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PRIVACY STATEMENT

This privacy statement (this “Statement”) describes the practices of Sirius Benefits, a People Corporation company (“PC”, “we”, “us”, “our”) with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct and access your personal information provided to us from you as a user of (a) the website (the “Portal”) (b) any front-end software provided by us (the “Software”) and (c) the services we provide through the Software (the “Service”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. We also govern our activities in accordance with PC’s corporate Privacy Policy which can be found on our website at www.peoplecorporation.com. We encourage you to review both this Statement as well as our Privacy Policy.

  1. Introduction and General Concepts

We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information. In keeping with that goal, we have developed this Statement to explain our practices for processing your personal information.

  1. Personal Information

For the purposes of this Statement, “personal information” means any information about an identifiable individual, including but not limited to an individual’s name, home address, telephone number, gender, but excludes any business contact information that is processed solely for the purpose of communicating with that person in relation to their employment or profession, any information that is anonymous or unidentifiable such as web browsing information or aggregate information, and any other information otherwise exempted pursuant to the applicable laws of Canada and other applicable jurisdictions.
We will only process your personal information in accordance with this Statement, applicable laws and our ordinary business practices.

  1. Information about Minors

The Portal, Software, and Service is intended solely for the Covered Individuals, their Covered Spouses and Minor Dependents (each as defined in the Terms of Use). When Covered Individuals provide access to the Portal, Software, and Service to their Minor Dependents, Covered Individuals acknowledge that they hereby consent and are deemed to have consented on behalf of their Minor Dependents to the collection, use, and disclosure of such Minor Dependent’s personal information in accordance with this Statement to the extent such Minor Dependent is not able to provide such consent.

  1. Privacy Officer

We have appointed a Privacy Officer who is responsible for our compliance with this Statement. Information on how to contact the Privacy Officer can be found below.

  1. Other Websites

Our Portal, Software or Service may contain links or direct you to other third party’s websites, software, service providers or Internet resources (the “Other Providers”) that may interact with the Portal, Software or Service which are provided for your convenience, benefit and information. When you access any Other Provider, you are contacting another website, software, service provider or Internet resource we have no responsibility or liability for, or control over, those Other Providers or their processing of your personal information. We encourage you to read the privacy policies of the Other Providers to learn how they process personal information.

  1. Collection of Personal Information

When you use our Portal, Software or Service, we may collect the following personal information from you and/or your employer:

  • name, date of birth, social insurance number, gender, marital status
  • contact information such as email/mailing address, phone number
  • employment information including salary, leaves of absence, alternate work arrangements
  • banking information for delivery of benefit services
  • health, medical or lifestyle information related to your benefits.

 We also collect information about your dependants and beneficiaries including their name and date of birth with the understanding that you have been authorized to provide this information to us.

 To ensure our Portal, Software or Service is optimized for your use and for future communications between us and you, we or our service provider (s) may save your user data in the form of cookies and use such cookies to collect standard Internet log information about how and when you use our Portal, Software or Service. This information may include but not be limited to, your IP address and location data, weblogs, time, date, your language preferences, browser used, referring web addresses, other communication data, searches conducted, pages visited. You can manage your cookie preferences, but please note that if you refuse to allow cookies certain features of our Portal, Software or Service may not be available for your use.

  1. Use and Disclosure of Personal Information

We may use and disclose your personal information for the following purposes as part of our Service through the Portal or Software (the “Purposes”):

  1. Verify your eligibility for benefits and authenticate your identity.
  2. Enrol you and your dependants in selected benefit programs, provide ongoing benefit administration and customer service, adjudicate and process claims, and monitor for fraudulent claims activity.
  3. Exchange information with insurance carriers, trust companies, actuaries, auditors, and benefit providers as well as other third parties involved in delivering benefit services (e.g., claims processors, benefit card providers, technology providers).
  4. Communicate with you to provide you services, contacts, and materials or your needs through phone, email, or the Portal.
  5. Perform research and analysis using aggregated and anonymous data to provide your Trust with plan utilization and comparisons against industry metrics with the aim of improving your benefit program.
  6. Respond to your requests for assistance, or to resolve any technical issues you may encounter.
  7. Ensure that the Portal, Software or Service is optimized for your use.
  8. As otherwise required or permitted by law.

 

We will only process personal information provided to us for the Purpose(s) outlined above. Otherwise, we will not process your personal information without your consent.

  1. Your Consent

We will process your personal information only with your knowledge and consent, except where required or permitted by applicable laws. By using our Portal, Software, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Statement and as may be further identified at the time of collection.

If you do not consent to the processing of your personal information in accordance with this Statement, please do not provide any personal information to us.

You may notify us at any time that you wish to withdraw or change your consent to our processing of your personal information, subject to legal restrictions and reasonable notice by deleting your account within the Portal, Software or Service and stopping use of the Portal, Software or Service. However, upon your withdrawal or change to your consent, we may not be able to provide you with access to the Portal, Software, or Service.

  1. Security of Personal Information

The security of your personal information is important to us. We follow and employ generally accepted industry standards as appropriate to the sensitivity of your personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual, and technological safeguards to protect personal information, and insist that our service providers do the same. We require that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then, only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so we cannot guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

  1. Requests for Access to and Correction of Personal Information

Applicable Privacy Laws allow, to varying degrees, individuals the right to access, and request the correction of errors or omissions in, personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:

  • identification of personal information under our custody or control;
  • information about how personal information under our control may be or has been used by us; and
  • the names of any individuals and organizations to which the individual’s personal information has been disclosed.

We will respond to requests within the time allowed by applicable privacy laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

  1. Retention of Your Information

We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.

  1. Location of Data

Your personal information collected by us will be processed and stored in Canada. Some of our technology providers may be accessing technology from outside of Canada.

  1. Contact Information of Privacy Officer

You can direct any questions or concerns regarding our compliance with this Statement to our Privacy Officer by emailing at privacy.officer@peoplecorporation.com.

If you are not satisfied with our Privacy Officer’s response to their question or concern you may be able to make a complaint under applicable privacy laws. Our Privacy Officer can provide you with the contact information to make such a complaint.

Privacy Officer
People Corporation
1403 Kenaston Blvd
Winnipeg MB R3P 2T5
Email: privacy.officer@peoplecorporation.com

  1. Changes to Privacy Statement

Privacy laws continue to evolve and, as a result, this Statement may be changed by us from time to time at our full discretion without any prior notice or liability to you or any other person. The processing of your personal information by us will be governed by the version of this Statement in effect at that time.

Privacy Statement Last Updated June 11, 2024

© 2021 Avantages Sirius (une société People Corporation)