Our commitment to our insurance suppliers, and our customers:
In order to provide customers with access to insurance products and services, Spectre Financial Inc will collect certain personal information about them. Our commitment goes beyond meeting legal requirements for protecting personal information. The trust and confidence that our customers and insurers hold in us, including our ability to protect the confidentiality of personal information and the privacy of the individuals who provide it, are critical to our success. This Policy applies to our employees and any third party service providers or representatives with which we do business. We also adhere to the Canadian Anti-Spam Legislation and Regulations and will only communicate electronically with your permission.
Why we collect, use and retain personal information:
Spectre Financial Inc acts as an intermediary between you and the insurance companies with which we hold contracts to promote their products and services. When we collect information in order to assess your insurance needs and provide advice, we do so with your explicit consent. In order to place an insurance application with any insurer, we are required to obtain certain essential personal information about you on behalf of the insurer and under the consent that the insurer obtains from you on the application. Your application is provided to The Gryphin Advantage, a Managing General Agent (MGA), which provides administrative services to both us and the insurer, under a contractual arrangement. The MGA's and our own privacy policies, practices and safeguards must meet the standards that insurers establish in their own privacy policies. Your information is used to determine insurance risk, assess eligibility for products, to administer those products once purchased and to fulfill certain regulatory requirements. This can include health information, financial information and history and information about avocations. The MGA, insurer and ourselves retain some of this information in order to be able to administer business, to provide ongoing service to you and when we are required to do so by law. We may use anonymous data to manage our business, to identify products and services that might benefit you and to prepare reports about our business.
We collect only the information needed to fulfill our contracts with you, the MGA and the insurer and to meet our regulatory obligations. This will use only fair and lawful means to collect this information, and only with consent. We collect personal information incompliance with applicable laws and ethical business practices, in order to provide services and to conduct business. We limit the information that we collect to that which it is necessary for, or related to, these purposes.
How we collect customers’ information:
We collect your personal information, including health information, directly from you, in-person or submitted in any online form or social media exchange completed by yourself.
We abide by the Ten Privacy Principles. The Principles are based on the federal government's privacy legislation, the Personal Information Protection and Electronic Documents Act:
1. Accountability: An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.
2. Identifying Purposes: The purposes for which persona information is collected shall be identified by the organization at or before the time the information is collected.
3. Consent: The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except when inappropriate.
4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as necessary for fulfillment of those purposes.
6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
8. Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
9. Individual Access: Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals for the organization's compliance.
The customer consent that insurers receive includes consent to provide personal information to Spectre Financial Inc and generally to the MGA, which allows us both to fulfill our contractual obligations to the insurer. The MGA and our company also operate under the customer consent that we receive at the outset of our relationship. When you request or use any of the products or services made available, we will transfer whatever information is necessary by implied consent. If we receive notice from you or an insurer that you have withdrawn consent for the continued use and retention of personal information, we will take whatever steps are necessary to adhere to the Act. This may require termination of our relationship. Spectre Financial Inc will act on whatever instructions I receive from the insurer regarding your status.
Limits on use and disclosure:
Spectre Financial Inc will use and disclose personal information to perform my contractual duties, to provide you with information and when we am required to do so by law. We may disclose this personal information to our employees or service providers, including Managing General Agents, so that they can perform their duties, to insurers and any person or organization to which consent has been given and where authorized by law. Where personal information is provided to service providers, insurers and we require them to protect that information consistent with our policies and practices. We may also use personal information to offer products and services that we believe will interest you but SpectreFinancial Inc does not and will never give or sell personal information to third parties for marketing purposes.
Limits on retention of information:
We will retain personal information in my records only as long as it is needed for the purposes identified, or as legally required or permitted.
Accuracy of information:
Spectre Financial Inc is responsible to the insurer for keeping your personal information as accurate and up-to-date as possible. The insurer is responsible for providing us of any notices of changes that you provide to them directly. You may challenge the completeness and accuracy of your personal information that we hold. We will make any necessary corrections to information that is shown to be incomplete or inaccurate and will notify any third parties, including insurers and MGAs, if we make such corrections. Any disagreement or discrepancy regarding accuracy will be documented. You may gain access to your personal information we hold under the consent you provided to us by making an access request to your advisor. If you wish to request access to information that we collected on behalf of the insurer, you may make the request through your advisor but we may be asked to direct you to the insurer.
Protecting personal information:
Spectre Financial Inc will protect personal information from unauthorized access or use by ensuring that safeguards are in place, including physical security measures for our office location, operational policies, procedures and access protocols and technological measures for my computer systems. We will use safeguards to prevent unauthorized access to personal information during the destruction process. Hired staff members are required to sign a confidentiality agreement upon commencement of employment.
CASL Compliance (Canadian Anti-Spam Law):
Spectre Financial Inc abides by Canada’s Anti-Spam Law which came into effect on July 1, 2014. This legislation require sus to secure your consent in order to continue to communicate with you electronically. These electronic messages may include bulletins, evites, newsletters, emails, texts or general messages including relevant information to you and your finances. If you at any point in time wish to withdraw, or feel you were added upon error, please email us at firstname.lastname@example.org subject: Unsubscribe, and we will unsubscribe you from these electronic messages.
Contact the Privacy Commissioner of Canada:
Hours of service are from 8:30 a.m. to 4:30 p.m. Toll-free: 1-800-282-1376 Phone: (613) 947-1698 Fax: (613) 947-6850 TTY: (613) 992-9190
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