Effective Date: August 5, 2021
Victor Insurance Managers Inc. (“Victor,” “we,” “us”) believes strongly in protecting the privacy and the confidentiality of the personally identifiable information (“Personal Information”) we collect, use and disclose in the course of providing our insurance placement, managing general underwriter and risk management services (the “Services”). This Privacy Statement is intended to inform you of the ways in which we collect, use and disclose your personal information, and sets forth your rights.
This Privacy Statement is subject to change at any time. If we make changes to this Privacy Statement, we will update the “Effective Date” at the top of this page and post it on our Sites. Any changes we make to this Privacy Statement become effective immediately.
If you have any questions, contact us at PrivacyPolicyInquiries@victorinsurance.com.
Why We Collect Personal Information
Victor collects, uses and discloses personal information received from you or your broker, insurance carrier, employer or program sponsor to:
- Provide services to you, your employer or the plan sponsor.
- Allow you to manage the services you requested.
- Respond to your inquiries (for example, we may send you electronic or written materials or, if you supply us with your telephone number, you may receive telephone contact from us in response to your request).
- Market services to you, including ours, those of our affiliates, and those of other third parties; provided, however, that we only use your personal information for marketing purposes with your consent. We will comply with Canada’s anti-spam legislation (CASL) in connection with obtaining any necessary consents from you required under CASL.
- Comply with and enforce applicable laws, industry standards, and our own policies.
- Verify your identity.
- Conduct research, statistical analysis, survey/demographical interpretation, and other data studies based on the data collected
We may also collect, use and disclose personal information through our Sites to:
- Administer, improve, and personalize our Sites. In addition to our own analysis, enhancement, and evaluation activities, we work with Google Analytics to collect information about the use of our Sites (including how often users visit the Sites and what pages users visited prior to visiting the Sites). We use this information to maintain and improve the Sites. For information about how Google uses the information, see Google’s Terms of Service and the Google Privacy Statement. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout
- Maintain network security and performance and protect against cyberattacks.
- Register and service your online account.
- As otherwise described to you at the point of collection or pursuant to your consent.
What Personal Information Do We Collect?
The types of personal information we collect, use and disclose will vary depending on the circumstances; however, we collect, use and disclose only the personal information that is necessary for the intended purpose.
We may collect and process the following personal information relating to you and, where applicable, your dependents:
- Individual details: name, address (and proof of address), other contact details (e.g. email and telephone details), sex, marital status, family details, date and place of birth, employer, job title and employment history, relationship to the policyholder, insured, beneficiary or claimant.
- Identification details: identification numbers issued by government bodies or agencies, or by an insurance provider (e.g., social insurance number, ID number).
- Financial information: bank account number and account details, income and other financial information.
- Insured risk: information about the insured risk, which contains personal information and may include, only to the extent relevant to the risk being insured:
- Health data: relevant personal habits (e.g. smoking), previous health insurance information.
- Policy information: information about the quotes individuals and plan sponsors receive and the policies they obtain.
- Claims information: information about current and/or previous claims, which may include health data.
- Marketing data: whether or not you have consented to receive marketing from us and/or from third parties.
In most circumstances, the individuals or the program sponsors will know about the collection, use and disclosure of their personal information and, subject to legal or contractual restrictions and reasonable notice to us, will have the opportunity to withdraw their consent. In situations where there is no consent or no opportunity to withdraw consent, we will continue collection, use or disclosure of the information only to the extent permitted or required by law. For your protection, we will need to validate the identity of anyone making such a request for withdrawal of consent.
Collection by Automated Means
We also collect personal information through automated means on our Sites. We use various tools to enhance your user experience and track users of our Sites, including cookies and web beacons. These tools may collect personal information including your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
You can refuse to accept and delete cookies by adjusting your browser setting. Please note that refusing or deleting cookies may impact your browsing experience on our Sites, or prevent you from using some of their services, and may result in the deletion of any preferences you have set. For more information on how to reject or delete cookies, you should consult with your browser's or device’s help documentation or visit www.aboutcookies.org. We do not use technology that recognizes do-not-track signals from your browser. You can also opt out of internet-based advertising by installing a browser plugin from the third party where available. For more information about internet-based advertising, please see: http://www.networkadvertising.org/managing/opt_out.asp. You may also be able to opt out of our use of certain cookies using our Cookie Management Tool, where available, linked at the bottom of our Sites.
In addition, in the course of seeking network security and consistent service for all users, software programs may be employed to monitor network traffic, identify unauthorized access or access to non-public information, detect computer viruses and other software that might damage our computers or the network, and monitor and fine-tune our network’s performance. These programs may detect additional information from your computer such as your IP address, addresses from network packets, and other technical information. Any such information is used only for the purpose of maintaining the security and performance of our networks and computer systems.
We may combine the information you provide us and information we automatically collect with information from public or third party sources.
With Whom Do We Share Your Personal Information?
We will not sell, exchange or otherwise distribute your personal information without your consent except to the extent required by law, in accordance with your instructions, or as identified in this Privacy Statement. We may disclose your personal information with the following:
- Plan Administrators and Plan Advisors: In connection with the benefit plan(s) offered or provided to you.
- Insurance Brokers and Carriers: To enable them to provide insurance services to you, your employer or a program sponsor.
- Affiliates: To enable them to provide services to you and to contact you regarding additional products and services in which you have expressed an interest.
- Agents, Vendors and Service Providers: We sometimes contract with other companies and individuals to perform functions or services for us or on our behalf, such as hosting a Site or data, sending email messages, and receiving or making phone calls. They may have access to personal information to perform their functions, but are contractually restricted from using it for purposes other than providing services for Victor or on our behalf.
- Business Transfers: As we continue to develop our business, we might sell or buy assets. In such transactions, user information generally is one of the transferred business assets. Also, if either Victor itself or any of Victor’s assets were acquired, your personal information may be one of the transferred assets.
- Legal Matters: Victor may preserve, and has the right to disclose, any information about you or your use of a Site without your prior permission if Victor has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Victor or our affiliates, users of a Site or the public; (b) enforce the terms and conditions that apply to use of a Site; (c) respond to claims that any content on a Site violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process or governmental requests.
We may also share information that is not reasonably likely to identify you personally for any commercially legitimate business purpose.
What Steps Do We Take to Protect Your Information?
All personal information that Victor collects is stored and processed in Canada or the United States within databases controlled by Victor or our affiliates. When stored in the United States, your personal information may be accessed by U.S. courts, law enforcement and national security authorities. We restrict access to your personal information to those employees of ours and our affiliates, and to those service providers who need to use it to provide the services. We have implemented physical, administrative and technical safeguards to protect your personal information from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Vendors and service providers with whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, on behalf of your employer, or to comply with or as permitted by applicable law.
Accessing and Correcting Your Information:
Keeping your information accurate and up-to-date is very important. Inaccurate or incomplete information could impact our ability to deliver relevant services to you. Please let us know about any changes that may be required to your personal information, or if you require access to your personal information, by contacting us at PrivacyPolicyInquiries@victorinsurance.com. For your protection, we will need to validate the identity of anyone making a request to access or change your personal information.
How Long Do We Keep Your Information?
We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and other permitted purpose(s), including retention of personal information required by contract, law or regulation. Our retention periods are based on business, legal and regulatory needs with information that is no longer needed either de-identified or securely destroyed.
Applicability of This Privacy Statement to International Users:
Our Sites are not intended for children, and we do not knowingly collect information from children under the age of thirteen (13) without the consent of their parents or legal guardians. In an instance where such information was collected, it would be solely in connection with the services.
Questions or Concerns?
If you have any questions, concerns or complaints about this Privacy Statement, or our privacy practices in general, please send such questions, concerns or complaints via email to PrivacyPolicyInquiries@victorinsurance.com or contact our Privacy Lead at:
Victor Insurance Managers Inc.
Attn: Privacy Lead and Compliance Officer
1166 Avenue of the Americas
New York NY 10036