Johnson Inc. and other members of the Johnson group of companies (“Johnson”, “we”, “our”, “us”) are committed to protecting your privacy and the confidentiality of your personal information. The Johnson group of companies includes Johnson Inc., and their subsidiaries involved in general insurance products and services. In certain locations Johnson Inc. operates under various trade names and styles that it owns, including, Johnson Insurance, Cummings-Cossitt Insurance, Flewwelling Insurance, Hunt Insurance, Batty & Associated Insurance, Bradley’s Insurance – Home and Auto, Compass Insurance, Marshall & Woodwark Insurance, Thomson Jemmett Vogelzang, TJV, Morgex Insurance, Haber Blain Insurance, Crain & Schooley Insurance, Crain & Schooley Financial, JB Insurance Services, Bell & Grant Home and Auto Insurance, Tingley Home & Auto Insurance, Central Home & Auto Insurance, Amherst Insurance, Asbell Insurance, Pratt, Lambert & Brown Home and Auto, a division of Johnson Inc. and ACP Insurance. Under licence from the owner of the brand name, Johnson also operates under the trade name and style, “Servus Insurance Services – Home and Auto”.

This Privacy Policy sets out our responsibilities regarding the collection, use and disclosure of our applicants’, insureds’, former insureds’, customers’, former customers’ and claimants’ (“you” or “your”) personal information in Canada. Personal information is information about you as an identifiable individual and may include such information as your age, marital status, education, employment history, identification numbers and financial information. It does not include certain publicly available information, such as certain telephone directory listings of your name, address and telephone number.

Protecting this information is one of our highest priorities and as such we have instituted policies and procedures and use vigorous security safeguards to protect your privacy and the confidentiality of your personal information. The protection of your personal information is an integral part of our service commitment to you.

Why do we collect, use, and disclose personal information about you?

We collect, use and disclose personal information (including to and from our affiliates and / or subsidiaries, referring organizations and / or third party providers / suppliers)  for the following purposes.

• Establish your identity
• Understand and assess your needs and eligibility for products and services
• Analyze, assess, underwrite and reinsure risk
• Facilitate payment of your premiums through credit card or through bank, payroll, or pension  deductions
• Investigate and settle claims
• Protect you and us from error, fraud, and illegal activity
• Communicate with you
• Ensure quality assurance
• Establish and maintain responsible commercial relations with you
• Develop, enhance, market, or provide products and services
• Analyze business results and to report to appropriate regulatory or industry entities
• Marketing
• Compile statistics, conduct market research in accordance with prudent practices
• Comply with the law or requests of law enforcement officers or regulators
• Provide ongoing service
• Survey your customer and claims experiences and satisfaction; and
• Your personal information may be collected, used or disclosed for other purposes with your consent or as permitted or required by law

What personal information do we collect?

We obtain most of your personal information directly from you. However, we may need to collect information from other sources. We will only collect information pertinent to the appropriate purpose. The personal information we collect includes.

• Name, address, telephone numbers, fax numbers, or e-mail address
• Birth date, gender, marital status
• Driving record, including moving traffic violations and convictions
• Medical and health information
• Details about your automobile, such as make, model, value
• Details about your home and its contents, such as its size and value
• Previous insurance and claims history
• Employment information
• Banking information, credit card information, credit history, and payment records
• Customer and claims experience and satisfaction; and
• Such other information we may collect with your consent or as permitted or required by law

How do we collect your information?

We may collect information from the following sources.

• You, or any person authorized by you, on applications for insurance or service products, or other forms  filled out in person or through telephone, email, or online
• Government, industry and other entities authorized by law that have information on your claims history  or pertinent to an application for insurance
• Consumer reporting agencies
• Your continued interaction with us, such as payment history or claims settlement; or
• Reputable, third party market research agencies who conduct customer and claims satisfaction  surveys on our behalf
• We may verify your personal information, or obtain additional personal information about you by checking with government agencies, credit bureaus, motor vehicle agencies, and other authorized fact collecting and verifying entities

We use session cookies (small data files that a site sends to your computer). They do not contain personal identifiable information. We use cookies and IP addresses to obtain information from online visitors to determine how many people visit our website.  You can set your browser not to accept cookies or have your computer notify you when cookies are being sent by following the instructions for your particular web browser.  However, if you refuse cookies, you may not be able to use certain features of our website.

With whom do we share information about you?

We may share information with the following.

• Any person authorized by you
• Any person required or permitted by law to have access to your personal information
• Any person as is necessary to meet our legal, regulatory, insurance, audit, processing and security  requirements or to protect our reasonable business interests
• Intermediaries, such as authorized providers of claims history or motor vehicle abstracts to insurers
• Applicable motor vehicle registries and driver license authorities
• Other insurers, agents or brokers, as necessary
• Professionals, such as lawyers, doctors or adjusters working with or retained by us
• Credit and financial organizations
• Credit card issuers and processors; and
• Industry data collection agencies for the purpose of analyzing business results
• If you are a member of an organization that participates in one of our home and auto insurance sponsorship programs, we may share certain personal information, such as your name, with your sponsor organization to confirm your membership and eligibility and maintain current lists of your sponsor group

When we share personal information with third parties, we provide only that information that is required in the circumstances and we take reasonable contractual or other measures to protect your personal information.

Service Providers:  We may transfer personal information to third party agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as administrative and technical services, verification services, claims management services, collection services, marketing and research services, data hosting, processing or similar services, or that otherwise collect, use, disclose or store personal information on our behalf for the purposes described in this Privacy Policy.  We or service providers acting on our behalf may process and/or store some or all of your personal information in jurisdictions outside of Canada, including the United States.  You should note that some jurisdictions outside of Canada may not have laws that provide privacy protections that are substantially similar to those in Canada.    We take reasonable contractual or other measures to protect your personal information while processed or handled by our service providers.

Business Transactions:  Personal information may be used and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of: permitting such parties to determine whether to proceed or continue with such transaction, and to fulfil reporting, inspection or audit requirements or obligations to such parties.  Assignees or successors of our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

How may you give your consent?

There are many ways you can give consent.  Consent can be express, for example, in writing on a form you may sign describing the intended uses and disclosure of personal information, verbally, or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you’ve taken or when you continue to use a product or service after we’ve notified you of a change with respect to your personal information and you have not withdrawn your consent, such as by using an “opt out” option provided, if any. You may indicate your consent by the following.

• Providing your personal information to us for the purposes of acquiring an insurance related product or  service, including information previously provided to us
• Your express consent or acknowledgement contained, for example, within a written, verbal, or  electronic application process
• Your express consent solicited by us for a specific purpose
• Your receipt of this Privacy Policy until you notify us of a withdrawal of this consent; or
• Your consent given through your authorized representative such as your legal guardian, agent, or holder of power of attorney

We maintain your consent for electronic messages (e.g. email and text messages) in compliance with the Canadian Anti-Spam Legislation.

Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.

By providing personal information about a third party such as a family member you represent that you have obtained their consent to the collection, use, and disclosure of such personal information in accordance with this Privacy Policy.

May you withdraw your consent for us to collect, use and disclose your information?

Subject to certain legal and contractual obligations you may, on reasonable notice, withdraw your consent to the collection, use, or disclosure of your personal information. If you do not wish to consent or if you withdraw your consent we may not be able to provide you with a particular product or service.  Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures of the personal information.   We will explain the impact of withholding or withdrawing your consent, to help you with your decision.

If you wish to withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed below. Unless we hear otherwise from you, you are giving to us your consent for the collection, use, and disclosure of personal information as provided in this Privacy Policy.

We may contact you on behalf of us or our affiliates to offer other insurance products and services through direct mail, telephone, or other means.  If you would rather not receive such information, please use the contact information below to let us know.

How long will we retain your personal information?

We will retain your personal information only as long as necessary to satisfy legal or business obligations, including reasonable business record-keeping obligations. The length of time we keep your information depends on the product or service and the nature of the personal information. We have retention standards that meet customer service, legal, and regulatory needs. When the information is no longer required, we securely destroy it or convert it to an anonymous form.

How do we keep your personal information accurate and secure?

We take reasonable steps to ensure the information in our records is correct and up to date, however we rely on you to tell us when your personal information changes.

As part of our effort to keep your personal information secure, we limit access to your personal information and store it securely using a variety of physical, technological, and organizational safeguards appropriate to the sensitivity of the information. Depending on the nature of the information, it may be stored in the branch you deal with, in various secure computer systems, or in archives in various locations across Canada.

Authorized employees, agents and mandataries who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

Do you have the right to request access to your personal information?

Yes, you have the right to request access or correction of your personal information that we have in our possession or control. You also have the right to know which third parties have received your information from us.

To request access or correction of your personal information, please make your request in writing to our Privacy Officer, being as specific as possible as to which personal information you are requesting. We will advise you if for some reason we cannot respond right away. We may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.

In providing you with a list of the organizations to which we have disclosed any of your information, we will try to be as precise as possible. When it is not possible to provide an exact list of such organizations to which we have actually disclosed your personal information, we shall provide a list of organizations to which we may have disclosed the information.

We may refuse your request for access to your personal information if, for example.

• the information is protected by solicitor-client privilege
• granting access would reveal confidential commercial information
• doing so would reasonably be expected to threaten the life or security of another individual
• the information was collected for purposes related to the detection and prevention of fraud
• the information was generated in the course of a formal dispute resolution process; or
• the information would likely reveal personal information about another individual

What if you have a question or concern about your privacy?

We are responsible for the personal information under our control and have designated a Privacy Officer to be accountable for compliance with this Privacy Policy. If you have any questions or concerns about our privacy practices or compliance with our Privacy Policy or procedure, or if you would like more information about our policies and practices regarding service providers outside Canada, please contact our Privacy Officer at 1-800-507-4115, fax # 1-888-737-4125, or email [email protected], who will respond to your question or investigate your complaint. If you are not satisfied with our response to a privacy related inquiry or complaint, you may contact the Office of the Privacy Commissioner of Canada, or your provincial privacy commissioner, if applicable.

The Privacy Policy may change from time to time.  If we intend to use or disclose personal information for purposes materially different than those described in this policy, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Policy.  If you are concerned about how your personal information is used, you should contact us as described above or check our website periodically at www.johnson.ca to obtain a current copy of this policy.  We urge you to request and review this Privacy Policy frequently to obtain the current version.  Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.  This Privacy Policy is effective as of January 1, 2015.