Privacy
Our privacy promise describes in clear language how ING ensures the protection of the personal information you entrust to us.
Please read this document carefully, not because anything in it is difficult to understand, but because we want you to know that ING protects your personal information. As you read you will come across certain specialized words, Industry Terms. We have underlined these words and provided definitions to make sure everything is perfectly clear. Simply look under our section Industry Terms, and what they mean.
We view our Privacy Promise as if it were an ING product, not just a legal obligation. And as you know, we believe in superior products.
When you became an ING client, you shared important personal information with us. You did this so we could serve you better and knowing we would honour and respect your privacy. Your trust was not misplaced. At ING we are committed to offering you superior products and services, so it should come as no surprise that we are also committed to meeting the privacy standards applicable to you.
Let's be perfectly clear.
What is personal information?
Personal information is any information that relates to a natural person and allows that person to be identified.
What information are we responsible for protecting?
ING Canada is responsible for protecting your personal information in its possession or custody, including personal information that has been transferred to, or received from our service providers, agents or other third parties in the course of commercial activities for processing or other purposes for which you have consented.
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Collecting, using and disclosing your personal information. Why do we do it?
We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your insurance and financial needs, communicate effectively with you, and provide you with the services and products you want.
Let's be specific.
We collect, use and disclose your personal information to:
- verify your identity
- determine your eligibility for ING Canada insurance and financial products and services, whether purchased through ING or your broker, and for products and services that may be of interest to you from organizations with whom we have strategic alliances, and to offer these products and services to you
- assess and
- underwrite insurance and reinsurance risks
- determine prices, fees and premiums
- investigate and settle claims
- detect and prevent fraud
- compile statistics, conduct market research, and report to regulatory or industry entities in accordance with prudent insurance practices, including claims
- investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities determine the suitability of your investments
- comply with the law
- or comply with tax requirements
How do we gather your personal information?
The collection, use and disclosure of your personal information depend on how you do business with us. As a general rule, we gather information directly from you unless you consent to the collection of your personal information from third parties.
As a result, we may gather information from the following sources:
- from you, on applications for our insurance and investment products, or on other forms filled out through telephone, e-mail or face-to-face interviews
- from licensed agents, insurance brokers, intermediaries and financial services representatives with whom you have a relationship, as well as adjusters and inspectors
- from your interactions with us (for example, through your payment history, underwriting and claims)
- from government and other entities, that have information on your driving record and claims history
- or from consumer reporting agencies (for example, your credit history
What you are committing to when you share personal information with us.
When collecting personal information, either directly from you or from any of the above mentioned sources, we establish a file and we will inform you of the identified purposes for which it is being collected. We will not use your personal information for a purpose that is not relevant to the object of the file without obtaining your consent.
We may disclose your personal information to third parties if we have sought your prior consent except under certain situations in which we are authorized by law such as the use and communication of personal nominative information for commercial prospection purposes in order to offer you products and services.
Within each company of ING Canada, personal information will be accessible to our employees, mandataries or agents for whom accessibility is necessary in the performance of their duties or the execution of their mandates.
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Your consent.
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in situations permitted by the law, such as during a fraud investigation, an investigation by the police.
How do you provide us with your consent?
The consent to the collection, use or disclosure of personal information will always be express and for specific purposes. Express consent may be oral, in writing or in electronic format unless otherwise specifically prescribed under pertinent legislation.
You have the power to say no.
How you can withdraw.
Please note, however, that withdrawing may affect our ability to continue to provide you with the products and services that you have or would like to receive. As well, you may withdraw from commercial prospection activities at any time upon reasonable notice, subject to legal or contractual restrictions.
To withdraw, you should contact our Privacy Officer at the address listed below.
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How long do we keep your personal information?
Your personal information is retained only as long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements or in order to exhaust the recourses provided by law. ING Canada shall use care when storing or destroying your personal information in order to prevent unauthorized access.
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How do we protect your personal information?
Whether in electronic or paper-based format, ING Canada maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information, we take as much care to destroy it as we do when storing it.
In the event that we transfer your personal information to a third party for processing (for example, when printing cheques, managing claims and client statements, or for data processing), we ensure that any person or organization providing products or services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.
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Your right to access your personal information.
You have a right to access your personal information that we have in our possession or control. You also have the right to request rectification of personal information material to the object of the file subject to the exceptions prescribed by law.
How do you access your personal information?
Please make your request in writing to ING Canada's Privacy Officer, stating as specifically as possible which personal information you are requesting.
We will try to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. ING Canada may charge you a reasonable fee for reproducing, transcribing or transmitting information to you from your file, but only after first advising you of the approximate cost.
ING Canada has the right to refuse your request for access to personal information if:
- the information is protected by solicitor-client privilege
- the information was collected for purposes related to the detection and prevention of fraud
- the information affects judicial proceedings in which either person has an interest
- or the information would likely reveal personal information of a
- third party and doing so would reasonably be expected to threaten the life or security of the third party
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Keeping your information accurate.
A priority.
ING Canada strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the identified purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records.
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If you have a complaint, we want to know about it.
If you have a complaint related to this Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Policy and practices, if necessary.
If we are not able to resolve your concern, or if you have any other concerns about ING Canada's Personal Information Policy and procedures, you may contact the provincial Privacy Commissioner or, if applicable, the Office of the Privacy Commissioner of Canada. ING Canada's Privacy Officer will provide you with this contact information upon request.
You may also address your complaint or a request for examination of disagreement concerning access to your file or rectification to the Commission d'accès à l'information du Québec. Mailing addresses and phone numbers for the Commission d'accès à l'information can be found on its Internet site at: www.cai.gouv.qc.ca.
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Industry terms, and what they mean.
adjuster....A representative of an insurance company who is licensed to investigate claims which are submitted and to negotiate the amount of the settlement, if any.
reinsurance risks....Reinsurance is when an insurance company places all or part of the insurance with another insurance company, who will then be responsible for a percentage of the risk or loss. This does not affect you in any way.
third party....Person other than you who is involved in a transaction.
underwrite....To estimate the value and determine at what amount and on what terms the insurance company will provide insurance. Underwrite is another way of saying insure.
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About this document.
This Personal Information Policy spells out the responsibility of the ING Canada group of companies (ING Canada, ING, we, our, us), and your rights as our applicant, customer, former customer or claimant (you or your), regarding the collection, use and disclosure of your personal information. The ING Canada group of companies includes ING Canada Inc., ING Canada Holdings Inc., ING Insurance Company of Canada, ING Novex Insurance Company of Canada, Belair Insurance Company Inc., The Nordic Insurance Company of Canada, ING Wealth Management Inc., ING Insurance Services Inc., ING Investment Management, Inc., Equisure Financial Network Inc. and its broker subsidiaries, and Wellington Warranty Company Inc.
This Personal Information Policy is subject to any amendments which will be posted on ING Canada's website.
How to contact us. Easy.
Updated versions of this Personal Information Policy are posted on ING Canada's website at www.ingcanada.com, or you can direct any queries about this Policy to ING Canada's Privacy Officer at the mailing address or email address listed below.
For more information, to file a complaint, to make inquiries or to withdraw, please contact ING Canada's Privacy Officer:
ING Canada Privacy Officer
2450 Girouard Ouest
Saint-Hyacinthe, Quebec
J2S 3B3
E-mail Address: privacy@ingcanada.com
Internet: www.ingcanada.com
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