Last Revised: June 14, 2023
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.
This Privacy Policy applies to personal information, in any form, collected, used or disclosed by CompareHealth in the course of commercial activities. It will not typically apply to information directly regarding CompareHealth's corporate clients. However, such information may be protected by other CompareHealth policies and through contractual arrangements.
This Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by CompareHealth:
The application of this Privacy Policy is subject to the requirements and provisions of PIPEDA, and any other applicable legislation or regulation. If you reside in British Columbia, Alberta or Québec, then the substantially similar provincial privacy law of your province will apply to our handling of your personal information, rather than PIPEDA. In that case, reference in this Privacy Policy to PIPEDA will be deemed to include your province's substantially similar privacy law.
Advisors: Insurance brokers who are independent or affiliated with a Brokerage or insurer.
Additional users: Affiliated individuals, such as Advisors and employed staff of an organization, authorized by a User to access their account and to use its features.
Brokerage: Insurance agencies with more than one affiliated Advisor or a managing general agent (MGA).
Clients: Customers or prospective customers of Users and Additional Users, identified by province, date of birth and sex.
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent we seek may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, we take into account the sensitivity of the personal information and your reasonable expectations. Consent may be provided directly by you, or by your authorized representative, in accordance with applicable law.
disclosure: Making personal information available to a third party.
employee: An employee of, or an independent contractor to, CompareHealth. The inclusion of independent contractors within the definition of "employee" is for convenience of reference only, and should in no manner imply that such independent contractors are our employees within the meaning of employment legislation or are in an employee-employer relationship with us.
personal information: Information about an identifiable individual, but does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address. Where an individual provides their home address to CompareHealth as their business contact information, CompareHealth considers it to be business contact information, and is therefore not subject to protection as personal information. Information about corporations is not considered personal information.
third party: An individual or organization outside of CompareHealth.
use: The treatment, handling, and management of personal information by and within CompareHealth or by a third party with the knowledge and approval of CompareHealth.
User: An Advisor or Brokerage (as those terms are defined above).
CompareHealth is an online platform that makes quoting and comparing personal health and replacement health insurance plans easy for Advisors, Brokerages and Clients in Canada by generating Client quotes for these health insurance products, on-demand.
Users can modify each Generated Client Quote for up to sixty (60) days, without charge to the User. Each Generated Client Quote is based on the Client’s province, sex and date of birth. CompareHealth will assign a unique Quote ID for each Generated Client Quote. Users may modify other comparison criteria in the Generated Client Quotes, such as the Client’s family details and specific benefits which are requested by the Client, without further charge.
CompareHealth allows Users and Additional Users to create and manage quotes, manage account details, input unique commission links for provinces and insurance providers to be credited for sales, and access Tier-specific features such as allowing Clients to generate their own quotes. The Administrator Account provides additional access to manage provinces and providers for the User account and the account of all Additional Users, view subscription payments, and add Additional Users.
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.
CompareHealth collects personal information from you for the following purposes:
Further reference to “identified purposes” mean the purposes identified in this section of this Privacy Policy.
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 person within CompareHealth who can explain these identified purposes.
If you request information, products or services from CompareHealth, we will collect your name and contact details, such as your email address, mailing address and telephone number. In addition, if you have created an account with us, we may collect other information that is associated with your account, such as account activity (including information you input into CompareHealth for the purposes of generating and forwarding Client quotes) and your credit card or other payment information, in order to pay for products and services we make available to you, from time to time. We collect this billing information only for the purposes we indicate to you at the time of collection.
If you engage with our social media accounts, we will collect whatever information you provide to us through the applicable platform.
We may also provide you an opportunity to specify certain preferences in respect of our products or services. If you choose to provide such information, we will collect and implement your preferences.
CompareHealth will only collect personal information that is necessary for the purposes identified in this Privacy Policy or as otherwise agreed to by you.
In most cases, we collect your personal information directly from you. Sometimes, however, we use third parties to provide us your personal information, such as when a User has associated an Additional User with its account.
We collect no personal information about you unless you choose to provide that information to us. We do not use techniques that collect personal information about anyone without their knowledge. We only collect personal information about individuals when they specifically and knowingly provide it to us, for example, when they fill out a registration form on our website, contact us by telephone or email or input information to generate a Client quote. As a limited exception to this principle, we may collect personal information without your consent:
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.
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.
By signing up for an account, you are giving CompareHealth permission to contact you by way of the information you provide. Should you wish not to be contacted by CompareHealth, please opt-out under CompareHealth’s Account Settings and Preferences, or contact hello@comparehealth.ca to do so.
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:
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 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 aggregate information – not personal information – about its users and Generated Client Quotes with other parties and related service providers, to help them better understand CompareHealth users and their interests. Such aggregate information is used to give CompareHealth demographic data about its users in order to improve our organization and the products and services we provide.
Our website may use various technologies, from time to time, to:
This information enables us to:
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:
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 accuracy of the relevant 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.
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.
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.
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.
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.
If you have any questions or concerns about this Privacy Policy or about CompareHealth's information handling practices, please contact us at:
Attn: Privacy Officer
Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.