Privacy Policy

QUBE RISK SERVICES LTD. (the “Company”) is committed to protecting the privacy and security of all Personal Information inputted via its website at www.quberisk.ca (the “Website”) or stored on servers under its control. This policy explains the steps the Company takes to ensure Personal Information is handled appropriately. The Company’s policies and practices have been designed to comply with the Personal Information Protection Act of British Columbia (“PIPA”).

This Privacy Policy applies to all users of the Website.

1. Definitions

1.1. “Personal Information” means information about an identifiable individual including name, age, home address, income, employment information, etc. Personal information does not include Contact Information.

1.2. “Contact Information” means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact Information is not covered by this privacy policy or by PIPA.

2. Changes to Privacy Policy

2.1. The Company may make changes to this Privacy Policy from time to time in its sole discretion without notice to users of the Website. The most recent version of this Privacy Policy will be posted on the Website, and you should regularly check the Website for updates. If you continue to use the Website after the Privacy Policy changes, you will be deemed to have agreed to the new Privacy Policy.

3. Collecting Personal Information

3.1. Unless the purposes for collecting Personal Information are obvious and the user provides his or her Personal Information for those purposes, the Company will communicate the purposes for which Personal Information is being collected before or at the time of collection.

3.2. The Company will only collect Personal Information necessary to fulfill the purposes set out in Section 5.1 below.

3.3. Examples of the Personal Information the Company collects include:

• name;
• email address;
• phone number; and
• Website usage data (including IP address, browser type, unique device identifiers, and other diagnostic data).

4. Consent

4.1. The Company will obtain user consent to collect, use, or disclose Personal Information (except where, as noted below, the Company is authorized to do so without consent).

4.2. Consent can be provided orally or in writing, or it can be implied where the purpose for collecting, using, or disclosing the Personal Information would be considered obvious and the user voluntarily provides Personal Information for that purpose.

4.3. Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users can withhold or withdraw their consent for the Company to use their Personal Information in certain ways. A user’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict the Company’s ability to provide a particular service or product.

5. Using Personal Information

5.1. The Company will use Personal Information for the following purposes:

• to communicate with users generally;
• approving, quoting, administering, servicing and managing your insurance coverage;
• determining your eligibility and suitability for, and providing you with, other products and services you request;
• verifying your identity and other information you have provided to us (including your identity and bank account if applicable);
• meeting legal and regulatory requirements;
• detecting and preventing fraud and other unauthorized or illegal activities;
• as otherwise permitted or required by applicable law; and
• to fulfil any other purpose that would be obvious to a reasonable person.

6. Sharing Personal Information

6.1. The Company may share Personal Information with third party web hosting services to facilitate the storage of Personal Information.

6.2. The Company may publish Personal Information on the Website in order to allow potential buyers of a user’s property to communicate with that user.

7. Retaining Personal Information

7.1. If the Company uses a user’s Personal Information to make a decision that directly affects that user, the Company will retain that Personal Information for at least one year so the user has a reasonable opportunity to request access to it.

7.2. Subject to Section 7.1, the Company will retain Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

8. Ensuring Accuracy of Personal Information

8.1. The Company will make reasonable efforts to ensure that a user’s Personal Information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization.

8.2. Users may request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.

8.3. If the Personal Information is demonstrated to be inaccurate or incomplete, the Company will correct the information as required and send the corrected information to any organization to which the Company disclosed the Personal Information in the previous year.

9. Securing Personal Information

9.1. The Company committed to ensuring the security of Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.

9.2. The Company will employ the following security measures to ensure that Personal Information is appropriately protected:

• physical security measures such as restricted access facilities;
• electronic security measures for computerized data such as password protection and database encryption;
• organizational processes such as limiting access to Personal Information to a selected group of individuals; and
• contractual obligations with third parties requiring them to protect and secure your Personal Information.

9.3. The Company will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

10. Providing Access to Personal Information

10.1. Users have a right to access their Personal Information, subject to limited exceptions.

10.2. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought.

10.3. Upon request, the Company will tell users how the Company uses their Personal Information and to whom it has been disclosed, if applicable.

10.4. The Company will make the requested Personal Information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

10.5. If a request is refused in full or in part, the Company will notify the user in writing, providing the reasons for refusal and the recourse available to the user.

11. Cookies, Interest-Based Advertising, and Third-Party Advertising

11.1. Cookies, Tracer Tags & Web Beacons

• Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (i) may let us know who you are, (ii) may be necessary to access your account information (stored on our computers and/or servers) in order to deliver products and personalized services to you, and (iii) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences. We and our service providers (such as Google Analytics) also use cookies to help us understand our website activity, to improve our Website and provide better customer service. For more information about Google Analytics, see www.google.com/policies/privacy/partners/.
• You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the features of our Website.
• Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.

11.2. Third-Party Advertising, Links and Content

• Our Website may contain links to content maintained by third parties that we do not control. We allow third parties, including business partners, advertising networks, and other advertising service providers, to collect information about your online activities through cookies, pixels, local storage, and other technologies. These third parties may use this information to display advertisements on our Website and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.
• Some third parties collect information about users of our Website to provide interest-based advertising on our Website and elsewhere, including across browsers and devices. These third parties may use the information they collect on our Website to make predictions about your interests in order to provide you with ads (from us and other companies) across the internet. Some of these third parties may participate in an industry organization that gives users the opportunity to opt out of receiving ads that are tailored based on your online activities. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable targeted ad technologies in mobile apps. Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings.
• You may be able to opt out of interest-based advertising through the settings within the mobile app or your mobile device, but your opt-out choice may apply only to the browser or device you are using when you opt out, so you should opt out on each of your browsers and devices if you want to disable all cross-device linking for interest-based advertising. If you opt out, you will still receive ads but they may not be as relevant to you and your interests, and your experience on our Website may be degraded.

11.3. Safeguards and Retention

• We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. We have Personal Information retention processes designed to retain Personal Information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of your relationship with us).

12. Privacy Officer

12.1. The Company’s Privacy Officer is responsible for ensuring the Company’s compliance with this policy and PIPA.

12.2. Users should direct any complaints, concerns or questions regarding the Company’s compliance in writing to the Company’s Privacy Officer at:

• info@quberisk.ca; or
• 777 Hornby Street, Suite 600 Vancouver, BC V6Z 1S4
• Attention: Privacy Officer

12.3. If the Privacy Officer is unable to resolve the concern, the user may also write to the Information and Privacy Commissioner of British Columbia