Privacy Policy

Personal information is any information about an identifiable individual as described under Canadian privacy laws. Personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work email address. Personal information also does not include information that has been anonymized or aggregated in such a way that it is, at all times, reasonably foreseeable in the circumstances that it irreversibly no longer allows identification of an individual, whether on its own or in combination with other information. 

We may collect, use and disclose different types of personal information, depending on our relationship with you. We generally collect the following types of personal information (not all of which may apply to you): 

• identity information such as your name, date of birth and gender;
• business contact information such as your billing address, email address and telephone numbers;
• professional information such as your brokerage name, RIBO number and designations;
• financial information such as your bank account number and payment card details used to renew your membership or pay for our programs and services we provide;
• technical and usage information when you use our website such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
• educational information such as your participation and registration in courses and training we may offer, and your performance and results of any examinations;
• event participation information such as your enrollment and attendance at our events;
• information you provide via surveys and contests;
• marketing and communication information, such as your preference for receiving our newsletter. 

We generally use your personal information for the following purposes: 

• to communicate with you about our programs and services;
• to provide you with information about industry changes;
• to provide you with information about our Board and committee activities;
• to register you for programs and to manage your membership with us, including to send invoices and statements to you for membership dues;
• to aggregate data and identify general trends;
• to respond to your enquiries, complaints or requests; 
• to investigate legal claims and protect our rights, operations or property;
• other purposes that are permitted under applicable law. 

We may share your personal information with: 

• our regional and provincial affiliate associations who use this information to verify which brokerage members fall under their territory;  
• the Insurance Brokers Association of Canada (“IBAC”) who use this information to verify graduates from IBAC designation programs; 
• the service providers we rely upon to perform a variety of services on our behalf such as our database technology providers, payment card processors, data hosting providers, research and analytics service providers (collectively, “Service Providers”). If we transfer your information to a Service Provider, we require that they maintain the confidentiality of your personal information, keep it secure and comply with applicable privacy laws, only using your personal information for the limited purposes for which it is provided.  

We may also disclose your personal information where we believe such disclosure is required or permitted by law or regulation. 

We collect, use and disclose your personal information with your consent or as permitted or required by law. The method by which we obtain consent, including whether it is express or implied, will depend on the circumstances and sensitivity of the personal information being collected, used or disclosed.  

Generally, IBAO will seek your consent (either verbally, in writing or electronically) at the time we collect, use or disclose your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or disclosure. 

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information as described in this Privacy Policy. 

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer in writing using the information in the “How to Contact Us” section below. In certain circumstances, the withdrawal of consent may render us unable to continue to provide our programs and services to you.

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 and used purely for technical purposes and to facilitate use of our website. One type of cookie saves a file permanently on your computer. Cookies will be used to personalize a web page according to the user’s choices and interests. The other main type of cookie is called a session cookie. While you are visiting a web page, session cookies are sent between your computer and the server to access information. Session cookies disappear when you turn off your web browser. For more information about cookies generally please visit www.allaboutcookies.org. 

We utilize cookies that are technically necessary and that increase the functionality of using our website. In addition to cookies, we may use web beacons, pixels and similar technologies when you use our website for our business or analytical purposes, such as assessing traffic on our website and understanding how customers utilize it. 

If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. If you decide not to accept cookies from our website, you may not be able to take advantage of all of its features.

Our website utilizes Google Analytics, a service from Google, Inc. (“Google”) that uses cookies. The information collected by the cookies (which includes your IP address) is transferred to Google who stores and processes the information in the United States. Google uses the information to provide us with an analysis of your use of our website, overall use of and traffic on our website. You can opt out of Google Analytics by downloading and utilizing the Google Analytics Opt-out Browser Add-on. By using our website, you understand and acknowledge our use of Google Analytics. 

We may send you information about programs and services that we believe may be of benefit to you.  Where applicable, we rely on our existing business or non-business relationship with you to send these marketing messages electronically. If we do not have an existing business or non-business relationship with you, we will obtain your opt-in consent to send these marketing messages to you, unless we are otherwise permitted to send the message under applicable law.   

If you no longer want to receive these marketing messages electronically from us, you may opt out of receiving them by clicking the “unsubscribe” link at the bottom of any electronic message you receive from us. You may also opt out by contacting us directly using the contact information in the How to Contact Us section below.  

Please note that if you opt out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters. 

IBAO only retains your information for as long as necessary to fulfill the purpose for which it was originally collected or as required by law, in accordance with its records retention policies. 

We store all personal information we collect in Canada. We may transfer your personal information outside of Canada to fulfil the purpose for which we collected it, including for processing and storage by Service Providers. These jurisdictions may include the United States of America. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the How to Contact Us section below. 

The IBAO maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. 

Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in risks such as phishing and identity theft. In such cases, we will act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law. 

We may also require that you assist us in safeguarding your personal information. For example, you are responsible for maintaining the confidentiality of any password(s) you are given to access our website and are fully responsible for all activities that occur under your password(s). If you have reason to believe that your personal information is no longer secure, please contact us immediately using the contact information in the How to Contact Us section below. 

You may make a request to access or review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by applicable laws. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you an administration fee to access your personal information; however, we will advise you of any fee in advance. We will respond to your request within 30 days. 

We expect you to supply us with updates to your personal information when required. We will not routinely update your personal information unless such a process is necessary. 

You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate, incomplete or equivocal, we will amend or delete your personal information as required. Where appropriate, we will transmit the amended information to third parties to whom we have disclosed your personal information. 

Your right to access, update, or challenge the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to adhere to your request. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event of any of the foregoing, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

Any request to access, update or challenge your personal information that we have collected, used or disclosed can be made in writing using the contact information set out in the How to Contact Us section below. 

Our website contains links to other sites that IBAO does not own or operate. Links to our website may be featured on third-party websites on which we advertise. Except as described in this Privacy Policy, we will not provide any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you review. We do not have any control over such websites and therefore have no responsibility in respect of them. 

The IBAO encourages you to provide feedback, questions, comments and suggestions to us on our website, programs and services. Any such information submitted by you to the IBAO shall be deemed to be non-confidential. The IBAO has no obligation of any kind with respect to such information and shall be free to reproduce, use, disclose and distribute the information to others without limitation. The IBAO shall be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose. However, the IBAO will not use your name or otherwise publicize the fact that you submitted materials or other information to the IBAO unless: (a) we ask your permission to use your name; or (b) we first notify you that the materials or other information you submit to a particular part of this site will be published or otherwise used with your name on it; or (c) we are required to do so by law. 

Our Privacy Policy was last revised as of the date that appears at the bottom of this page. From time to time, we may make changes to our Privacy Policy. Any changes that affect your rights will be communicated to you and posted on our website. We encourage you to refer back to it on a regular basis. 

Your privacy matters. If you have any questions or concerns about your privacy rights or how we manage your personal information, please let us know. Our Privacy Officer oversees compliance with our privacy obligations and commitments — their contact details can be found below.  

 

Insurance Brokers Association of Ontario 

Privacy Officer: Brett Broadway 

Phone: (416) 488-7422 

Email: bboadway@ibao.on.ca  

Mailing Address: Insurance Brokers Association of Ontario 

1 Eglinton Avenue East, Suite 700 

Toronto, ON M4P 3A1 

 

If after following these procedures, you remain dissatisfied with our privacy practices, you are entitled to make a written submission to the Privacy Commissioner of Canada or the Office of the Information and Privacy Commissioner of Ontario using the following methods: 

 

Office of the Privacy Commissioner of Canada (OPCC) 

Phone: (800) 282-1376 (toll-free) 

Website: www.priv.gc.ca 

Mailing Address: Office of the Privacy Commissioner of Canada 

30 Victoria Street 

Gatineau, QC K1A 1H3 

 

Office of the Information and Privacy Commissioner of Ontario (OPCO) 

Phone: (800) 387-0073 (toll-free) 

Website: https://www.ipc.on.ca 

Mailing Address: Office of the Information and Privacy Commissioner of Ontario 

2 Bloor Street East, Suite 1400 

Toronto, ON M4W 1A8