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.
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
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.
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
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:
In addition to this information, we also collect the following data related to your use of our Sites:
💡 Your information enables 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:
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):
Emma mainly uses 2 types of 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
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.
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.
Social Media Features
Links to Websites
🎯 We work with trustworthy providers
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:
In addition, as described in the section "How we use your personal information", we may share anonymized data.
🎯 Your family is safe and sound
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:
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.
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
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
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
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.
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.
4 Place Ville Marie Suite 300, Montreal, QC H3B 2E7
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.
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.
Emma Services Financiers inc.
4 Place Ville Marie Suite 300, Montreal, QC H3B 2E7