.

Information We Collect

We generally collect your personal information when you submit an application, provide it to an insurance advisor, or provide it through other electronic or paper means, and from your transactions and other interactions with us. This information may include the following personal information:

• Information such as your name, address, email address, telephone number, date of birth, social insurance number or citizenship.
• Financial information, such as your income and banking information.
• Health related information, such as health and medical information or information about your lifestyle and habits.
• Information about your interactions with us, such as when you visit our websites, applications, social media sites or when you call our service centres.

We collect your personal information in the following ways:

Directly from you: We collect personal information from applications and other forms that you submit to us, such as when you apply for insurance or file a claim. We also collect personal information from our telephone conversations with you and information you provide us online. This personal information may include your name, address, social insurance number, financial data, health history and biometric data such as your voiceprint should you choose that option when you call us.

Automatically or indirectly from you: We collect personal information when you use our products and services, from your transactions with us or others, and when you use or interact with our websites or social media sites. For example, we may collect information such as online identifiers including location data, your Internet Protocol (IP) Address, device or browser type, or information about how long you used the website and pages visited.

From third parties and other sources: We collect information from third parties such as your insurance advisor, consumer reporting agencies, other service providers who process or administer products or services requested by you, and from health care providers, clinics, and other insurance companies. We may also collect information from the Medical Information Bureau or other persons that have records about you or your health. These third parties from whom we obtain information collect information and disclose it to other persons pursuant to their own privacy policies and practices.

Online Privacy

Foresters understands that you care about how we collect, use and share information when you interact with us online through our websites, online services and applications (collectively “Sites”) and through social media platforms.

Some of our Sites may collect your personal information and use online data analytics tools or cookies. We use these technologies to improve functionality, enhance security, evaluate the effectiveness of our Sites and advertising campaigns, or to improve your online experience.

Our Online Privacy Statement explains the types of personal information we collect through our Sites, how we use and protect that information, and the choices you have regarding our collection, use and sharing practices. You can also learn more about how we use cookies in our Cookies Policy.

View our Online Privacy Policy

Why do we collect your information and how do we use it?

The primary purpose we collect your personal information is so that we may offer and deliver the products and services that you request and that are suited to your needs.

We use your personal information to help us to:

• Assess your eligibility for our products and services
• Market and administer our products and services
• Administer, manage and communicate with you about your and our products and services
• Investigate and pay claims and to process transactions
• Respond to your inquiries or complaints
• Identify and mitigate potential losses to you and/or Foresters, for example to verify your identity, to detect, prevent, or investigate fraud or security breaches
• Hold and inform you of fraternal and community events and activities and operate our branch system
• Conduct industry or market research, including by de-identifying your personal information and using such information
• Support and optimize the user experience on our websites and to develop and improve our products and services
• Fulfill our legal and regulatory obligations

We may also use and disclose your information as otherwise permitted or required by law.

Your Consent

We collect, use and share your personal information only for disclosed purposes related to the insurance and related services and fraternal benefits we offer, and only with your consent or as permitted or required by law. Your consent may be expressed in writing, or it may be given verbally, electronically, or through our or your authorized representative(s). Depending on the circumstances and the sensitivity of the personal information, where it is appropriate to do so your consent may also be implied or inferred. You may withhold or withdraw your consent for us to collect, use and disclose your Personal Information, subject to legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the insurance services and fraternal benefits you have requested.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Policy.

Limiting Use and Sharing

The disclosure of and access to your personal information will be restricted to those who have a need for, or the legal right to, the information.

Some of our business areas, subsidiaries or affiliates may, from time to time, offer or promote other financial products, benefits or services, or those of select third parties, that we believe may be of interest to you. We may also have joint marketing or distribution agreements with other financial institutions that may offer or promote products that we believe may be of interest to you. We will not disclose your personal information, without your consent, with any third parties for the purpose of that organization marketing their own products or services directly to you. We may disclose your personal information to insurance agents and agencies for the purposes of those agents to process or administer products or services requested by you.

We may also share your personal information with service providers (including our subsidiaries and affiliates) or insurance agents and agencies, including to process or administer products or services requested by you and for marketing purposes, and to other service providers such as email and other internal service providers, payment card processors, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers. We will not share your personal information, without your consent, with any non-Foresters organization for the purpose of that organization marketing their own products or services directly to you.

Additionally, we may use and disclose your personal information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business transaction.

How Do We Protect Your Information?

We strive to protect your personal information in our possession or control, including information transferred to a third-party service provider or representative, from the risk of loss, unauthorized access, disclosure, modification, or misuse. We comply with applicable laws and regulations and have implemented reasonable physical, electronic and procedural safeguards to protect your information that are appropriate for its sensitivity. For example, we encrypt your personal information and we use advanced firewall technology and layered security tools to protect our environment.

In some instances our employees, advisors, service providers, representative, reinsurers and any of their service providers may be located in provinces or other jurisdictions outside Canada. Your personal information may then be subject to the laws of those other jurisdictions and these other jurisdictions may have different privacy and data protection laws than your jurisdiction. All such persons, whether or not they are located in Canada or outside Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policies and practices. We regularly train employees to keep your information safe. Despite the measures outlined above, however, no method of information transmission or information storage is completely secure or error-free, so we unfortunately cannot guarantee absolute security.

For written information about our policies and practices regarding service providers outside of Canada, contact us using at the contact information in the “Contact Us” section below.

Your Rights and Choices

You have the right to request in writing, to access and verify your personal information maintained in our files, and to be informed of the use and disclosure or your personal information. If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it, or you may contact us to update your personal information in our records. We will address any such request as required by applicable law.

Complaints

If you have a concern regarding our collection, use, and disclosure of your personal information you may contact us and we will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to address your complaint as required by law, including by changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.

Updates to This Privacy Policy

We may amend this privacy policy from time to time to reflect changes in our personal information practices. We will post the revised policy on our website and make it available to you upon request. If the changes are substantial, we may also notify you of the changes using our customary methods of communication with you, including any of the following ways:

• A notice sent by email
• A notice or announcement on Foresters website or member portal, MyForesters.com
• A notice included with other correspondence or communication that we periodically send to you.

Contact Us

If you have any questions or wish to contact us about this policy, you may contact us:

Toll-free: 800-828-1540

By email:
Foresters Financial
Attention: privacy@foresters.com

Canada Protection Plan
Attention: privacy.officer@cpp.ca

By regular mail:
Foresters Financial
Attn: AVP, North American Compliance Officer and Assistant Chief Privacy Officer
789 Don Mills Road
Toronto, Ontario
M3C 1T9

Foresters Online Privacy Policy

This Online Privacy Policy applies to visitors to Foresters websites and users of Foresters mobile applications (collectively “Sites”) and supplements our privacy policies. It outlines the types of personal information we collect through our Sites, how we use it, with whom we share it, and some of the choices you can make about our use of the information. This Online Privacy Policy should be read in conjunction with our Privacy Policy.

Information We Collect Online

Using various technologies, Foresters may collect various personal information about visitors to our Sites. Personal information is information about or that relates to you and that can identify you, as set out in Canadian privacy laws.

Personal Information we collect in connection with our Sites may include:

Information about your browser, IP address, device type or how long you have used the site and the pages you have visited. Click here to learn more about how we use cookies.

We may also collect anonymous data about visitors to our Sites, such as browsing history or location data.

Analytics

We use Google Analytics, Web Trends and similar analytics service providers (“analytics services”) to collect various types of data about use of our Sites. We use this data to monitor and improve our Sites, measure the effectiveness of our marketing and engagement campaigns and to offer you content, products or services that may be of interest to you.

Advertising

Foresters may contract with advertising and marketing service providers to promote our brand, products and services, across different media, including on third party websites that are not affiliated with us. Third parties, including Facebook and LinkedIn, may use cookies, web beacons and similar tracking technologies to gather information about your online activities, including your interactions with our Sites and the pages you visit. You have a variety of tools to control the data collected by cookies, web beacons, and similar tracking technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

We may use this information to deliver advertisements to you, both online and offline, that are customized to meet your specific interests. For example, we may send a marketing email based on a consumer’s interaction with a specific Site. We may use aggregated and de-identified data, along with other personal information we have about you and your relationship with Foresters to determine which advertisements, products or services may be of interest to you, display them to you, monitor responses, and help us measure customer engagement.

To learn more about your choices relating to the collection and use of data for analytics or targeted advertising, visit https://youradchoices.ca/

Social Media and Third Party Websites and Services

We use social networking platforms such as Facebook, Instagram, LinkedIn, Twitter and YouTube (“social platforms”) to provide product and service information, articles, news, community events and career opportunities. These social platforms facilitate online sharing and collaboration among users who have registered to use them. Any content you post on social platforms, such as pictures, videos, information, “Likes”, or any personal information you choose to make available on these platforms is subject to the terms of use and privacy policies of those platforms. We may receive personal information about you when you use such social platforms, for example your profile picture.

Some of our websites may include social media buttons or icons (“plug-ins”) that enable users to easily share information on a social platform. These plug-ins may log certain information such as your IP address, browser type and language, and the web pages you have viewed. If you are logged into a social platform while using our websites, they may also link information collected with your profile on that social platform. Foresters does not control these third party tracking technologies. We encourage you to review the privacy policies on social platforms where you have an account to better understand how they collect and treat such information. Foresters is not responsible for the privacy or security practices of the social platforms we use.

Neither this Online Privacy Policy or our Privacy Policy extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites, products or services.

You can view the Privacy Policy on Foresters Financials’ Canadian Privacy Page at https://www.foresters.com/en-ca/legal?t=privacy%20policy#tabs

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