Privacy Policy

1. Introduction

2678562 Ontario Inc. o/a Walnut Brokers ("Company", "Walnut Brokers", "we", "us", "our") respects your privacy and is committed to protecting it through our compliance with this policy. We are a property and casualty insurance brokerage placing home, auto, tenant, and commercial coverage.

This policy describes how we collect, use, disclose, and protect the Personal Information of our individual customers and users of our website, walnutbrokers.ca ("you"). "Personal Information" consists of information through which a person is identifiable or may be identified through the use of the information alone or in combination with other information.

This policy describes the types of Personal Information we may collect from you or that you may provide when you visit our website, walnutbrokers.ca (our "Website"), or when you communicate with us by email, text, and other electronic messages on a voluntary basis with regards to any services offered by the Company, and describes our practices for collecting, using, protecting, and disclosing that Personal Information.

We will only use your Personal Information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

This policy applies to Personal Information we collect, use, or disclose about our customers and Website users:

• On this Website, including through our quote request and contact forms;
• In email, text, and other electronic messages between you and this Website;
• When you interact with our advertising on third-party websites and services, if that advertising includes links to this policy.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy does not apply to Personal Information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party;
• Any third party, through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, or the site's Terms of Use, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the collection, use and disclosure of your Personal Information as described in this policy and this site's Terms of Use.

2. Information we collect about you

In order to provide you with the services you request and depending on the type of service we assist you with, we may collect the following Personal Information:

Directly from you:

• Information that we can reasonably use to directly or indirectly identify you, such as your name, address, e-mail address, telephone number, age, birth date, driver's licence number and driving record, claims and loss history, prior insurance and current policy details, details of the property, vehicle, tenancy, or business to be insured, credit records (with your express consent, where an insurer uses them), billing, payment, and account information, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier we may use to contact you online or offline;
• Information you submit through our quote request and contact forms, which is stored in our secure database and sent by email to our brokerage team;
• Information in any correspondence between you and us;
• Any responses to surveys that we might ask you to complete for our own internal purposes.

From other sources, such as partners (e.g. other insurance brokers, insurance companies, managing general agents, and consumer reporting agencies):

• With your consent, some of our partners may share your contact information with us (such as your name, email address, phone number), for example, if you have requested certain services that we offer or if you requested information or offers from us;
• With your prior express consent, we may collect credit report information, driving record information and insurance history information.

Automatically, via automated technologies or interactions (through cookies, web beacons, and other tracking technologies, as applicable), as you navigate through our Website:

• Technical information, including browser type and version, time zone setting, your device location, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details;
• Information about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our office.

3. Information we collect through cookies and other automatic data collection technologies

As mentioned above, when you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website;
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can manage and disable cookies at any time by changing your browser settings; depending on the browser you use, different instructions may apply.
• Web beacons. Pages of our Website and any of our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

You may make the following choices regarding these automated technologies:

• Tracking technologies and advertising. As described above, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
• Third-party advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to contact@walnutbrokers.ca.

We do not control third parties' collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

4. Third party links and use of cookies and other tracking technologies

Third-party links. The Website may include links to third-party websites, plug-ins, services, social networks, or applications, including insurer portals and regulators. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. These third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website or service you visit.

Third-party marketing emails and communications. You may have the opportunity to receive information or marketing offers directly from unaffiliated third parties. If you agree to receive the communications, your Personal Information will be disclosed to those third parties and all Personal Information you disclose will be subject to their privacy policies and practices. We do not endorse and are not responsible for the privacy policies and practices of those third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Third-party use of tracking technologies. Some content or applications on the Website may be served by third parties, including analytics providers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. How we use your information

We may use Personal Information that we collect about you or that you provide to us, including any Personal Information:

• To present our Website and its contents to you;
• To determine your eligibility for, offer and/or provide you with insurance products and other services that you request from us, including where you have been referred to us by third party organizations (with your consent);
• To verify your identity;
• To determine prices, fees and premiums, including by evaluating your coverage needs and assessing risk;
• To maintain, administer, collect, service and renew your policies and accounts and assess your ongoing needs for insurance products and services;
• To evaluate credit worthiness where permitted, and to collect premiums and fees;
• To assist with and advocate for you in the investigation and settlement of claims;
• To detect and protect against error or fraud;
• To compile statistics and conduct market research;
• To maintain business records for reasonable periods;
• To meet legal, regulatory, self-regulatory, insurance, security and processing requirements;
• To fulfill the purposes for which you provided the Personal Information or that were described when it was collected, or any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
• To notify you about changes to our Website or any products or services we offer or provide through it;
• To contact you about any service or information you may have requested and, where you have consented, to contact you with marketing and promotional offers;
• To improve our Website, products or services, marketing, or customer relationships and experiences;
• In any other way we may describe when you provide the Personal Information;
• For any other purpose with your consent.

Note that we may aggregate, de-identify and/or anonymize Personal Information in order to use such data for purposes such as to generate statistics about our services or to identify trends. This information does not directly or indirectly reveal your identity or relate to an identified individual.

6. Disclosure of your information

We may disclose aggregated information about our customers or Website visitors, and information that does not identify, directly or indirectly, any individual, without restriction.

Unless described below or through a clear notice to that effect, Personal Information collected by the Company is not sold, distributed, rented or communicated to other persons or organizations. The Company only communicates your Personal Information to certain types of third parties when it is necessary. We may disclose Personal Information that we collect or you provide as described in this privacy policy:

Insurers, managing general agents and underwriters

As your broker, we communicate your Personal Information to the insurers, managing general agents, and underwriters we approach on your behalf so that they can quote, underwrite, rate, issue, administer, and renew your coverage.

Adjusters, appraisers, investigators, premium finance companies and other insurance intermediaries

We may communicate Personal Information to claims adjusters, appraisers, investigators, legal counsel, reinsurers, premium finance companies, other brokers, and insurance industry and anti-fraud databases, as is standard practice in Canadian property and casualty insurance.

Corporate event

In accordance with applicable law, we may communicate Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the securities or assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, investment, or similar proceeding.

Contractors, service providers, and other third parties

We may communicate Personal Information to contractors, service providers, and other third parties we use to support our business (such as those assisting us with website hosting, database hosting, email, broker management systems, analytics, and payment processing) or that perform services on our behalf such as data processing, data warehousing or administrative services. Note that these third-party service providers and contractors are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy.

Third party organizations who disclosed your Personal Information to us

We may communicate Personal Information to third party organizations who disclosed your Personal Information to us (with your consent) as part of a referral to (a) allow the third party to provide services to you (for example, where a mortgage provider refers you to us for insurance, we will inform them if you buy insurance from us so that they can confirm the mortgage), and (b) allow the third party to track referral conversion rates.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government, insurance regulator or other regulatory request, in accordance with applicable law;
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, including sharing Personal Information with law enforcement agencies or legal authorities in cases of suspected fraud, identity theft, or other criminal activities;
• In other circumstances for which we have your prior consent.

7. Location of personal information

We, or our service providers, may process, store, and transfer your Personal Information in and to a foreign country, including the United States, which may have different privacy laws that may or may not be as comprehensive as Canadian law.

We will take steps to ensure your Personal Information is adequately protected in accordance with applicable privacy and data protection laws while outside of your province of residence. However, please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is processed, including lawful access — for example, your Personal Information may be accessible to law enforcement agencies, government agencies, courts, and national security authorities of the foreign jurisdiction.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See "Contact information and challenging compliance" below for more information.

8. Data security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

9. Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, or to meet any legal or regulatory requirements, including the record-retention periods that apply to licensed insurance brokers. At the end of this period, the Personal Information is destroyed or anonymized, in which case it will only be used for serious and legitimate purposes.

10. Children under the age of 14

We do not target or knowingly collect Personal Information about children. Please contact our Privacy Officer at the contact information below if you believe we have collected Personal Information about a child, and we will delete that information.

11. Individual rights

We make reasonable efforts to ensure that the Personal Information we have on file about individuals is accurate, complete and up-to-date as necessary for the purposes for which it is to be used, including Personal Information that is shared with third parties and Personal Information that is used to make a decision about an individual. Please keep us informed if your Personal Information changes and must be updated.

Depending on where you reside, you may have one or more of the following rights relating to your Personal Information:

• Right to opt-out: Subject to certain exceptions, you may "opt-out" or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your Personal Information. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to quote, place, or service your insurance.
• Rights of access, correction and erasure: You may request access to and obtain a copy of any of your Personal Information that we hold, request the correction of any inaccurate, outdated or incomplete information related to you, or request the deletion of your Personal Information under certain circumstances. You also have the right to know the types of Personal Information that is being collected.
• Unsubscribe from marketing materials: You may unsubscribe from marketing materials to which you have subscribed by selecting the "unsubscribe" link in any marketing email or commercial electronic message we have sent you. You can also send us a request using the contact information below. Please note that if you unsubscribe from marketing communications, you will still receive transactional and other necessary communications from us about your coverage.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include information protected by solicitor-client privilege, information that is part of a formal dispute resolution process, and information that is about another individual that would reveal their Personal Information or confidential commercial information.

If you are concerned about our response or would like to correct the Personal Information provided, you may contact the Privacy Officer at the Company at contact@walnutbrokers.ca. Proper access and use of information provided on the Website is governed by our Terms of Use.

12. Consent

The Company collects, uses and discloses your Personal Information for specific purposes. Your consent is valid for the time required to fulfill these purposes. If we wish to use or disclose your Personal Information for other purposes, we will seek your consent (unless otherwise permitted or required by law). Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide Personal Information necessary for a service you have requested). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). By accessing and/or using our Website, you consent to the collection, use and disclosure of your Personal Information as described in this privacy policy. In the event that you do not consent, you have the choice not to interact with the Company. Generally, by providing us with Personal Information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this privacy policy, if applicable, or otherwise at the time of collection.

If you obtain insurance for a family member or other third party or otherwise provide Personal Information concerning a third party, including a family member, for example by naming them as an additional driver, additional insured, or beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of their Personal Information for the purposes described above.

Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact the Privacy Officer at the Company at contact@walnutbrokers.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

13. Changes to our privacy policy

We may make changes to this privacy policy at any time in order to reflect our practices. It is our policy to post any changes we make to our privacy policy on this page. We include the date the privacy policy was last revised at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

14. Contact information and challenging compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact the Privacy Officer at the Company at:

Privacy Officer
2678562 Ontario Inc. o/a Walnut Brokers
713 Oshawa Blvd N, Oshawa, ON L1G 5V1
contact@walnutbrokers.ca
1-888-818-8261

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.

If you are not satisfied with our response, you may contact the insurance regulator in your province or the Office of the Privacy Commissioner of Canada at priv.gc.ca.

See also our Terms of Use and Licensing & Disclosure.