ReedGroup Canada Privacy Statement
Effective Date: August 10, 2021
Reed Group Canada Services ULC (hereinafter referred to as “we,” “us,” “our,” “ReedGroup”) understands that you care about how we collect, use, and share information when you interact with our websites (“Sites”), online services, applications, and business operations and services (collectively, “Services”). We value the trust you place in us. This Privacy Statement (the “Privacy Statement” or the “Statement”) explains how ReedGroup, an affiliated entity of the Guardian Life Insurance Company of America (“Guardian”) will collect, use, share, and protect information in connection with the services that refer or link to this Privacy Statement. We provide some services on behalf of our clients, and in those circumstances the client is primarily responsible for your information. For example, we may provide services to your employer, and in those circumstances, we only process information at the instruction of your employer when you interact with us in relation to our agreement with your employer. We may re-direct to your employer any inquiry about the way we use your information.
This Statement explains:
- the types of information we collect about you through our websites, online services and mobile applications (our “Sites”) as well as from third party sources and offline in connection with our Services;
- how we use and protect that information;
- the types of information we may share with others and under what circumstances;
- the rights you may have regarding your personal information and our data handling practices;
- our security practices related to your information; and
- other practices related to the handling of personal information.
A. When This Privacy Statement Applies
This Privacy Statement applies to our Sites, the use of our Services, the information we collect when you interact with us through social media, as well as to information that we collect offline (e.g., via paper or telephone call) and combine with information collected on our Sites or otherwise through the Services. It does not apply to non-ReedGroup websites and mobile applications that may link to or be linked from our Sites. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
By accessing the Sites or using the Services, you agree to be bound by this Privacy Statement. We may make changes to this Privacy Statement from time to time. We will post any changes to www.reedgroupcanada.ca/privacy–policy, and update the “Last Updated” date at the bottom of this policy, so be sure to check back periodically. Such changes will become effective when they are posted. Your continued use of our Sites and Services following the posting of any changes will mean you accept those changes.
B. Information We Collect From or About You
Below we describe the different types of information we collect from you, including from the devices you use, when you interact with our Sites and/or take advantage of our Services.
Information You Give Us: We collect and maintain personal information about you from many sources to understand and meet your needs, provide our Services, manage our business, and for other purposes disclosed to you. We collect and store any information you enter on our Sites, provide to us in written form, or communicate to us verbally. This may include:
- Personal identifiers such as your name, address, email address, social insurance number, etc.;
- Business contact information (e.g., information printed on a business card);
- Personal or physical characteristics protected by federal or provincial law, such as gender age, etc.;
- Employment information;
- Medical and health-related information
We also collect personal information that you submit to us when applying for a job via the ReedGroup website (including any CV or résumé that you upload to the website). This information will be collected and processed, where permissible by relevant, applicable law. This includes without limitation:
- Education and Professional Employment Information collected from you directly and third party sources authorized to provide additional background information about criminal history.
Absence Management and Claim Services (When we are acting as a Service Provider to Your Employer)
You may also provide personal information directly to us (by website, email, telephone, and/or mail) as a benefit plan participant for the purpose of our administration of your employer’s absence and disability management program. You may authorize us to collect information from medical providers or other third parties to obtain information to determine eligibility for a claim or absence. Your employer or service providers (such as third party administrators or payroll processors) may also provide personal information to us for the same purpose.
We may also collect information relating to your plan eligibility, such as benefit elections, claims information, benefit plan account balances or accrued benefits. In this role, we act as a service provider to your employer. As such, we use this information for the purposes of providing absence management and claim services to your employer. This information is disclosed to our service providers that assist us in providing those services to your employer, and any third parties as required or directed by your employer or applicable law. Your employer controls how we use the information provided for these purposes.
Usage Data: When you interact with our Sites, certain information is automatically collected. This information includes computer and connection information, such as statistics on your page views, traffic to and from our Sites, referral URL, advertising data, your IP address, browser type, and device identifiers. This information also may include your transaction history, and your web log information, how you search for our Sites, the websites you click on from our Sites or emails, whether and when you open our emails. We may combine this data with the aforementioned collected information, which may identify you.
A cookie is a text file sent by a web server and placed on your computer by your web browser. Cookies can be divided into two different types: session and persistent. Cookies automatically collect information when you visit our Sites, including log file information such as Internet protocol (IP) addresses, browser type, browser language, browsing history, referral URLs, pages viewed, and the date and time of a visit.
Location Information: When you interact with our Sites, we may collect information about your location and your device. Some of this information may be general, such as the province and postal code, while some of this information may be more precise, such as information associated with your mobile device or desktop computer. Most mobile devices allow you to control or disable the use of precise location services globally or per application in the device’s settings menu.
Information from Social Media and Third Party Services: When you connect to, authenticate through, or interact with us or our Sites using a social media platform (such as by clicking on a social media icon linked from our Sites) or third party service (such as a Google account), we may collect information, including personal information, available through the service or the service’s application programming interfaces (APIs). This information may include your name, account ID or username, contact details, email address(es), information related to your contacts, calendars, location information, profile picture, the contents of your posts or other communications, and other information the platform or third-party service makes available. If you choose to log in to your account with or through a social networking service or third-party service, you intentionally interact with that third party service and, by doing so, will be sharing information about yourself and your activities with that service directly or through us. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party service. You should check your privacy settings on these platforms and third party services to understand what information is made available to us, and you may be able to change the settings for these platforms or services to prevent, limit or otherwise control the information made available to us.
For job applicants, we may also collect information about you from publicly available social media profiles, such as content from external job bulletin boards.
Unless ReedGroup is prohibited by contract, ReedGroup uses the information you make available to us when you interact with our public facing websites to provide you with advertising and offers that are more relevant to you. We partner with third party advertising companies to provide advertisements on our Sites, as well as on other websites and applications about our products and services that may be of interest to you. Some of our Sites may also include advertisements for unaffiliated products and services. The advertisements you see may be based on information collected through cookies, web beacons and other tracking technologies from our Sites and on other third-party websites you visit and mobile applications you use that participate in our advertising networks. These third parties may use persistent identifiers to track your Internet usage across other websites and mobile applications in their networks beyond our Sites. While ReedGroup will not share information that personally identifies you with unaffiliated third parties for their own uses, such third parties may, with sufficient data from other sources, be able to personally identify you.
- Apple: http://support.apple.com/kb/HT4228
- Android: http://www.google.com/policies/technologies/ads/
- Windows: http://choice.microsoft.com/en–US/opt–out
Information related to Minors: ReedGroup does not knowingly collect information directly from minors—persons under the age of 13, or another age of a minor as defined by law—via our Sites or offline, other than when required to comply with the law or for safety or security reasons.
If you are a parent or guardian of a minor who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by emailing us at email@example.com.
C. How We Use Information We Collect From or About You
We may use information you give us or information we collect about you to:
- Communicate with you, including to respond to your inquiries and fulfill your requests;
- Respond to your comments and queries for our internal business purposes;
- Provide, maintain, personalize, optimize, secure and improve our Sites or Services, including research and analytics regarding use of our Sites, social media platforms and third party services, physical locations, facilities and infrastructure and to remember you when you leave and return to our Sites or facilities;
- Provide and improve our products and services, including to provide you with health-related tools, to process any transactions you request, or to authenticate your identity;
- Discuss, negotiate, and facilitate business transactions with our brokers and agent representatives;
- Deliver advertising, including interest-based advertising on our Sites, other websites and applications and other media;
- If applicable, evaluate your application for employment with ReedGroup, including to communicate with you about your application, conduct any necessary or appropriate background checks, comply with our policies, manage any aspects of your prospective, current or former employment relationship with ReedGroup and verify personal information by contacting your references;
- In connection with the establishment and defense of legal interests
- Comply with our obligations, including legal, regulatory, operational or fiscal obligations, including to report adverse events to regulators;
- Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal; and
- For all other purposes to which you have agreed.
We may combine information that you provide to us or information that we collect automatically through our Services with other information we obtain from our business records, including your use of ReedGroup products, services, websites and applications and, where applicable, your preferences and other personal characteristics. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
We may use information we collect from or about you to create aggregated or de-identified data that does not identify you. Once the data is aggregated or de-identified, we may use it for any purpose permitted by law and we may share it with third parties for their own uses.
D. How We Share Information About You
We may share your information:
- With companies who work on our behalf to help us provide and support our Sites, our products and services and our human resource functions. We require these service providers to treat all information we provide as confidential and to use it only for providing the services for which they have been engaged.
- Within the Guardian family of affiliate companies in order to service you, including for our internal management and administrative purposes.
We may use or disclose information about you if required to do so by law or on the good-faith believe that such sharing is necessary to (a) conform to applicable law or comply with legal process served on us or our Sites; (b) protect and defend our rights or property, our Sites, or our users; or (c) act to protect the personal safety of our employees and agents, other users of our Sites, or members of the public.
E. Rights You Have Regarding Our Data Handling Practices
By using our Sites or Services and/or submitting personal information to us, you are accepting and consenting to the practices and uses described in this Privacy Statement. This Privacy Statement is not a contract.
Your Rights to Request Access to and Correction of your Personal Information
Canadian residents, subject to certain exceptions, have the right to request access and correction of your Personal Information collected, used, transferred, disclosed, or processed by ReedGroup.
If you are making a request relating to information we hold relating to services we provide to your employer, you can make such a request by submitting a request to your employer.
Some of the information that we collect may not be reasonably associated with you directly. In such instances that information will not be addressed as part of your request. You can learn about aggregate information throughout this Statement.
F. How We Secure the Information We Collect From or About You
safeguards to protect the information we collect through our Sites and offline. When your personal information is shared, ReedGroup will take a reasonable approach to prevent the unauthorized use or disclosure of personal information.
While we use these precautions to safeguard your personal information, please be aware that no security measures are perfect or impenetrable. We cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf. Please use caution when submitting any personal or other sensitive information to us online.
You can learn more about how we protect your information here.
G. Other Important Information
Retaining Your Information
If required, we may also retain your Personal Information where such retention is necessary for compliance with a legal obligation to which we are subject.
Cross Border Data Transfers: We are based in Canada and our Sites and Services are directed to residents of Canada. Guardian is a US based company, and offers certain support services to ReedGroup. The information you submit to us and that we collect as a result of using our Services may be transferred to the United States or accessible by our service providers located in another jurisdiction, including India. By using our Services you consent to the collection, international transfer, storage, and processing of your information by us and our service providers.
If you use our Sites outside of Canada, you understand and consent to the transfer of information about you, and the collection, processing, and storage of information about you, in the United States and Canada. The laws in the U.S. and Canada regarding personal information may be different than the laws of your country. If it is illegal to access our Sites or transfer your data to the United States or Canada, please do not use our Services.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please visit our Accessibility page for additional information.
For Questions, or to Report a Problem
If you have other questions, comments or concerns about our privacy practices, or if you wish to issue a request to exercise your rights where applicable by law, please contact us at 1-866 572 5664 or email our Chief Privacy Officer at firstname.lastname@example.org. Please provide your name and contact information along with the request.
Alternatively, inquiries may be mailed to the following address:
Guardian Life Insurance Company of America
c/o Chief Privacy Officer
10 Hudson Yards
New York, NY 10001 USA
Last Updated: August 20, 2021