PRIVACY POLICY

 

SNOWBIRD MEDI-QUOTE INC. PRIVACY CODE

Last revised: September 10, 2009

Respecting Privacy

At Snowbird Medi-Quote, respecting privacy is an integral part of our business. That is why Snowbird Medi-Quote has adopted this Snowbird Medi-Quote Inc. Privacy Code (this "Privacy Code"), which explains our privacy protection practices in accordance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act ("PIPEDA").

The ten principles that form the basis of this Privacy Code are interrelated and Snowbird Medi-Quote adheres to the ten principles as a whole. Each principle should be read in conjunction with the accompanying commentary. The commentary in this Privacy Code has been drafted to reflect privacy issues specific to Snowbird Medi-Quote.

Snowbird Medi-Quote will continue to review and revise this Privacy Code to make sure that it remains current with changing industry standards, technologies and applicable laws.

Scope and Application

This Privacy Code applies to the personal information of individual clients of Snowbird Medi-Quote in any form, collected, used, retained or disclosed by Snowbird Medi-Quote in the course of our commercial activities.

This Privacy Code does not impose any limits on the collection, use, retention or disclosure of the following information by Snowbird Medi-Quote

• certain business contact information, such as the name, title or business address or telephone number of an employee of an organization;
• aggregate information that cannot be associated with a specific individual, such as non-personally identifiable statistics about financing; or
• other publicly available information as exempted by applicable privacy laws, including PIPEDA.

The application of this Privacy Code is subject to the requirements and provisions of PIPEDA, an order of any court and any other applicable legislation or regulation.

Definitions

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent sought by Snowbird Medi-Quote may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, Snowbird Medi-Quote takes into account the sensitivity of the personal information and the reasonable expectations of the individuals. Consent may be provided directly by an individual or by an authorized representative.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to Snowbird Medi-Quote. The inclusion of independent contractors within the definition of "employee" is for convenience of reference only, and should in no manner imply that such independent contractors are employees of Snowbird Medi-Quote within the meaning of employment legislation or are in an employee-employer relationship with Snowbird Medi-Quote.

Snowbird Medi-Quote: Snowbird Medi-Quote Inc. and any subsidiaries, successor company or companies thereof, as a result of corporate reorganization or restructuring.

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

use: The treatment, handling, and management of personal information by and within Snowbird Medi-Quote.

Principle 1 - Accountability

Snowbird Medi-Quote is responsible for personal information under its control and shall designate one or more persons who are accountable for Snowbird Medi-Quote’s compliance with this Privacy Code.

Snowbird Medi-Quote is responsible for all personal information under its control and has designated the Snowbird Medi-Quote Privacy Officer to oversee its privacy compliance. Other individuals within Snowbird Medi-Quote may be delegated to act on behalf of the Snowbird Medi-Quote Privacy Officer or to take responsibility for the day to day management of personal information.

As appropriate, Snowbird Medi-Quote implements privacy policies and procedures to properly enforce this Privacy Code and Snowbird Medi-Quote uses contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party or agent of Snowbird Medi-Quote.

Snowbird Medi-Quote has implemented privacy policies and procedures to give effect to this Privacy Code, including:

• implementing privacy procedures to protect personal information and to oversee compliance with this Privacy Code;
  
• establishing privacy procedures to receive and respond to inquiries or complaints;
  
• training employees about Snowbird Medi-Quote's privacy policies and procedures; and
  
• developing publicly available information to explain Snowbird Medi-Quote's privacy policies and procedures.

Principle 2 - Identifying Purposes for Collection of Personal Information

Snowbird Medi-Quote shall identify the purposes for which personal information is collected at or before the time such information is collected.

As part of our operations, Snowbird Medi-Quote has collected and collects personal information for the following purposes:

• to establish and maintain responsible relations with individuals;
• to provide products and services to individuals;
• to develop, enhance and market Snowbird Medi-Quote's products and services;
• to understand individual's needs in the areas of travel insurance;
• to manage and develop Snowbird Medi-Quote's business and operations, including personnel and employment matters;
• to conduct investigations relating to breaches of agreements or contraventions of laws;
• to meet legal and regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Snowbird Medi-Quote corporate reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Snowbird Medi-Quote, provided that the personal information disclosed continues to be used by the entity acquiring the personal information either for evaluation of the possible transaction, or, on completion of any transaction, for the purposes permitted by this Privacy Code; or
• to carry out any other purpose that an individual has authorized or that is required or permitted by law.

Further reference to identified purposes mean the purposes identified in this Principle.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.

Snowbird Medi-Quote generally collects, uses, retains and discloses an individual's personal information only with an individual's knowledge and consent. Such consent may be obtained by a third party or agent of Snowbird Medi-Quote. Snowbird Medi-Quote may depart from this general consent principle only in accordance with the limited exceptions set forth in applicable laws such as PIPEDA (for example, Snowbird Medi-Quote may collect personal information in the course of conducting an investigation where acquiring consent may compromise the accuracy or availability of personal information).

In obtaining an individual's consent, whether express or implied, Snowbird Medi-Quote will explain the purposes for which Snowbird Medi-Quote will manage an individual's personal information. Snowbird Medi-Quote will not depart from these original and stated purposes unless an individual provides further consent or unless otherwise required or permitted by law.

Individuals may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. An individual's may contact Snowbird Medi-Quote for more information regarding the implications of withdrawing consent.

Principle 4 - Limiting Collection of Personal Information

Snowbird Medi-Quote shall limit the collection of personal information to that which is necessary for the purposes identified by Snowbird Medi-Quote. Snowbird Medi-Quote shall collect personal information by fair and lawful means.

In most cases, Snowbird Medi-Quote will only collect personal information that is necessary for the purposes identified in this Privacy Code. Snowbird Medi-Quote may collect personal information from other sources that represent that they have the right to disclose such information to Snowbird Medi-Quote.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

Snowbird Medi-Quote shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Snowbird Medi-Quote shall retain personal information only as long as necessary for the fulfillment of those purposes.

Snowbird Medi-Quote will not disclose personal information for purposes other than those purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Snowbird Medi-Quote may disclose an individual's personal information:

• when we have an individual's consent, whether express or implied;
• to third party agents or suppliers engaged by Snowbird Medi-Quote to perform functions on our behalf;
• to meet legal and regulatory requirements, including to protect or defend a legal interest, in connection with an actual or possible Snowbird Medi-Quote corporate reorganization, merger or amalgamation with another entity, or natural or possible sale of all or a substantial portion of the assets of Snowbird Medi-Quote; and
• where required or permitted by law.

In such circumstances, Snowbird Medi-Quote will not disclose more personal information than is required for the identified purposes. Snowbird Medi-Quote will also, whenever it is reasonable and practicable to do so, enter privacy agreements with third parties with whom Snowbird Medi-Quote discloses personal information.

Snowbird Medi-Quote will retain personal information for a period of time only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law.

Depending on the circumstances, where personal information has been used to make a decision about an individual, Snowbird Medi-Quote shall retain, for a period of time that is reasonably sufficient to allow for access by the individual, either the actual personal information or the rationale for making the decision.

Only those employees of Snowbird Medi-Quote who require access for legitimate business reasons, or whose duties reasonably so require, are granted access to personal information.

Snowbird Medi-Quote maintains reasonable and systemic controls, schedules and practices for personal information retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required or permitted by law to be retained. Such personal information is destroyed, erased or made anonymous as appropriate.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Snowbird Medi-Quote makes reasonable efforts to ensure that the personal information it collects, uses or discloses is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. If an individual finds any errors in Snowbird Medi-Quote’s personal information holdings, Snowbird Medi-Quote should be informed and will make the appropriate corrections. Snowbird Medi-Quote will convey these corrections to anyone that Snowbird Medi-Quote may have misinformed. In circumstances where the accuracy or completeness of personal information remains in dispute, Snowbird Medi-Quote will make a note in its records of an individual's opinion as to accuracy or completeness of the relevant personal information.

Principle 7 - Security Safeguards

Snowbird Medi-Quote shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Snowbird Medi-Quote protects personal information against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Snowbird Medi-Quote protects personal information regardless of the format in which it is held.

All employees of Snowbird Medi-Quote with access to personal information are required as a condition of employment or engagement to respect the confidentiality of personal information and obligations set forth in this Privacy Code.

Principle 8 - Openness Concerning Policies and Procedures

Snowbird Medi-Quote shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Individuals should forward questions or concerns regarding Snowbird Medi-Quote's privacy practices to the Snowbird Medi-Quote Privacy Officer.

Principle 9 - Access to Personal Information

Upon request, Snowbird Medi-Quote shall inform an individual of the existence, use, and disclosure of his or her personal information and shall provide access to that information. An individual shall be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

An individual may request access to any personal information that Snowbird Medi-Quote has concerning them by sending a written request to the Snowbird Medi-Quote Privacy Officer. Snowbird Medi-Quote may advise an individual in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days.

In accordance with PIPEDA and applicable laws and/or policies or procedures of Snowbird Medi-Quote, we may not be able to provide personal information to an individual if doing so would violate the privacy of a third party or if certain personal information is subject to solicitor-client privilege, contains confidential commercial information or cannot be disclosed for other legal reasons. If Snowbird Medi-Quote is unable to provide access to all or part of an individual's personal information, we will explain our reasons for such a decision to the greatest extent permitted by law.

Personal information that is disclosed to third parties by Snowbird Medi-Quote will be subject to the general laws of applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, Snowbird Medi-Quote may not legally be permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, Snowbird Medi-Quote shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the personal information. In providing an account of disclosure, Snowbird Medi-Quote shall provide a list of organizations to which it may have disclosed personal information about an individual when it is not possible to provide an actual list.

In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit Snowbird Medi-Quote to account for the existence, use and disclosure of personal information and to authorize access to an individual's personal information. Any such information shall only be used for this purpose.

Where an individual has been provided with access to their personal information, they shall be able to challenge the accuracy and completeness of their personal information and have it amended as appropriate.

Principle 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Snowbird Medi-Quote’s compliance with The Snowbird Medi-Quote Inc. Privacy Code.

Questions or concerns regarding Snowbird Medi-Quote's privacy practices should be directed to the Snowbird Medi-Quote Privacy Officer.

Snowbird Medi-Quote will investigate all complaints concerning compliance with this Privacy Code and if a compliant is found to be justified, Snowbird Medi-Quote shall take the appropriate measures to resolve the complaint including, if necessary, amending its privacy policies and procedures. Snowbird Medi-Quote shall inform an individual of the outcome of an investigation regarding his or her complaint.

Additional Information

For more information regarding this Privacy Code or our privacy practices, please contact the Snowbird Medi-Quote Privacy Officer at:

Snowbird Medi-Quote Privacy Officer
303 - 93 Lombard Avenue
Winnipeg, Manitoba
R3B 3B1

Phone: 204.947.9210
Toll Free Phone: 1.800.661.3098
Fax: 204.895.2918
E-mail: info@mediquote.ca

For additional information about your privacy rights, please visit the Office of the Privacy Commissioner of Canada’s Internet web site at www.privcom.gc.ca.

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SNOWBIRD MEDI-QUOTE INC.

WEBSITE PRIVACY POLICY

Last Revised: September 10, 2009

This Internet Website Privacy Policy (this "Privacy Policy") governs your access and use of the website located at www.mediquote.ca. Snowbird Medi-Quote Inc. ("Snowbird Medi-Quote") owns and operates the services located at www.mediquote.ca (the "Site").

IT IS IMPORTANT THAT YOU CAREFULLY READ THE FOLLOWING.

1. Acceptance of Terms

By accessing and continuing to use the Site, and by providing certain Personal Information (as hereinafter defined) to Snowbird Medi-Quote through the Site, you are indicating your acceptance to be bound by the terms and conditions of this Privacy Policy. If you do not accept these terms and conditions, please do not access or use the Site, or provide Personal Information through the Site.

2. Modifications and Notices

Snowbird Medi-Quote may revise this Privacy Policy, at any time, by updating this posting. Snowbird Medi-Quote may provide notice to our users of such revisions by means of a general notice on the Site. Continued use of the Site after such revisions are posted will signify your agreement to these revised terms. Therefore, you should visit this page periodically to review this Privacy Policy.

3. Snowbird Medi-Quote Respects Your Privacy

Snowbird Medi-Quote is committed to protecting the privacy of all of our users to the Site and maintaining the integrity of any personally identifiable information ("Personal Information") that we collect, use, retain or disclose via the Site. The purpose of this Privacy Policy is to inform you about how and why we collect Personal Information on the Site, to outline the steps we take to safeguard your Personal Information, and to provide you with Snowbird Medi-Quote contact information should you have any questions or concerns about our privacy practices.

In addition, Snowbird Medi-Quote has adopted a more comprehensive organizational Privacy Code, which is available upon request.

4. General Information

The Site provides information intended to promote Snowbird Medi-Quote's products and services. Our Internet servers may passively and automatically collect certain information about website visitors’ traffic patterns, which may be linked to their Internet Protocol (IP) addresses (which are unique Internet “addresses” assigned to all Internet users by their Internet Service Providers). Server logs may record statistical information, such as visitors’ IP addresses, type of operating systems, time and duration of visit, pages requested, and identify categories of visitors by items such as domains and browser types. These statistics are generally collected and used on an aggregate basis.

The Site may contain links to other websites that are provided as a convenience only, and which may have different privacy policies and practices than Snowbird Medi-Quote. Snowbird Medi-Quote has no responsibility for such third party websites, and we encourage you to review the privacy policies of any third party websites you choose to visit.

5. Why does Snowbird Medi-Quote collect your Personal Information?

In the course of operating the Site, Snowbird Medi-Quote has collected and collects Personal Information from individuals for the following purposes:

• to establish and maintain responsible relations with individuals;
• to provide products and services to individuals;
• to develop, enhance and market Snowbird Medi-Quote's products and services;
• to understand individual's needs in the areas of travel insurance;
• to manage and develop Snowbird Medi-Quote's business and operations, including personnel and employment matters;
• to conduct investigations relating to breaches of agreements or contraventions of laws;
• to meet legal and regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Snowbird Medi-Quote corporate reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Snowbird Medi-Quote, provided that the personal information disclosed continues to be used by the entity acquiring the personal information either for evaluation of the possible transaction, or, on completion of any transaction, for the purposes permitted by this Privacy Code; or
• to carry out any other purpose that an individual has authorized or that is required or permitted by law.

Further reference in this Privacy Policy to "Identified Purposes" means the reasons set forth above.

6. Does Snowbird Medi-Quote disclosure your Personal Information?

Snowbird Medi-Quote does not disclose Personal Information to third parties for purposes other than those for which it was collected, except with your consent or as required or permitted by law. In situations where we disclose Personal Information in accordance with this Privacy Policy to third parties, we do not disclose more information than is required and, where it is reasonable and practical to do so, enter privacy agreements with third parties with whom we disclose Personal Information.

7. How does Snowbird Medi-Quote safeguard your Personal Information?

Snowbird Medi-Quote protects Personal Information against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Snowbird Medi-Quote protects Personal Information regardless of the format in which it is held. All employees of Snowbird Medi-Quote with access to Personal Information are required as a condition of employment or engagement to respect the confidentiality of Personal Information and obligations set forth in this Privacy Policy.

8. Your Consent/Verifying and Amending Personal Information

You may withdraw your consent for Snowbird Medi-Quote to manage your Personal Information in a particular way, subject to legal or contractual restrictions and reasonable notice. However, this may limit our ability to provide you with certain services and/or products. You may contact Snowbird Medi-Quote for more information regarding the implications of withdrawing consent.

You can typically access and review your Personal Information held by Snowbird Medi-Quote and make appropriate changes to it by contacting Snowbird Medi-Quote. You may be required to put your request in writing and show us identification. The reason we ask for identification is to ensure that, among other things, we do not unintentionally change or release your Personal Information to a third party who is representing him/her as you.

For more information regarding this Privacy Policy, please contact the Snowbird Medi-Quote Privacy Officer at:

Snowbird Medi-Quote Privacy Officer
303 - 93 Lombard Avenue
Winnipeg, Manitoba
R3B 3B1

Phone: 204.947.9210
Toll Free Phone: 1.800.661.3098
Fax: 204.895.2918
E-mail: info@mediquote.ca

You may update or make changes to your Personal Information maintained by us by writing or e-mailing to Snowbird Medi-Quote at the addresses provided above. In addition, you may request access to, or correction of, your Personal Information by writing or e-mailing to Snowbird Medi-Quote at the addresses provided above.

9. Resolving Your Concerns

If you would like more information about Snowbird Medi-Quote’s privacy practices including a copy of the Snowbird Medi-Quote Inc. Privacy Code, or if you would like to better understand and verify what Personal Information we have collected about you, please contact the Snowbird Medi-Quote Privacy Officer. Please let us know about your questions or concerns and we will do our best to help you.