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Privacy Policy

Last updated: July 27, 2022

💡 We protect what you value most

The Emma group of companies (Emma Services Financiers Inc. and Emma Labs Inc. together "Emma", "we", "us" or "our") acts as an intermediary between life and health insurers and independent financial security advisors. Emma also works with external financial security agencies to offer you the product best suited to your needs.

Emma takes your privacy and the protection of your personal information very seriously. That is why we have established a best practice privacy management program and have appointed a Privacy Officer.

The purpose of this Privacy Policy (the "Policy") is to inform you about how Emma collects, uses, discloses, maintains and protects your personal information.

In order to provide you with quality services, we must have access to certain personal information about you. We ensure that our employees manage this information with all the necessary discretion and care, and in compliance with the legal and regulatory requirements in force.

💡 You remain in control of your family's information

Personal information

We define "personal information" as any information about an identifiable individual or that, individually or in combination with other data, can identify an individual. Generally, personal information does not include your business contact information such as your name, title, business address or business telephone number.

Consent

Generally, Emma will obtain the necessary personal information directly from you by your consent, subject to the exceptions provided by law.

By providing us with personal information, through our website or web platform (collectively our "Sites"), in an application, by telephone, email, chat or any other means, you consent to the collection, use and disclosure of your personal information in accordance with this Policy.

Emma will not collect, use or disclose personal information without your consent unless it is permitted or required to do so by applicable regulations. Where required, Emma may share your personal information with regulatory bodies with whom it must cooperate and who govern its activities. For example, Emma may need to proceed without your consent where, for reasons of fraud detection or prevention or law enforcement, seeking the individual's consent would impede the process.

💡 You may withdraw your consent at any time

Opting Out of Data Collection and Withdrawing Your Consent

You have the right, if you so choose, to refuse the collection, use and disclosure of your personal information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of personal information previously collected by contacting our Privacy Officer. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services, as the personal information is necessary for the proper management or administration of your files or the delivery of ongoing services in connection with your file. In such circumstances, you should be aware that we may be forced to close your file or cease providing you with a product or service.

Please note, however, that anonymized, non-identifying information will be retained.

Use for Secondary Purposes

Emma may also ask for your consent to use your personal information for secondary purposes, such as market research or building databases. As noted above, we will ask for your consent to do so. In addition, your consent for secondary use may be withdrawn at any time without affecting the delivery of our services to you.

💡 We collect only what is necessary
What personal information do we collect?

Information collected by Emma

As part of our interactions with you, whether you are dealing with one of our advisors (life and health insurance) or one of our broker representatives (group savings), we need to collect certain personal information about you. The personal information we collect is necessary to provide you with the services you have requested. This includes but is not limited to:

  • Your contact information such as a name, address, email or telephone number in order to identify and contact you;
  • Your Social Insurance Number (SIN) to meet government obligations, including tax reporting and other purposes, such as opening an income generating account and registered retirement income investment, to meet Canada Revenue Agency requirements.
  • Health information, such as your family history, use of certain medications or smoking habits, in order to determine your eligibility for certain insurance products;
  • Financial information, such as the amount of your mortgage, debts, savings, investments, cash flow and salaries, or information on your current insurance contracts, in order to know you well and offer you advice and products and investments that meet your needs;
  • Information about you and your family, such as your employment, marital status, whether you have a will or the number of children in your family and their ages. We need this information to properly assess your insurance or investment needs and recommend the right products;
  • Information relating to marketing and communication preferences that you have voluntarily provided to us such as comments, survey responses;
  • Information relating to the use of our website including technical information about visits or any other information collected through cookies or similar tools;
  • Recruitment information such as resumes, employment or academic history, psychometric test results or other information relevant to a potential recruitment;
  • Any other personal information you provide.

In addition to this information, we also collect the following data related to your use of our Sites:

  • Number of visits
  • The conversion rate
  • The average length of your visit
  • Actions performed on our Sites
  • The pages viewed during your visit
  • The type of device used during your visit
  • The web browser used during your visit
  • The IP address used during your visit
  • The origin of visitors, i.e. the web page you visited before being redirected to our Sites
  • The advertising campaign that brought you to our Sites
💡 Your information enables us to provide you with the service you expect
Why do we collect your personal information?

Emma collects, uses and discloses personal information for the purposes identified at the time of collection or as permitted or required by law. This includes, but is not limited to, the following purposes:

  • Establish and manage our interactions with you, such as:
    - Determining your eligibility for our insurance products;
    - Obtaining your selected coverage;
    - Accessing products purchased on our platform;
    - Making changes to your insurance coverage;
    - Cancelling your insurance policy;
    - Offer products through our partnership and referral agreements;
    - Prevent fraud.
  • Providing services, such as arranging for your purchase of savings and insurance products, for example:
    - Determining your eligibility for our insurance products;
    - Determining your coverage needs;
    - Determining if you can be automatically pre-approved online;
    - Recommending the appropriate products for your needs;
    - Facilitate the drafting of your will.
  • To facilitate the use of our Sites, to ensure their relevance and to track their usage;
  • To respond to your requests for information, questions, complaints or comments;
  • To allow business development and marketing in order to inform our current and future customers about our new offers with the prior consent of the person concerned;
  • To conduct development and research to ensure we maintain the highest standard of security and understand our customers' requirements to improve our offerings;
  • Recruit staff, process applications and assess the candidate's profile in relation to the job requirements;
  • As permitted or required, for any applicable legal or regulatory obligation or provision, including anti-money laundering, anti-terrorism and tax evasion;
  • Any other purpose to which you have consented.
How do we collect your personal information?

Emma collects your personal information primarily from you, but also from third parties or through the use of cookies or pixels.

  1. From you
    ‍
    You provide us with personal information directly, such as when you purchase life insurance or savings products, when you contact us or when you click on an advertisement we have placed on a third party website (e.g. Google, Facebook, etc.).
  2. From a third party
    We may also collect personal information from third parties, or publicly available records as permitted by law or if we have obtained the necessary consent.
  3. Live Chat Tool
    ‍
    When using the chat support tool, Emma offers you online services through an advisor who may request and collect information about you. This information establishes your identity and also allows you to benefit from the services that are available through this tool and that are best suited to your needs.
  4. Phone call with an advisor
    If necessary, Emma offers phone consultations with an advisor who may ask you for and collect information about you. This information establishes your identity and also allows you to benefit from the services that are available through this tool and that are best suited to your needs.
  5. Cookies
    ‍
    Cookies are small data files that are commonly stored on your device when using websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. Emma collects the personal information provided by cookies.
  6. Pixels
    Pixels are tiny images that we may place on our web pages or emails. They can be used, for example, to anonymously track the number of times a particular page has been visited by a user. As the name implies, pixels are invisible and any part of our Sites, including advertisements displayed on them, may contain pixels. Unlike cookies, pixel tags are not placed on your computer.
  7. Use for Research and Development Purposes
    Information obtained through the use of cookies or pixels may also be used for research and development purposes and to enhance your experience on our Sites. In this case, the information is anonymized and is used primarily for statistical purposes. However, we want to reassure you that no personally identifiable information will be used. As mentioned above, the information is anonymized and will be used for statistical and research purposes.
💡 We make use of cookies
Details on Data Collection, Use and Disclosure on our Sites (Cookies, Pixels and Other Social Media Features)

As mentioned in the previous section, we may use various tools to improve your web experience, better understand our customers' behavior, and in connection with our marketing strategies.The following section is intended to give you more information about our use of these tools.

Cookies and pixel

By using cookies and pixels, we are able to provide you with advertising that is more relevant to your needs because it is targeted to your interests. When you visit our Sites, cookies and pixels tell us, among other things, which pages you are interested in and, as a result, we can display advertising that is relevant to your interests.  These technologies do not contain any personally identifiable information. They may, however, contain a unique identifier necessary for retargeting. When you click on one of these ads, we may also track the response rate of the campaign.

Emma uses different types of cookies (collectively referred to as cookies here):

  • Performance and Functionality Cookies
    These cookies are not essential to the provision of our services. They help personalize and enhance the user experience. For example, they may remember your preferences so you don't have to re-enter information more than once, or remember your login information so you don't have to enter it each time you use the service. They allow us to understand your behavior in order to improve our services and our Sites.
  • Cookies for advertising purposes
    These use information about your visit to the Site, such as pages viewed or response to advertisements, to help provide the best user experience for you.
  • Cookies for security purposes
    These cookies help protect your accounts from unauthorized users. They help maintain session integrity and provide enhanced security by blocking unauthorized attempts to access your account.

Emma mainly uses 2 types of cookies:

  • The session cookie
    This cookie is kept in memory for the duration of your visit to our Sites, after which it is deleted from your device. It identifies you and is then deleted when you leave our Sites.
  • The persistent cookie
    This cookie is stored on your device until it expires and will be retrieved the next time you visit our Sites. Our persistent cookies last for 30 days.

Please note that the use of cookies only identifies you as a user and does not recognize you by name or address.

Deactivating Cookies

It is possible to prevent the personalization features of our Sites by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.

However, if you choose to decline cookies, some pages or sections of our Sites may not display properly or some features may not be available.

Do other sites have access to cookies when you browse our Sites?

We sometimes use third-party service providers.

When you access our Sites, either directly or through an advertisement that directs you to our Sites, a cookie is automatically created on your computer or mobile device. At that time, a web analytics tool (for example, Google Analytics and Amplitude) and possibly external ad servers have access to this cookie, which allows us to provide you with a better experience on our Sites or, in some cases, to track your activity to promote some of our products. Although a code in the cookie identifies you as a user, it does not recognize you by name or address.

Our service providers may also need to collect your IP address or mobile device identifier when you visit a site. This information may be transmitted to and stored on servers located in Canada or elsewhere, such as the United States. Emma does not combine any information collected by these third parties with information we have about you. You should be aware, however, that some suppliers may be required to share information with third parties if they are required to do so by law or if they wish to outsource the processing of certain information to third parties. No information that would allow these providers to identify you is shared with them.

Please note that third party service providers have their own cookies and privacy policies.

Usage of Google Analytics and Amplitude

Emma uses Google Analytics, which is provided by Google Inc (Google), and Amplitude to analyze the browsing behaviours of visitors to its Sites, which are tools for analyzing website traffic and usage. The information collected by Google Analytics and Amplitude is used to analyze the use of our Sites and to generate statistical reports on visitor activity. You can get more information about Google Analytics here and Amplitude here.

🎯 You decide if you are interested in advertisement

Targeted Advertising

Emma also works with third-party advertising companies, such as Facebook or Google Adworks, that collect and use information about your visits to our Sites in order to present you with advertising that may be of interest to you. Emma does not share any personally identifiable information with these advertising companies.

Please note that our advertising partners and other third parties may also set cookies or pixels when you click on their advertisements or links to their websites or services on our Sites. This Privacy Policy does not apply to third party websites or third party advertising providers.

You may disable Google Analytics while browsing by selecting the appropriate settings on your browser or computer tool, as well as the ad settings. It is possible to opt-out of sharing your information with these third parties by installing an add-on and thus opt-out of receiving interest-based advertising.  Emma also uses Facebook's Custom Audience feature to target advertising to the interests of our customers and prospects. We encourage you to check your Facebook privacy settings if you wish to manage your advertising settings. You can get more information here.

Please note that even if you choose not to receive ads targeted to your interests, it will still be possible to see ads from Emma. In this case, they will simply not be tailored to your actual needs and may be displayed more frequently.

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

Social Media Features

Our services include social media features such as the Facebook share button or interactive mini-programs that run on our Sites. If you use these features, they collect your IP address, the page you visit on our Sites, and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Sites. Your interaction with these features is governed by the privacy policy of the company that provides the feature and not by this policy.

Links to Websites

It is important to understand that this Policy does not apply to other third party websites that may be accessed from links on our Sites. We are not responsible for these third party sites, their content or access to them. Therefore, any personal information you submit through these sites is subject to the privacy policy of those sites. It is your responsibility to read their privacy policies to ensure the protection of your personal information.

🎯 We work with trustworthy providers
How do we share your personal information?

Occasionally, we may need to share your personal information with agents or other service providers to help us make available all the features of our Sites (maintenance, analysis, legal requirements, fraud detection, marketing and development). Please note that these service providers may be located in Canada or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these functions on our behalf and are required not to disclose or use it for any other purpose. Please be aware that we have contractual agreements with these vendors to ensure the security of your data and we conduct Privacy Impact Assessments prior to disclosing any personal information outside the province of Quebec.

Please note that we may also share your personal information when required by law, to enforce compliance, or to protect the property or safety of our rights or those of others. For example, we may disclose personal information to legal or regulatory authorities where we suspect money laundering, insider trading, manipulative or deceptive business practices, or other criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental authorities, regulators, or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).

This means that we may share your personal information with third parties, including in the following circumstances:

  • We have obtained your consent to do so;
  • You wish to subscribe to an insurance policy or obtain one of our products: In this case, we transmit the following information to our partners, including Humania Assurance Inc. and MICA Financial Services Inc:
    - All the information you provided when you applied for insurance;
    - The photo identification and the ID number;
    - Information on the product you have selected;
    - A file containing the transcript of your conversation with advisors in the chat room and the metadata associated with each message (time, date, IP address, browser and device used);
  • In order to make the features of our Sites available;
  • As required by a securities regulatory authority or other regulatory body;
  • We are required or permitted by law to do so.

In addition, as described in the section "How we use your personal information", we may share anonymized data.

🎯 Your family is safe and sound
How we protect your personal information

The security and confidentiality of your personal information is important to us. We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession. In doing so, we follow generally accepted industry standards. The personal information we hold is therefore only accessible to those persons who have the authority to access it and who consult it only when necessary for the performance of their duties.

Appropriate physical, technical and/or administrative safeguards and security measures have been put in place and are maintained to prevent:

  • Any accidental or unlawful destruction;
  • Any accidental loss;
  • Any unauthorized disclosure;
  • Unauthorized modification;
  • Unauthorized access; and
  • Unlawful processing.

We do this by restricting access to our offices and computer equipment, by training our staff, and by requiring our agents and suppliers of goods and services with access to personal information to sign confidentiality agreements and implement security measures deemed equivalent.

If you believe that your personal information has been compromised, we invite you to contact us using the contact information listed in the "Questions, Comments, Complaints" section of this Policy.

Children's Privacy

Our insurance products and Sites are intended for individuals 18 years of age or older. We do not knowingly process personal information of minors, other than information you voluntarily provide to us, to determine your need for insurance. If you believe that we have collected Personal Information directly from minors, or if you are a parent or legal guardian and believe that your minor child has provided us with Personal Information, you may contact us as described in the "Questions, Complaints, Comments" section.

🎯 We are diligent in managing your family's information
How long do we keep your personal information?

We keep records of your personal information only as long as it is required for our business relationship, in accordance with our internal record retention policies or legal and regulatory standards. These records will be retained by your advisor or mutual fund dealer representative with whom you normally do business, by Emma's Compliance Department or by our service providers.

Strict procedures for the retention of your personal information are followed and we will dispose of personal information that is no longer required by Emma for the identified purposes.

If you would like additional information, we invite you to contact us using the contact information listed in the "Questions, Comments, Complaints" section of this Policy.

🎯 You have rights regarding your information
What are your rights?

Access to and correction of your personal information

You have access to your personal information through your user account on our Sites. You can correct and update certain personal information from this access or by chatting with one of our consultants.

You may request access to your Personal Information or information about the existence of such information or obtain information about how we collect, use, maintain and/or disclose your Personal Information or to what categories of third parties we disclose your Personal Information. You may also request that information held by Emma be corrected if it is found to be inaccurate, misleading or incomplete.

If you wish to obtain copies of your Personal Information, we may charge you a nominal fee, which is disclosed to you in advance, simply to cover the cost of transcription, reproduction or transmission.

Request for Erasure

You may request the deletion of your personal information to the extent permitted by law.

Automated Decision Making

EMMA uses systems that collect and analyze your personal information in a fully automated manner, without human assistance, when determining your eligibility for our products or your insurance needs.

You may request that we provide you with the key parameters of this automated decision making. You may also request a human review of the decision.

Withdrawing your consent

You may choose to withdraw your consent to the collection, use or disclosure of your personal information, to the extent permitted by law.

You may also withdraw your consent to any commercial or philanthropic prospecting by us.

How to exercise these rights

Submit your request to us by writing to the Privacy Officer at the address indicated in the "Privacy Officer" section below.

🎯 We are here for you
Privacy Management Program

In order to protect your information, we have put in place policies, practices and procedures relating to the management of the personal information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance. These policies and practices also provide the framework for the operationalization of Privacy Impact Assessments, as well as the prevention of and response to potential privacy incidents. All of these policies and practices have been approved by our Privacy Officer.

The collection of your personal information through our application complies with the requirements of this program.

Privacy Officer

EMMA's senior management has delegated the management of the privacy program to the Privacy Officer. The Privacy Officer is responsible for the internal management and oversight of EMMA's privacy program.

It is the Privacy Officer who approves and implements privacy policies and procedures, ensures that they are functioning properly and reports to EMMA's senior management on the effectiveness of the program.

The Privacy Officer is also responsible for providing you with the necessary support in the event of a privacy-related question, complaint or request:

Emma Services Financiers inc.
‍
Guillaume Plante
4 Place Ville Marie Suite 300, Montreal, QC H3B 2E7
privacy@emma.ca

Emma is committed to responding promptly and accurately to all your questions and concerns about the privacy and security of your personal information and our privacy policies and procedures.

In the event of a complaint by you regarding the exercise of your rights under this Policy, your case will be handled by the Emma Privacy Officer's office, who will advise you of the appropriate procedures to follow. Each complaint will be investigated. If the complaint is justified, the specific situation will be corrected and you will be informed.

Changes and Updates to the Policy

The content of our Sites may change at any time. If so, we will notify you as required by law. As this Policy may change from time to time, we recommend that you review it frequently to stay informed about how we are handling your personal information. This version of the Policy was last updated on July 27, 2022.

Questions, comments, complaints

Emma Services Financiers inc.
Guillaume Plante
4 Place Ville Marie Suite 300, Montreal, QC H3B 2E7
privacy@emma.ca
‍

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