1.    What we collect

Personal information

When providing our services, we collect certain information regarding individuals which allows us to identify them. We collect the information sent to us voluntarily, through the Website interface (for example, when you fill out a form or chat with us) or otherwise (for example, in an e-mail or regular mail). This information may include the following:

• Last name and first name;
• E-mail address;
• Telephone number;
• Physical address;
• Country, Province or State of residence;
• Any information shared with us by an individual via the Website, via chat, by e‑mail or over the telephone.

When you contact us by phone, we gather specific personal information to verify your identity, to provide you with service, and to ensure that we fulfill our contractual obligations. Genesys, our service provider, collects the following personal information:

• Language selected;
• Call’s date and time;
• Call duration;
• Option chosen by the caller; 
• Waiting time.

For our brokerage activities, on top of the above, we may collect information:

• List of Insureds;
• Declaration (DEC page);
• Renewal date;
• Invoices.

We may also collect personal information from other sources, such as subcontractors, which may send FBA non-identifying reports on the use of services provided via their numeric platforms.

Your on-line transactions are secured in accordance with the transmission standards used by Moneris and PayPal, our service providers. We do not collect payment cards numbers.  Payments made via the Website are processed directly by our service provider, PayPal, which has sole access to payment card information.

When you apply for a job with our team, you provide us with the following information to evaluate your application, to contact you to continue the hiring process, and to conduct a background check:

• Your name, telephone number, e-mail address;
• curriculum vitae and cover letter;

This information is accessible only to those responsible for recruitment. We keep your applicant record for as long as is necessary for the purposes described above and to meet legal requirements and contractual obligations.

Information collected automatically

We collect certain information automatically when the Website is browsed, via tools such as log files, chat application or Google Analytics. This information may include the following:

• The IP address used to access the Website;
• The configuration of the browser and operating system;
• The configuration of the mobile device, when the Website is accessed via a mobile device;
• Geographic location and location data;
• The pages visited, the products viewed, the path followed on the Website;
• Key words used during a search; and
• The date and time of the visit.

However, we do not disclose this information.

Information related to cookies

When you visit our website, we may send cookies – a small text file that uniquely identifies your browser – in order to improve the performance of the Website and the user experience. Cookies are saved onto your hard drive by the server on which the Website is located or by third party servers (such as chat plugin). Certain cookies are automatically erased when a user closes his browser, while others remain indefinitely. You can usually control whether cookies are saved through the browser options. However, cookies cannot identify the user (unless otherwise indicated, for example when activating a service related to a user account).

2.    How we use information about you

We collect and use your personal information for the following purposes:

• Provide our services (ex.: brokerage activities).
• Communicate with you and provide the information requested by our users.
• Manage transactions (ex.: brokerage, deductible payments, …).
• Analyse the performance of our numeric platforms regarding our users and the habits of Website visitors and users.
• Enhance the performance of the Websites, particularly by determining which pages are visited and which functionalities are used more frequently, and by monitoring Websites traffic. For this purpose, we use resources provided by Google Analytics to analyze and optimize websites and digital platforms, which possible resources are described at https://policies.google.com/technologies/partner-sites?hl=en&gl=ca
• Identify and solve technical problems with the Website.

3.    Retention of personal information and confidentiality

FBA stores the information if it is necessary to carry out its activities, such as customer service or for legal purposes or commercial purposes. It may be included in its CRM and stored with the highest security standards. When the information doesn’t need to be stored, it is destroyed or erased by secured overwriting.

We consider personal information regarding our users to be confidential. Although it is impossible to guarantee total protection, we take reasonable measures (technical, contractual, administrative and physical) to protect the personal information of our users and clients.

In some cases, we may deal with external service providers who may retain personal information. All our partners and suppliers respect a Confidentiality Agreement. We take reasonable steps to ensure that such external suppliers use reasonable measures to handle the personal information held by FBA in accordance with this Policy and the applicable legislation.

All data is stored on servers located in Canada in a safe venue. All systems are installed behind a firewall featuring enabled, active and monitored intrusion detection and unified threat management (UTM) appliances. FBA relies on an extensive business security protocol. We share our detailed IT security standards and procedures with our clients.

We undertake to keep your personal information only for as long as is necessary to provide you with the service or for legal or commercial purposes.

4.    Disclosure of personal information

Saved as specified in this Policy, personal information collected by FBA is not sold, distributed or leased.  Personal information such as name and address may be disclosed to subcontractors, with the client’s approval, to complete the service offered.

Consolidated information

We may disclose consolidated and non-identifying information obtained from personal information to other persons or organizations. In such a case, we will take reasonable measures to prevent possible identification of an individual based on the consolidated information.

5.    Undesirable messages

We comply with the anti-spam laws and regulations currently in force.

Nonetheless, we will still be entitled to contact our users regarding their claims, their requests for information or their personal information, the whole in accordance with the applicable legislation.

6.    Amendment of the Policy

Users are encouraged to routinely check whether this Policy has been amended. Users are considered to have accepted the amended Policy if they continue to provide personal information after the amendments have been posted.

7.    Governing laws

This Privacy Policy and all transactions relating are governed by, and interpreted in accordance with, the laws of the province of Québec and the laws of Canada applicable therein.

8.    Access to personal information

Subject to the exceptions provided for at law, individuals may access their personal information and ask that we make corrections to that information, where necessary, by writing to us at the following address:

FBA Solutions

100-30, Aberdeen Street

Saint-Lambert QC

J4P 1R4

1 877 334-3201

protection@fbasolutions.ca

We may verify the identity of a person requesting access to personal information. The information provided for purposes of such verification will not be saved or used for other purposes.

9.    Contact us

If you have any questions, comments or suggestions regarding this Policy or our practices for the protection of personal information please contact us:

FBA Solutions

1 877 334-3201

protection@fbasolutions.ca

If you believe we are not handling your confidential personal information as it is required by the law, you can file a complaint with us. We will investigate the complaint and, if it is justified, make the necessary adjustments.

If you are not satisfied with our investigation of your complaint, you can contact:

[1] Canadian Personal information Protection and Electronic Documents Act and the Québec Act Respecting the Protection of Personal Information in the Private Sector.