Privacy Policy

PRIVACY POLICY

Last Revised: February 22, 2025

In this Privacy Policy, "CompareHealth", "we", "us", "our" and "ours" means CompareHealth Inc., and "you" means (and “your” refers to) anyone who provides personal information to us, and their successors, heirs, administrators, executors and assigns (as the case may be).

We have adopted this CompareHealth Privacy Policy (this "Privacy Policy") to explain how we will meet our responsibilities with respect to the information you provide to us. This Privacy Policy applies to both individuals and organizations from whom we collect personal information.

The principles that form the basis of this Privacy Policy are interrelated and CompareHealth adheres to all of the principles as a whole. Each principle should be read in conjunction with the accompanying commentary. As encouraged by the Personal Information Protection and Electronic Documents Act ("PIPEDA"), the commentary in this Privacy Policy has been drafted to reflect privacy issues specific to CompareHealth. We will continue to review this Privacy Policy to make sure that it remains current with exceptions, changing technologies, industry standards and applicable laws.

Scope and application

This Privacy Policy governs the collection, use, and disclosure of personal information by CompareHealth in connection with its commercial activities, including the operation of the Website and Services. It applies to personal information collected from all users of the Services, including Leads, Clients, Advisors, External Partners, and Insurers, unless otherwise specified.

This Privacy Policy does not typically apply to information related to CompareHealth’s corporate clients or other organizations. However, such information may be governed by separate CompareHealth policies or contractual agreements.

The following categories of information are not subject to the limitations of this Privacy Policy:

Information about an individual that is publicly available and specified by regulation under PIPEDA or other applicable privacy laws.
Personal information not collected, used, or disclosed for commercial purposes.
Non-personally identifiable information, such as aggregated data or anonymous statistics.
Business contact information, such as name, title, work address, or work telephone number, used solely for professional communication.

Where privacy laws in British Columbia, Alberta, or Québec apply, this Privacy Policy adheres to the substantially similar provincial laws. References to PIPEDA in this policy include the relevant provincial laws where applicable.

CompareHealth operates in Canada and adheres to applicable Canadian privacy laws.

Definitions

Advisor: An insurance broker, whether independent or affiliated with a brokerage or Insurer, who holds the applicable license to sell personal health insurance plans in Canada, who subscribes to CompareHealth to access tools for managing Clients and generating personal health insurance plan comparisons, which assigns a Quote ID.
Advisor Account: The account granting Advisors access to the Services and administrative tools, including managing subscription Tiers, adding commission links, and accessing other features.
Billing Period: A monthly period beginning on the date an Advisor or Insurer subscribes, during which fees are charged in advance for access to the Services.
Client Quoter: A feature that allows Advisors’ Clients to create health insurance comparisons based on criteria defined by the Advisor, such as location or Insurer. The Client Quoter requires a specific subscription Tier.
Client: A customer or prospective customer of an Advisor, identified through criteria such as province, date of birth, sex and insurance preferences exploring personal health insurance plans for personal use.
Collection: The act of gathering, recording, or obtaining personal information by any means, including directly or via third parties.
Consent: Voluntary agreement for the collection, use, or disclosure of personal information for specific purposes. Consent may vary based on the type of information and the context of its use.
Disclosure: The act of making personal information available to a third party.
External Partner: A third-party organization or individual, such as an insurer, brokerage, or marketing partner, that interacts with Leads provided by CompareHealth to offer insurance products and services. This may also include advisors who receive Leads in addition to their paid subscription access. External partners may either generate Leads through referral links or receive and engage with Leads but cannot do both. See CompareHealth’s Terms of Use for details.
Insurer or Insurance Provider: An insurance company in Canada offering insurance products and services that may be shown on our Website.
Lead: A Lead directly uses our Services to explore personal health insurance plans for personal use identified through criteria such as province, date of birth, sex and insurance preferences. Leads access our Website directly or through an External Partner.
Personal Information: Information about an identifiable individual but excludes information used for professional communication, such as a business address or work email address.
Questionnaire: A form on the Website designed to capture user information, including location, preferences, and demographics, for quoting and comparison purposes.
Quote ID: A unique identifier automatically generated whenever an Advisor, Lead, Client, or Insurer creates a comparison using CompareHealth’s platform for immediate or future reference. Quote IDs do not contain personally identifiable information but may be associated with specific quote details for tracking purposes. The ability to modify or save Quote IDs may vary on the type of User.
Services: Any tools, features, or products offered through CompareHealth’s Website or applications.
Tier: The subscription level that determines the maximum number of Quote IDs an Advisor can create during a Billing Period and may include additional features.
Use: The handling or management of personal information by CompareHealth or authorized third parties.
User: Any individual or organization that uses the Services, including Leads, Clients, Advisors, External Partners, and Insurers.

How CompareHealth works

For details on how CompareHealth operates, including its role as a platform provider and its business model, please refer to our Terms of Use.

Access to Services

Leads can explore personal health insurance plans through our Website by completing a brief Questionnaire that captures essential details like province, date(s) of birth, and preferences. Leads receive limited personal health insurance plan information relevant to their preferences and may voluntarily provide contact details to connect with an External Partner for further assistance.
Clients access the Services through an Advisor. Advisors use features like the Client Quoter to create personal health insurance plan comparisons or enable Clients to review limited comparisons independently. Advisors configuring the Client Quoter tool control elements of the comparison survey, including provinces displayed, Insurers shown, and custom web links assigned to "Apply" buttons. Clicking these links may direct Clients to external websites outside CompareHealth's control. Clients should verify all information with their Advisor or the Insurers before finalizing any decisions and review the privacy policies of any third-party platforms they interact with.

Accessing Services may require access to an account for Advisors, External Partners and Insurers:

Advisors access the Services through subscription-based Advisor Accounts, which provide tools to generate Quote IDs, manage Leads, and utilize other features specific to their subscription Tier. Advisors may grant access to one (1) staff member for administrative support only.
External Partners may access Leads’ information through CompareHealth to offer insurance products and services. This includes Insurers who participate as External Partners, allowing them to engage directly with Leads. External Partners must adhere to applicable privacy laws and CompareHealth’s policies regarding the handling and use of Leads’ personal information. External Partners using CompareHealth may require access to an account.
Insurers can purchase a research license to access insights into how their insurance products and services compare in the market. This type of access does not involve direct engagement with Leads or Clients. Insurers must comply with all licensing agreements and usage restrictions outlined in CompareHealth’s Terms of Use. Insurers using CompareHealth will require access to a subscription-based account.

Privacy for Leads, Clients and External Partners

Leads: When Leads use the Website, they may voluntarily submit personal information, such as their name, email address, phone number, and insurance preferences, to review insurance products and services and connect with External Partners. CompareHealth processes this information to generate an email notification sent from CompareHealth’s official domain (@comparehealth.ca). This email is first received by CompareHealth and then manually forwarded to one or more designated External Partners based on the Lead’s needs and the availability of an External Partner to assist them. If an External Partner does not respond or take action, CompareHealth may share the Lead’s information with an alternative External Partner to ensure timely follow-up. In the future, this process may be automated, but Leads’ information will continue to be shared only for insurance-related purposes. Leads who do not provide contact details or close their browser session will not have their information stored for future reference. By submitting contact details, Leads consent to data sharing with the relevant parties for follow-up actions.

Clients & Advisors: When Clients use CompareHealth’s Client Quoter feature, they may voluntarily submit personal information, such as their name, email address, phone number, and insurance preferences, to generate a comparison. CompareHealth processes this information to generate automated emails sent from CompareHealth’s official domain (@comparehealth.ca) to the Advisor who provided the Client Quoter link and the Client. This Advisor’s email contains the Client’s Quote ID, contact details, and confirms their information was submitted. The Client receives an email with the Advisor’s contact details and acknowledges the comparison was successfully submitted with the Advisor’s contact details. Advisors who receive Client information through CompareHealth must comply with privacy regulations and obtain valid consent for any follow-up communications. Advisors may only use Client information for the intended purpose of offering relevant insurance products and services. Clients who do not wish to be contacted can opt out by contacting their Advisor directly.

External Partners: External Partners who access Leads through CompareHealth are responsible for ensuring compliance with privacy regulations, including obtaining valid consent for any outreach. They may only use Leads’ information for the intended purpose of offering relevant insurance products and services.

Insurers: Insurers' access does not involve direct engagement with Leads. However, if an Insurer also participates as an External Partner, they may engage directly with Leads under the same terms and conditions that apply to all External Partners.

Accountability for our handling of personal information

CompareHealth is responsible for all personal information under its control and has designated the CompareHealth Privacy Officer to oversee privacy compliance. Other individuals within CompareHealth may be delegated to act on behalf of our Privacy Officer or to take responsibility for the day-to-day management of personal information. CompareHealth trains and communicates with employees about our privacy practices, including this Privacy Policy.

As appropriate, CompareHealth implements privacy policies and procedures to properly enforce this Privacy Policy, and we use contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party.

Reasons Why We Collect, Use, and Disclose Personal Information

CompareHealth collects personal information for the following purposes (collectively, the "identified purposes"):

To verify your identity when you create an account;
To notify you about products or services we offer or provide, including comparisons and additional tools;
To provide you with information, products, or services that you request from us;
To facilitate connections between Leads and External Partners for insurance-related purposes;
To enable Clients to use the Client Quoter feature and connect them with Advisors as needed;
To improve and personalize your experience on CompareHealth, including by tailoring the results of comparisons to your preferences;
To connect Leads with External Partners, enabling insurance-related services or product offerings, in accordance with applicable privacy laws and with your consent.
To analyze usage trends, improve platform functionality, and provide aggregated insights to Insurers and other third-parties without revealing personally identifiable information.
To improve our products or services, for marketing, newsletters, and customer relationship management;
To manage and coordinate the activities of employees, contractors, and volunteers;
To carry out obligations and enforce rights arising from contracts with you, including billing, collection, and ensuring compliance with agreements;
To comply with applicable legal or regulatory requirements;
To enable External Partners to provide relevant insurance products and services to Leads;
To collect additional data, such as contact details, to connect with External Partners;
To notify you of updates to this Privacy Policy or our Terms of Use;
In any other way we describe to you when you provide the information; and
For any other purpose with your consent or as required or permitted by law.

We will indicate the identified purposes to you orally, electronically, or in writing at or before the time your personal information is collected. Persons collecting personal information may explain the identified purposes or refer individuals to a designated CompareHealth representative for clarification.

Collection of Personal Information

CompareHealth collects personal information directly from you for the purposes identified above. This may include the following:

Contact Information: Such as your name, email address, mailing address, and telephone number when you request information, products, or services from CompareHealth.
Account Information: If you create an account, we may collect additional details, including account activity, preferences, and information provided for comparisons.
Billing Information: If applicable, payment details such as credit card or other payment methods to facilitate purchases. Billing information is collected solely for the purposes indicated at the time of collection.
Social Media: If you engage with CompareHealth through social media platforms, we collect any information you voluntarily provide on those platforms.
Preferences: We may collect information about your preferences to improve your experience with our products and services.
External Partner Data Sharing: CompareHealth may collect and share Leads’ information, such as name, contact details, and preferences, with External Partners when Leads initiate actions on our Website. External Partners must agree to use this data only for its intended purpose. Submitting contact information implies consent for data sharing with relevant parties to fulfill the request.
Client Data Sharing: When Clients use the Client Quoter feature, their submitted information—such as name, contact details, and insurance preferences—is shared with the Advisor who provided the Client Quoter link.

CompareHealth collects personal information directly from Leads and Clients to facilitate the Services:

Leads: This may include first and last name, email address, phone number, and details to create a comparison including, but not limited to, province, date(s) of birth, and health insurance preferences submitted through the Questionnaire.
Clients: This includes additional details provided through their Advisor or via the Client Quoter, such as first and last name, email address, phone number, and details to create a comparison including, but not limited to, province, date(s) of birth, and insurance preferences submitted through the Questionnaire to present personal health insurance plans from Insurers pre-selected by the Advisor (if applicable).

Client Quoter Data

The Client Quoter allows Advisors to customize the personal health insurance plan comparison experience for their Clients. Advisors configuring the Client Quoter tool control elements of the comparison survey, including provinces displayed, Insurers shown, and custom web links assigned to "Apply" buttons. Clicking these links may direct Clients to external websites outside CompareHealth's control. Clients should verify all information with their Advisor or the Insurer before finalizing any decisions and review the privacy policies of any third-party platforms they interact with.

Clients complete a simplified Questionnaire, providing their first and last name, phone number, and email, which is used to generate results. The completed Questionnaire is accessible to the Advisor, who receives an email containing the comparison results and the Client’s contact details. Clients also receive an email with the Advisor's contact details. Advisors also have access to additional filters and tools to further tailor comparisons for their Clients. Clients using the Client Quoter feature generate a Quote ID, which counts toward the Advisor's allocated monthly Quote IDs.

Client contact details are shared with the Advisor via email, but they are not stored in the Advisor Account.

Clients may contact CompareHealth or their Advisor to request access to, corrections of, or the removal of their information submitted through the Client Quoter, subject to legal or contractual obligations.

In addition to direct collection from you, CompareHealth may also collect personal information:

From third parties that provide information to us, such as External Partners, when it is necessary to facilitate the identified purposes;
Through forms or Questionnaires on our Website used to create comparisons, which may include personal details like province, date(s) of birth, and insurance preferences.

CompareHealth limits the collection of personal information to what is necessary for the identified purposes or as otherwise agreed upon by you. We do not collect personal information about you unless you knowingly and voluntarily provide it, such as when filling out a form, contacting us, or sharing information with an External Partner at your request.

CompareHealth does not employ methods to collect personal information without your knowledge. However, as permitted by law, CompareHealth may collect personal information without your consent in limited circumstances, including:

To comply with a legal obligation or regulatory requirement;
To protect the safety, security, or property of CompareHealth, its users, or the public;
As otherwise authorized or required by applicable law.
Where permitted by PIPEDA and other applicable laws;

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.

Consent for us to contact you about our products and services

The information you provide to CompareHealth – such as your name and address – allows us to inform you about issues, events or special offers which may be of interest to you.

Advisors: By signing up for an Advisor Account, you are giving CompareHealth permission to contact you by way of the information you provide.

Insurers and External Partners: By using CompareHealth’s platform, you are giving CompareHealth permission to contact you by way of the information you provide.

Leads: By submitting information through CompareHealth’s platform, you consent to having their personal information shared with External Partners for health insurance-related purposes.

Clients: By using CompareHealth’s Client Quoter feature, your information may be shared with an Advisor who will contact you regarding personal health insurance plan options.

Users may withdraw consent at any time by contacting CompareHealth or their Advisor, subject to legal and contractual obligations.

Disclosure of personal information

CompareHealth will not disclose personal information for purposes other than those purposes for which it was collected, except with your consent or as required or permitted by law. CompareHealth may disclose your personal information:

To fulfill the identified purposes (for example, by providing your billing information to a third-party payment processor, to have an Advisor contact you with your supplied contact information, or to share your details with an External Partner offering relevant insurance services);
When we have your consent, whether express or implied;
To your authorized representatives;
To External Partners, provided they comply with privacy laws and contractual obligations to use the information only for the intended purposes;
If and when we are involved in a corporate reorganization or if we sell or lease all or part of our business;
To meet legal and regulatory requirements; and
Where required or permitted by law.

While CompareHealth requires External Partners to adhere to privacy laws and contractual obligations, CompareHealth disclaims liability for any breaches of personal information that occur due to the actions or omissions of third parties. Users are encouraged to independently verify third-party compliance when providing additional information.

Responsibilities of Advisors and External Partners

Advisors and External Partners receiving personal information through CompareHealth are required to:

Obtain explicit consent before contacting Leads, in accordance with applicable privacy and anti-spam laws.
Use Leads’ personal information exclusively for the purpose of offering insurance-related services.
Maintain confidentiality and implement robust security measures to protect personal information.
Notify CompareHealth promptly in case of any data breach involving Leads’ or Clients’ personal information.

In such circumstances, we will not disclose more information than is required for the purpose for which the information is being disclosed. We will also, whenever it is reasonable and practicable to do so, enter into privacy agreements with third parties with whom we share personal information.

We will retain personal information only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law. Where personal information has been used by us to make a decision about you, CompareHealth will retain, for a period of time that is reasonably sufficient to allow for access by you, either the actual information or the rationale for making such a decision.

Only our employees who require access for legitimate reasons or whose duties reasonably so require, are granted access to personal information.

We maintain reasonable controls, schedules and practices for personal information management retention and destruction. Personal information that is no longer necessary or relevant for the identified purposes, or is required by law to be retained, is destroyed, erased or made anonymous, as appropriate in the circumstances.

CompareHealth may share non-personally identifiable, aggregated information with Advisors, External Partners, and Insurers. Insurers may access market insights, trend analysis, and comparative insurance data by purchasing a research license. This data does not contain personally identifiable information but may include aggregated user preferences, quote request trends, and competitive benchmarking reports. Research licenses are governed by CompareHealth’s Terms of Use and may be subject to additional agreements with participating Insurers.

CompareHealth may disclose personal information to Advisors and External Partners for the purpose of providing Leads or Clients with relevant insurance products and services. Advisors and External Partners must adhere to this Privacy Policy and applicable privacy laws and may not use the information for unrelated purposes.

CompareHealth requires Advisors and External Partners to follow applicable privacy laws, but CompareHealth is not responsible for how these third parties collect, use, or store user data. Users should review the privacy policies of any Advisor and External Partner before sharing personal information.

Failure to comply with privacy laws or CompareHealth's policies, including misuse of Leads’ or Clients’ personal information, may result in immediate termination of access to the Services, legal action, and monetary penalties as permitted by law.

CompareHealth website

Our website may use various technologies, from time to time, to:

Help us customize your experience on our website;
Track your use of our website for advertising, marketing, or promotional purposes;
Help us determine whether you opened an email message from us; or
Gather information to deliver advertisements about products and services we think may be of interest to you.

This information enables us to:

Customize the services we offer you, to improve our website;
Estimate our audience size and usage patterns;
Store information about your preferences, allowing us to customize our website according to your individual interests, including showing you advertisements that we think will be of interest to you;
Speed up your searches;
Recognize you when you return to our website;
Show our advertisements on external sites; and
Assist us in providing a better customer experience by understanding consumer behaviour.

Your choices about how our website collects your information

We strive to provide you with choices regarding the personal information you provide to us.

You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using opt out tools created by Google Advertising, the Digital Advertising Alliance of Canada or by the Network Advertising Initiative. You may also opt out of our use of Google Analytics by visiting the Google Analytics opt out page. We may have reporting of your aggregate interactions with our ads across the Google Display Network or DoubleClick for Advertisers in conjunction with activity on our website.

You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. 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.

In addition, we have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this website may not be accessible or may not function properly.
Promotional Offers. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by CompareHealth to promote our own or third parties’ products or services, you can opt out by contacting CompareHealth support: hello@comparehealth.ca. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by using the opt out tools created by the Digital Advertising Alliance of Canada, the Network Advertising Initiative or Google Advertising.

Accuracy of personal information

We make reasonable efforts to ensure that personal information we collect, use or disclose is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Please be advised, however, that CompareHealth is driven by third party information sources, the accuracy of which we cannot control.

If you find any errors in our personal information holdings (including information provided by a third party information source), we should be informed so that we can make the appropriate corrections. We will convey these corrections to any third party that may have been provided inaccurate information. For personal information that remains in dispute, we will make note in our records of your opinion as to the accuracy of the relevant personal information.

External Partners are responsible for verifying the accuracy of Leads’ personal information before proceeding with any health insurance-related activities.

Security of personal information

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to prevent any unauthorized access, disclosure, copying, use, or modification of personal information. Safeguards include securing physical documents and technological measures by way of secure access and encryption. We store all information you provide to us behind firewalls on our secure servers.

CompareHealth employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent it from being lost or destroyed.

We protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the personal information and the purposes for which it is to be used.

We may engage service providers to assist us with fulfilling the purposes for which personal information has been collected, used and disclosed, and, in some instances, these service providers may be located outside Canada. We only select service providers that protect personal information in a manner that is comparable to the protection we provide under our own privacy policies. However, personal information may be subject to, and accessed under, the laws of the countries in which our service providers operate. If you have any questions about our transfer of personal information to our service providers outside Canada, or if you would like to learn more about our privacy policies in that regard, please contact the CompareHealth Privacy Officer at the contact information provided below.

Openness concerning our policies and procedures

We are open about the policies, procedures and practices we use to protect your personal information. Information about these policies, procedures and practices will be made available to you either electronically or in writing.

Access to your personal information

You may access any personal information that we have concerning you, and which has been collected, used or disclosed for a commercial purpose, by sending a written request to the CompareHealth Privacy Officer. CompareHealth may advise you in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days, or advise that the request for access is subject to an extension as authorized by PIPEDA.

To protect your privacy, you may be required to provide sufficient identification, in order to permit us to account for the existence, use and disclosure of certain personal information and to authorize access to such information. Any such information will only be used for this purpose.

We may not be able to provide personal information to you if doing so would violate the privacy of a third party or if certain personal information is subject to legal privilege, contains information proprietary to us or a third party, is too costly to retrieve, or cannot be disclosed for other legal reasons. If we are unable to provide access to all or part of your personal information, we will explain our reasons for such a decision.

Where you have been provided with access to your personal information, you will be able to challenge the accuracy and completeness of your personal information and have it amended as appropriate.

Personal information that is disclosed to third parties by us will be subject to the general laws applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, we may not be legally permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, we will provide an account of the collection, use and disclosure of personal information and, where reasonably possible, we will state the source of the personal information. In providing an account of disclosure, we will provide a list of organizations to which we may have disclosed your personal information when it is not possible to provide an actual list.

Challenging compliance with privacy laws

All questions or concerns regarding our privacy practices should be directed to the CompareHealth Privacy Officer.

We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures. We will inform you of the outcome of the investigation regarding your complaint.

Language

You and CompareHealth have requested and agree that this Privacy Policy and all documents related to this Privacy Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s'y rattachent soient rédigés en anglais.

Contact Us

This Privacy Policy shall be governed by the laws of the Province of Manitoba and the laws of Canada applicable therein. Any disputes arising under this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Manitoba.

If you have any questions or concerns about this Privacy Policy or about CompareHealth's information handling practices, please contact us at:

privacy@comparehealth.ca

Attn: Privacy Officer

Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.