Last updated: September 21, 2023
💡 We protect what is most precious to you
The Emma group of companies (Emma Financial Services 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 firms and financial security advisors to offer you the product best suited to your needs.
Emma is committed to respecting your privacy and protecting your personal information. This is why we have established a personal information management program based on best practices, and have appointed a Privacy Officer.
Throughout the life cycle of the personal information we collect, the following principles govern the way we protect personal information:
The purpose of this Privacy Policy (the "Policy") is to inform you on how Emma collects, uses, discloses, maintains, and protects your personal information.
In order to provide you with quality services, we require access to certain personal information about you. We ensure that our employees manage this information with the necessary discretion and rigour and in compliance with the legal and regulatory requirements in force.
💡 You keep control of your family's information
By "personal information" we mean any information about an identifiable individual or that, taken separately or in combination with other data, allows an individual to be identified directly or indirectly. In general, personal information does not include business contact information such as your name, title, business address, or business telephone number.
Emma must obtain your consent before collecting, using or disclosing your personal information.
As a general rule, Emma will obtain the necessary personal information directly from you with your consent, subject to 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 otherwise, you consent to the collection, use and disclosure of your personal information in accordance with this Policy. Please note that your personal information may also be collected through the use of cookies when you visit our Sites.
Emma will not collect, use or disclose personal information without your consent unless it is permitted or required to do so by applicable law. For example, Emma may collect your personal information without your consent for research or statistical purposes, so long as the personal information is de-identified.
When required, Emma may transmit your personal information to regulatory bodies with whom it must collaborate and who govern its activities. For example, Emma may have to proceed without your consent when, for reasons of fraud detection or prevention or law enforcement, seeking the individual's consent would defeat the purpose.
💡 You may withdraw your consent at any time.
Withdrawal of consent and refusal to consent to the collection of personal information
You have the right to refuse the collection, use and disclosure of your personal information. It is your right, if you so desire, 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 already collected by contacting our Privacy Officer, whose contact information can be found in the "Contact Us" section of this Policy. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services, the personal information being necessary for the proper management or administration of your files or the delivery of ongoing services related to your file. In such circumstances, you should be aware that we may be required to close your file or discontinue providing you with a product or service.
Use for Secondary Purposes
Emma may also ask for your consent to use your personal information for secondary purposes, such as conducting market research or populating its databases. If Emma wishes to collect personal information for secondary purposes or purposes other than those described in this Policy, we will obtain your prior consent.
In addition, your consent for secondary purposes may be withdrawn at any time without affecting the provision of our services to you.
💡 We collect only the information we need
In the course of our interactions with you, whether when you deal 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
In addition to this information, we also collect the following data in connection with your use of our Sites:
It is also possible for us to create a customer account or login using the personal information we collect. Information related to this customer account or identifier is treated as personal information and is subject to the same protections and practices.
💡 Your information allows us to provide you with the service you expect.
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:
Emma collects your personal information mainly from you, but also from third parties or by means of cookies or pixels.
💡 We use cookies
As mentioned in the previous section, we may use various tools to improve your Web experience, to better understand our customers' behaviour, and in connection with our marketing strategies. The following section is intended to give you more information on how we use these tools.
Links to websites
It is important to understand that this Policy does not apply to other third-party Websites that may be accessed through links on our Sites. We are not responsible for these third-party sites, their content or access to them. As a result, any personal information you transmit to us through these sites is subject to their privacy policies. It is your responsibility to read their privacy policies to ensure the protection of your personal information.
Cookies and Pixels
By using cookies and web beacons, we are able to offer you advertising that better meets your needs, since it is targeted according to your interests. When you visit our Sites, cookies and web beacons tell us, among other things, which pages you are interested in, so that we can display advertising that matches your interests. These technologies do not contain any personally identifiable information. They may, however, contain a unique identifier for retargeting purposes. 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 here):
Emma mainly uses 2 types of cookies:
Emma uses different types of cookies, such as performance and functionality cookies, cookies for advertising purposes, and cookies for security purposes. For additional information on how we use cookies, we invite you to consult our Cookie Policy, available by clicking on the cookie image in the lower left-hand corner of your screen.
Please note that the use of cookies only identifies you as a user and does not recognize you by your name or address.
Deactivation of cookies
You can 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 refuse cookies, some pages or sections of our Sites may not display properly or some features may not be available.
Do other Websites have access to cookies while you are browsing our Sites?
We sometimes use third-party service providers.
When you access our Sites, either directly or through an advertisement that redirects you to our Sites, a cookie is automatically created on your computer or mobile device. At that time, a Web analysis tool (for example, Google Analytics and Amplitude) and possibly external advertising servers have access to this cookie, which enables us to offer you a better experience on our Sites or, in some cases, to track your activity in order to promote certain 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 hold about you. You should be aware, however, that some suppliers may be called upon to communicate the data they collect to third parties in the event of a legal obligation or if they wish to entrust the processing of certain data to third parties. No information that would enable these suppliers to identify you is passed on to them.
Please note that third-party service providers have their own cookies and privacy policies.
Use of Google Analytics and Amplitude
Emma uses Google Analytics, which is provided by Google Inc. (Google), and Amplitude to analyze the browsing behaviour of the visitors on our 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 produce statistical reports on visitor activity. You can get more information about Google Analytics here and Amplitude here.
🎯 You determine whether advertising is of interest to you
Targeted advertising
Emma also works with third-party advertising companies, such as Facebook or Google Adwords, which 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 companies.
Please note that our advertising partners and other third parties may also set cookies or web beacons when you click on their advertisements or links to their Web sites or services on our Sites. This Policy does not apply to third-party websites or third-party advertising providers.
You may disable Google Analytics during your browsing by selecting the appropriate settings on your browser or computer tool, as well as your ad settings.
Emma also uses Facebook's Custom Audience feature to target advertising to the interests of current and potential customers. We invite you to check your Facebook privacy settings if you wish to manage your advertising settings. More information is available 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.
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 proves the feature and not by this Policy.
🎯 We work with reputable suppliers.
From time to time, we may need to share your personal information with agents or other service providers to help us make all of our Sites' functionality available (for example, for purposes of maintenance, analysis, legal requirements, fraud detection, marketing and development). These organizations may include, but are not limited to, other Emma groups of companies and their representatives, or credit bureaus and reporting agencies such as Equifax or TransUnion.
These organizations and/or suppliers may be located outside Quebec or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these tasks on our behalf, and they are required not to disclose or use it for any other purpose.
Where applicable, we ensure through our contractual agreements that these suppliers comply with adequate security measures similar to ours to protect your personal information. In addition, we conduct Privacy Impact Assessments where required by law before disclosing personal information outside the province of Quebec.
As mentioned above, 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. We may also need to disclose personal information to comply with a legal obligation (for example, by court order) or to protect our assets (for example, to collect overdue accounts).
In other words, we may disclose your personal information to third parties in the following circumstances:
🎯 Your family is safe
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. To this end, we follow generally accepted industry standards.
The personal information we hold is therefore accessible only to those persons who are authorized to have access to it, and who consult it only when necessary for the performance of their duties.
Our employees, representatives and other stakeholders are committed to protecting your personal information. Our internal procedures clearly define everyone's roles and responsibilities in managing personal information throughout its life cycle.
Security measures
Numerous safeguards are currently in place to protect the personal information we collect. These measures include technological, physical and administrative safeguards. Access to your personal information is also controlled, limiting its use to the purposes specified at the time of collection.
These protection and security measures have been put in place and are kept up to date to prevent:
To this end, we restrict access to our offices and computer equipment, train our personnel and require our agents and suppliers of goods and services with access to personal information to sign confidentiality agreements and implement security measures deemed equivalent.
Emma also takes into consideration the protection of our technological platforms, facilities and computer systems.
For example, the following security measures are currently in place at Emma:
Technological measures
Physical and administrative measures
If you believe that your personal information has been compromised, or to report a privacy incident, we invite you to contact us using the contact information in the "Contact Us" section of this Policy.
Children's privacy
Our insurance products and Sites are intended for people aged 18 or over. We do not knowingly process personal information of minors, other than that which you voluntarily provide to us, to establish 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, please contact us promptly, using the contact information listed in the "Contact Us" section.
🎯 We are rigorous in the management of your family's information.
We keep your personal information only as long as necessary to fulfill the purposes for which it was collected and to meet our legal obligations.
We keep records of your personal information only as long as it is required for our business relationship, in accordance with our internal document 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 destroy personal information when it is no longer needed for the identified purposes. The length of time we retain your personal information may depend, among other things, on our legal and regulatory obligations, and the time required to protect our rights in the event of recourse.
If you wish to obtain additional information, we invite you to contact us using the coordinates listed in the "Contact Us" section of this Policy.
🎯 You have rights to your personal information.
As indicated above, we destroy your personal information once the purposes for which it was collected have been fulfilled.
You may also request that your outdated or unused personal information be deleted by submitting a request for the deletion of your personal information. For more information on this subject, we invite you to contact us using the coordinates found in the "Contact Us" section of this Policy.
Request for access to and correction of your personal information
At any time, you may make a request to consult or rectify the personal information we hold about you.
Such requests are free of charge. Emma may, however, charge a reasonable fee to the person making the request in cases where the latter wishes to obtain a copy of his or her personal information.
When such a request is made, the person making the request must justify his or her identity and prove that he or she is the person concerned by the personal information related to the request or that he or she can have access to it as a representative, for example.
Any request to exercise one of these rights must be made in writing and addressed to Emma's Privacy Officer using the contact information provided below. Emma undertakes to process each request received and to provide you with a written response within thirty (30) days of receipt of the request.
In certain circumstances, your request for access or rectification may be refused. For example, a request for access may be denied if processing the request would result in the disclosure of a third party's personal information and such disclosure would be likely to harm that third party.
If Emma refuses your request, we will provide you with the following information:
Making a complaint
If you feel that your personal information has been mishandled by Emma, you may file a complaint by contacting our Privacy Officer. We will take the time to analyze your complaint and implement solutions to resolve the situation.
In all cases, your complaint will be handled by our Privacy Officer. Each complaint will be investigated to determine whether it is justified. If the complaint is justified, corrective measures will be implemented by the Emma team to rectify the situation. Emma is committed to keeping you informed throughout the complaint process.
You may also file a complaint with the appropriate regulatory authority. In Quebec, this competent authority is the Commission d'accès à l'information.
Automated decision-making
Emma uses systems that collect and analyze your personal information in a fully automated fashion, without the assistance of a human, when determining your eligibility for our products or your insurance needs.
Emma is committed to informing you when you are the subject of an automated decision.
You may request that we provide you with the main parameters of this automated decision-making. You may also request a review of the decision by one of our advisors and provide comments to that effect.
Withdrawal of consent
As mentioned in the "Consent" section of this Policy, to the extent permitted by law, you may choose to withdraw your consent to the collection, use or disclosure of your personal information.
You may also withdraw your consent to the use of your personal information for secondary purposes.
For additional information on how to manage your consent, we invite you to consult the "Refusal to collect and withdrawal of consent" section of this Policy.
How to exercise these rights?
Submit your request in writing to the Privacy Officer at the address indicated in the "Contact us" section below.
🎯 We're here for you!
Personal Information Management Program
In order to protect your information, we have implemented policies, practices and procedures related 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 the handling of complaints, information security and data governance. These policies and practices also provide a framework for the operationalization of Privacy Impact Assessments, as well as for the prevention of and response to potential privacy incidents. All 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.
Roles and responsibilities
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 the privacy policies and procedures, ensures their proper functioning 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 question, complaint or request relating to the protection of personal information.
The protection of your personal information is important to us.
You may contact our Privacy Officer in writing using the following coordinates:
Privacy Officer
By e-mail: privacy@emma.ca
By mail, to the attention of the Privacy Officer or Emma Services Financiers inc.
4 Place Ville Marie, Suite 300, Montreal, QC H3B 2E7
If you have any questions or comments about this Policy, or if you wish to request information about your personal information, including requests for assistance, requests for access, requests for rectification and management of your consent, or if you wish to file a complaint about the way in which we manage your personal information, we invite you to contact our Privacy Officer.
Emma would like you to know that we are 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.
The content of our Sites may change at any time. We therefore recommend that you consult our Policy frequently to stay informed about how we handle your personal information. Publication of the amended Policy on our Sites constitutes sufficient notice of such change. In the event of major changes to the Policy, we will inform you. This version of the Policy was last updated on September 21, 2023.
Please note that in the event of any discrepancy(ies), the French version of this Policy shall prevail over the English version.
À titre informatif, en cas de divergence(s), la version française de cette Politique aura préséance à la version anglaise de cette même Politique.