• “Personal Information” or “PI” is information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked (directly or indirectly) with you. 

• “Use” of Personal Information means how Greatway processes or handles information internally or via our service providers who act on our behalf. 

• “Disclosure” of Personal Information means how Greatway shares information with third parties who do not act on our behalf. 

• “Third Parties” or “Suppliers” means our service providers to support our main operations and offerings 

• “Agents” (also known as Advisors) means contracted individuals by Greatway Financial who are licensed insurance brokers 

• “You” means you directly, whether you are a customer, applicant, website visitor, member or otherwise interacting directly with Greatway, or when another person or organization provides us with your information. 

The type and amount of Personal Information we collect depends on various factors, such as the type of products you apply for and buy, the services you have access to and use and the way you decide how to communicate with us. We collect personal information about you in several ways from various sources, including: 

i) Information you give to us. 

• We collect Personal Information directly from you, either in person, over the telephone, via email, and through our websites and service desks. We obtain your express consent when we interact directly with you. 

• We may record calls, online chats and other communications between us to ensure quality customer service, confirm our discussions and your instructions, resolve complaints, and train our staff. We ask for your consent to do so. If you do not want your communications recorded, you can do business with us by visiting one of our offices, or by writing or emailing us. 

ii) From third parties. Greatway may collect PI from service providers and other third parties, including: 

• Third party websites where you have entered your PI for the purpose of receiving an insurance quote or marketing materials 

• Credit reporting agencies for our agents 

• Healthcare providers when we refer our customers to an insurer 

• Information technology support providers 

• Claims support, handling and investigation services 

• Other individuals, including other customers and applicants, for example, where you are covered by another customer’s insurance. We expect the person providing your Personal Information to ask for your permission and get your consent to this Privacy Policy. We might also obtain information about you from another individual who is involved in a claim, like a witness. 

iii) From government bodies and law enforcement. If you apply for insurance products with us, we may also collect Personal Information (PI) for verification and investigation purposes from government bodies and law enforcement services. PI we collect from these sources may include: for example from lenders, as part of financial needs analysis as well as for insurability purposes, health and lifestyle and avocations. 

iv) Information we observe. When you interact with us, we may observe and record certain Personal Information through technology. This includes: 

a) Cookies, web beacons, and other website tracking technologies. We and service providers working on our behalf collect IP address, device ID, browsing history and other internet and web 

browsing information when you use our websites, mobile apps, view our emails or otherwise engage with us through a computer or mobile devices. 

b) Video Surveillance. For the safety of the public, Greatway customers, and Greatway employees, our premises may be outfitted with video surveillance systems. Video surveillance is collected strictly for security purposes and will not be disclosed to Third Parties unless required by law except in efforts to prevent fraud. 

The personal information we collect, and process, may include: 

• Identifying Information – your name, gender, age, date of birth, marital status, driver’s license information, preferred language and copies of your identification. 

• Contact Information - email address, mailing address, telephone number. 

• Service or product related information - policy coverage information, premiums, account name, policy number, payment history, claims history, records of assets and liabilities, insurance related products or services purchased, obtained, or considered, personal health history, immediate family health history, beneficiaries names and date(s) of birth, place of employment, occupation, salary or compensation, hobbies, lifestyle, criminal history, financial history, Canadian residency information and address, tax related information (according to Canadian regulations). 

• Financial information – bank account number, credit or debit card number, credit information, other payment or financial information. 

• Information about your place of residence – to inform our referral decisions to specific insurance providers. 

• Information about your investment preferences and feedback- data related to your investment preferences or use of our products and services (including feedback). 

• Online activity information – Browsing history, search history, information regarding your interaction with our websites or ads, browser type, internet service provider (ISP), cookies, and mobile device information including device identifier or other information. 

We use your personal and other information to operate our business, provide and develop our products and services, engage with you, communicate within our organization and with our suppliers, communicate with brokers, manage our risks, and comply with legal requirements. This includes to: 

i) Provide products and services. 

(a) We may use your personal information to: 

• Evaluate your coverage needs 

• Assess risk and share your information with potential insurers to review underwrite insurance risks 

• Verify your identity 

• Provide a quote for insurance to you 

• Send policy documents, renewal offers, policy change information, and any other administrative documentation regarding your policy or policies 

• Facilitate payments for your insurance policy or policies or for our merchandise (should you decide to purchase any of our merchandise we offer) 

• Communicate with you, solicit feedback regarding our products and services, and to respond to your inquiries 

• For services offered, you may review them here. 

(b) We may also collect information about other parties from you to carry out necessary services and/or requests, including adding another person to your existing policy. If you provide personal information about others to us, or if others give us your personal information, we will only use the information for the specific reason for which it was provided. 

ii) Improve, develop and analyze our business. We use your personal information and other information to: 

• analyze, improve, develop or deliver our websites, products, services features, contests and events; 

• conduct actuarial and/or research studies to maintain, protect and develop our networks, services, products, and protect our customers; 

• enhance and personalize your experience. 

We collect some information used for these purposes using analytics software, cookies and other tracking technologies. For more information about the collection and use of this information, see Cookies and Other Technologies below. 

iii) Communicate with you. We may communicate with you regarding products, services, policy(s), or membership/account; provide you transaction confirmations, payment alerts or other service or product-related messages via physical mail or email, telephone, to facilitate response to your inquiries. 

iv) Market to and communicate with you. We may: 

• send you promotional communications about products, services, features, offers, events and contests offered by Greatway or companies with whom Greatway maintains business relationships only if you have already established a business relationship with Greatway Financial 

• we may also serve ads on social medial platforms where Greatway is present, but we don’t specifically target individuals who visit the same platforms 

• we may respond to inquiries you make when you become a member of a social media platform group provided by Greatway 

• appear as marketing partners with our providers if they chose to add us on their marketing campaigns 

v) Comply with legal requirements and protect the safety and security of our business, services, and websites. We may use your personal information to: 

• comply with laws, regulations or other legal obligations 

• assist in an investigation 

• protect and defend our rights and property, or the rights of third parties, or enforce terms and conditions 

• detect, prevent and suppress fraud, and other illegal activities 

• prevent misuse or for any other reason permitted by law 

• protect our company, our affiliates, our customers, our network and our websites 

• to provide secure premises for our customers, employees, and the public. 

Our Service Providers 

We rely on third party service providers to support our business operations and fulfill the purposes set out above. We use service providers to: 

• Deliver and improve our products and services 

• Process insurance applications 

• Communicate information to you through electronic and physical mailing services about your policies 

• Support the operation of our websites 

• Store and protect our data 

• Obtain advice from third party advisers, such as lawyers and accountants 

• Conduct surveys, studies and data analytics 

• Facilitate payment processing 

• Market our products and services, including through contests, online advertising, and other communications as mentioned in our Market to and Communication section above 

• Meet compliance and legal requirements 

• Receive, assess and investigate complaints 

Our website technologies are managed by service providers. You can access information about each service provider’s privacy practices and how to opt out below: 

• Google. We use Google Analytics to better understand your use of our website. Google Analytics collects information on user behavior on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. To learn more about how Google uses data when you visit websites using Google Analytics, click here. You can deactivate the Google Analytics function with a browser add-on, which you can download here. 

Your choices regarding cookies: If you prefer not to accept cookies, change your browser settings to disable or block cookies, remove existing cookies, automatically accept cookies or to notify you when you receive a cookie. However, if you disable, modify, or reject cookies, some parts or functionalities of our Site may be inaccessible or not function properly. 

To limit interest-based advertising based on Site technologies visit AdChoices in Canada (youradchoices.ca). You may continue to see generic or non-targeted ads about our products and services if you opt out of interest-based advertising. 

We do not sell Personal Information to third parties. We may disclose some of your Personal Information to third parties for business purposes or as required or permitted by law, including with: 

• Insurance providers 

• Service contractors 

• Consumer reporting agencies 

• Insurance industry databanks 

• Government authorities 

• Educational and research institutions 

• Healthcare professionals and assessment facilities 

• Law enforcement agencies and/or bodies 

• Select businesses with which Greatway maintains relationships or with whom Greatway has marketing agreements 

Where we are permitted or required by law to disclose PI to third parties, we provide only the minimum amount of PI required to meet the objective or requirement. 

At Greatway Financial, personnel and agents must sign off and complete training on various privacy and security policies and procedures which address the personal information lifecycle. Our internal Privacy Policy identifies and sets expectations for roles and responsibilities inside Greatway, to ensure all personnel and agents fully understand how they need to handle and protect personal information. 

Greatway uses technical, physical and procedural (or administrative) security and data protection measures to safeguard Personal Information under our control, throughout the information lifecycle, which include but are not limited to: role-based access controls, limiting access only to a need-to-know basis, cryptographic measures and additional tools and automation which monitor the uses of personal information. We have policies and procedures that address how we protect PI, how we investigate and respond to security threats, and how we destroy PI when we no longer need to retain it. We require our service providers to do the same. The following are some examples of what we do to protect PI: 

• Annually, all Greatway employees (and agents) must acknowledge and agree to Greatway’s internal Code of Conduct, including a Privacy Policy and Information Security Policy. Employees and Agents who violate Greatway’s internal Code of Ethics are subject to disciplinary measures. 

• Only necessary PI is made available to Greatway employees, agents or service providers who require it in order to perform one or more operations serving the purposes identified in this Privacy Policy. 

• Electronic devices, including computers and mobile devices, are password protected and passwords must be changed on a regular basis. 

• Before entering into agreements with agents and service providers, Greatway evaluates whether security standards and data handling procedures satisfy its requirements based on Greatway’s policies and standards, which include requirements for compliance applicable federal and provincial privacy laws and regulations. 

• Greatway requires agents and service providers that it contracts with to enter into confidentiality agreements and/or agreements which have clauses concerning confidential information. 

• Security audits are conducted on information technology systems on a regular basis. 

• PI leaving the province of Quebec are subject to a privacy review which also includes any third-party suppliers involved in the handling of PI. 

• New technology projects are subject to privacy and security reviews. 

We may be required to retain Personal Information after the end of our relationship, to meet business and legal requirements. Once we are no longer required to keep it, we will securely destroy Personal Information. 

We and our service providers may use and store PI outside of your home province or territory. This means that, just like in Canada, we may be required by law to disclose your information to local governmental or law enforcement bodies. We have procedures to protect PI to the same standard required by Canadian laws no matter where it is located. 

You can ask to access or correct your Personal Information. You can ask to withdraw your consent to Greatway’s use and disclosure of your Personal Information. You can also ask questions about our privacy practices or contact us about a complaint. 

i) Access and correction requests 

Where applicable, your insurance coverage, policy documents, billing and other relevant information can be conveniently accessed online through the insurer website. Under Canadian and provincial Privacy Laws, you have the right to a) request what information we have about you in relation to the services we provide to you, b) ensure the information we have is correct and current; c) ask us to correct any inaccuracies. For these and any other inquiries, you may also submit a written request to our Privacy Office via email or mail. 

To avoid delays in obtaining your information, please provide sufficient detail to permit us to verify your identity and the specific information that you are requesting: 

• We will need you to verify your identity before searching for, or providing you with, access to your information; and 

• We may also ask you for additional information to confirm the scope of your request, such as the relevant time period or a specific description of the information you are seeking to access. 

Please note that there may be instances where access may be restricted as permitted or required by law; for example, if the information is subject to legal privilege, contains confidential commercial information, relates to an investigation of a breach of an agreement or law, or contains information about other another individual that cannot be separated. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations. 

If you ask to correct your Personal Information, and Greatway does not agree with the request – such as where our sources do not align with the requested change – we will explain this to you and keep a record that you made the request. 

ii) Requests to withdraw consent You may, at any time, submit a request to withdraw consent to the collection, use, disclosure or storage of your Personal Information. Send your request by email or mail to our Privacy Office. 

There may be cases where we cannot comply with the request without stopping or changing our relationship. For example, if you ask to withdraw your consent to our collection, use and disclosure of Personal Information on your application, Greatway will not be able to offer you an insurance policy. 

In still other cases, we cannot comply with the request at all, because we are required for legal or business purposes to handle your Personal Information. For example, insurance laws require you to provide certain Personal Information to your insurer if you make a claim under your policy, and require us to keep that information for a set amount of time. 

In all cases, we will explain the reasons why we are not able to comply with your request, or the impact it will have on your product or service. When you withdraw consent for us to have or use certain information about you, it may impact the level of service we may be able to provide to you. 

iii) Other privacy questions or concerns 

Currently Alberta, Quebec and British Columbia have substantially similar privacy laws. Ontario, New Brunswick, and Newfoundland and Labrador have enacted a similar law in its treatment of personal health information. PIPEDA applies in all other respects in these provinces, however, we may require your information to ensure compliance with other laws and regulations outside of the Privacy legal framework. 

At Greatway Financial, we acknowledge that you may have other rights over your personal information that you share with us and we will honor such requests according to the applicable Privacy Legislation governing your place of residence (examples include but are not limited to: stop processing, deletion requests, right to be forgotten, assurance of transparency and compliance etc.).

Links to other companies’ websites may be provided on the Greatway Sites as a convenience to you. Greatway is not responsible for the privacy practices of those websites. Our Website Privacy Policy applies solely to the Sites where it appears. 

Our Sites include social media features, such as the Facebook “Like” or “Share This” button or interactive mini programs that may run on our Site. These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it. We recommend you consult these other privacy policies so you can be well informed of how your Personal Information is collected and used. 

Please consult our Privacy FAQs link on our website