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CANADA Disclaimer  



May 31,2018
 

 

Privacy Policy

 

Protecting your privacy is important to CNA and its affiliates (collectively, "CNA"). It is important for you to understand how CNA collects, uses, discloses, retains and safeguards the information you may provide when you visit www.cna.com (the "CNA Website") and within the framework of the services offered by CNA, including but not limited to, CNA's social media platforms (collectively, the "CNA Services").

 

The CNA Privacy Policy (the "Privacy Policy") only applies to information collected through the CNA Services. For example, the Privacy Policy does not cover information you may provide to an independent CNA insurance broker outside of your use of the CNA Services. Other privacy policies, contractual provisions, or agreements you have entered into, including those with an independent CNA insurance broker, may apply depending on your relationship with CNA, your relationship with an independent CNA broker, your correspondence with other websites you visit, and your jurisdiction.

 

No information is collected from individuals who wish to browse the CNA Website without registering, except as may be contained in "cookies" (i.e. small files that are stored by your Web browser to help a particular system recognize you and the pages you visit in a Web site) as well as Other Information. For more information, please see "How CNA May Collect Other Information" below.

 

BY ACCEPTING OUR TERMS OF USE, SUPPLYING INFORMATION TO CNA AND/OR ACCESSING OR USING THE CNA SERVICES, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT USE ACCESS THE CNA WEBSITE OR USE OUR CNA SERVICES.
 

Personal Information

"Personal Information" is information that identifies you as an individual. Personal Information may include, depending on the circumstances, your name, postal address, phone number, email address, employment information, educational history, credit history, social security number, driver's license number, credit or debit card number, policy or claim information (including medical or health information you may provide), and criminal history information.

 

If you submit any Personal Information relating to other people to CNA or to CNA's service providers, you represent and warrant that you have the authority to do so and to permit CNA to use the information you provide.

 

CNA does not use Social Insurance Numbers as a way of identifying or organizing the information we hold about clients or others.
 
Why and How CNA Collects Personal Information

We collect Personal Information to:
 
underwrite polices;
 
administer claims or provide related services;
 
verify identities;
 
administer our client databases;
 
help us make credit decisions about clients;
 
detect and prevent fraud and money-laundering;
 
monitor and investigate transactions;
 
analyze business operations and results;
 
to include our clients in any direct marketing activities or other distributions of information or material that we believe may be of interest to the individual; and
 
as required or permitted by law.
 
With the individual's consent we may obtain Personal Information directly from the policyholder, the claimant/injured worker, and from third parties such as medical providers, attorneys, administrative consumer reporting agencies or index bureaus, other insurers and reinsurers, insurance brokers and adjusters, third party administrators, insurance associations, financial institutions, and government agencies and registries.

 

The type of Personal Information collected by CNA depends on a number of factors and context. CNA collects only the Personal Information necessary to provide CNA Services and to achieve the purposes set out in this Privacy Policy.

 

If we are notified that an individual no longer wishes to receive information regarding our products and services, we will not send any further material, in accordance with anti-spam legislation.
 
Consent
 
We ask clients to provide explicit consent if we collect, use, or disclose their Personal information, or rely upon the express consents obtained by the insurance brokers that represent us. Although we may ask for a consent in writing in some circumstances, in others we may accept a verbal consent. Sometimes, a consent may also be implied through conduct with us. The act of willingly providing Personal Information to CNA constitutes consent for CNA to collect, use and disclose such information in accordance with the terms and conditions of this Privacy Policy, for example you provide Personal Information when prompted to do so in the use of CNA Services or use of the CNA Website.

 

You can withdraw your consent at any time. However, if you choose to do so, CNA will not be able to effectively provide you the full range of access to our CNA Website and/or offer our CNA Services to you. Moreover, even in case of withdrawal of consent, CNA may nevertheless by law have the right or obligation to retain, use or disclose Personal Information about an individual.
 
How CNA May Use Personal Information

CNA may use Personal Information:
 
To contact or send you information you have opted-in to receive about CNA products and services.
 
To contact you at a telephone number, mobile number, postal address, or email address you provide to CNA. CNA may contact you in person, by recorded message, email, or by any other means of communication you agree to receive, as allowed by law and for reasonable business purposes.
 
To process claims you have submitted using the CNA Services.
 
To service your insurance needs.
 
To process employment applications you submit using the CNA Services.
 
To confirm or correct information you have submitted.
 
To help CNA prevent fraud and other crimes.
 
To comply with applicable laws and legal process, including responding to court, regulatory or governmental requests.
 
To personalize your experience while using the CNA Services.
 
To inform you of CNA job opportunities and to evaluate your suitability for a job.
 
To facilitate the social sharing functionality on CNA's social media platforms.
 
To enable you to participate in voluntary sweepstakes, contests and other promotions (see "Promotions, Sweepstakes, and other Promotions" below).
 
To protect CNA's privacy, property, and that of you or others.
 
As otherwise allowed or required by law.
 
How CNA May Disclose Personal Information

CNA may disclose your Personal Information:
 
Within the CNA family of companies.
 
To third parties to assist with the management and service of CNA's business and the provision of CNA Services. The third parties may include, but are not limited to, agents or brokers, claims management service providers, employment application service providers, other insurance companies, regulators, administrators, and service providers that provide services, such as website hosting, data analysis, payment processing, information technology and the provision of related infrastructure, and email delivery.
 
Occasionally we do use service providers located outside of Canada to process and/or store Personal Information for us. Please note that Personal Information in the custody of these service providers may be subject to access by the law enforcement authorities of those jurisdictions in which the service providers are located.
 
To insurance support organizations and consumer reporting agencies. Information CNA shares with such organizations, such as claim history, may be retained by those organizations and disclosed to others as needed to provide CNA Services.
 
To third parties to market their products and services to you, only if you have given CNA permission to do so.
 
By you, on message boards, chat, profile pages, blogs, and other services to which you are able to post information (including, without limitation, on CNA's social media platforms). Please note that any information you post or disclose through CNA's social media platforms or elsewhere may become public information and may be available to the general public. CNA urges you to be careful when deciding to disclose your Personal Information or any other information on the CNA Services or elsewhere.
 
To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of CNA's business, assets or stock (including in connection with any bankruptcy or similar proceedings).
 
As CNA determines necessary or appropriate: (a) under applicable law, including laws outside your country or territory of residence; (b) to comply with legal process; (c) to respond to requests from public, governmental, and regulatory authorities, including such requests initiated outside of your country or territory of residence; (d) to enforce CNA's Terms and Use; (e) to protect CNA's operations; (f) to protect CNA's rights, privacy, safety or property, and/or that of you or others; (g) to detect and prevent fraud; and (h) to allow CNA to pursue available remedies or limit damages CNA may sustain.
 
If a person is acting as your representative or if CNA reasonably believes that the person is acting pursuant to an appropriate authorization (for example as tutor, holder of parental authority, etc.), or is a person who owns a product or service jointly with you;
 
As otherwise allowed by law.
 
How CNA May Collect Other Information

CNA and its third party service providers may collect Other Information, including, but not limited to:
 
Through your browser, computer, or other device:
Certain information is collected by most browsers or automatically through your computer or device, such as your Internet protocol (IP) addresses and Internet browser type and version, as well as the date and time of the visit and the pages visited.
 
From Cookies:
A cookie is a piece of information that is stored directly on the device you are using to access the CNA Services. Cookies allow for the collection of information, including browser type, time spent using the CNA Services, pages visited, date/time stamp, clickstream data, and other anonymous traffic data. Such information is used for security purposes, to facilitate navigation, to improve the design and functionality of the CNA Services, to provide information more effectively, and to personalize your experience while using the CNA Services. Cookies also enable CNA to select which of CNA's advertisements or offers are most likely to appeal to you and display them while you are using the CNA Services. If you do not want information collected through the use of cookies, you may decline cookies or decline the transfer to your computer of cookies from a particular site. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for more information. If you set your browser to reject cookies, you may then be required to re-enter certain information each time you visit the CNA Services.
 
From you:
Information you may provide, such as your preferred means of communication, which may be collected when you voluntarily provide that information. Unless combined with Personal Information, this information does not personally identify you or other users of the CNA Services.
 
This Privacy Policy regarding Personal Information applies to Other Information, which may be considered as Personal information, with the appropriate adjustments set out below. By accessing or using the CNA Services and the CNA Website, you consent to the collection, use and disclosure of Other Information in accordance with this Privacy Policy
 
How CNA May Use and Disclose Other Information

CNA may disclose Other Information when legally required to do so. If CNA is legally required to treat Other Information as Personal Information, then CNA may use that information as described in the "How CNA May Collect Other Information" section above, as well as for the purposes disclosed in this Privacy Policy with respect to Personal Information.
 
Third Party Services and Websites

From time to time, the CNA Services may include links to third party websites. This Privacy Policy does not apply to Other Information or Personal Information you provide to third party websites. CNA is not responsible for the privacy or other practices of any third party website. The inclusion of a link on the CNA Services to a third party website does not constitute CNA's endorsement of any linked third party website or services offered thereon. Specifically, CNA is not responsible for the collection, usage, or disclosure policies and practices (including the data security practices) of any third party website, including, but not limited to, Facebook, LinkedIn, Twitter, or any other social media platform provider or operating system provider relating to Personal Information you may disclose through or in connection with any such third party website, including CNA's social media platforms.
 
Children's Privacy

The CNA Website and the CNA Services are not intended for use by individuals who are under the age of majority in their jurisdiction of residence, or for children under the age of thirteen, and CNA does not knowingly collect Personal Information from such individuals.
 
Sweepstakes, Contests, and Other Promotions

CNA may sponsor or facilitate contests, sweepstakes or other promotions (any, a "Promotion," and collectively, "Promotions") on or through the CNA Services, CNA's social media platforms, or otherwise. Participation in such Promotions is purely voluntary. In order to participate in a Promotion, you may be asked to provide certain Other Information or Personal Information. By participating in a Promotion, you agree to the Promotion's terms and conditions or official rules, including those that pertain to the collection and/or use of Other Information and Personal Information. Also, by participating in a Promotion, you acknowledge that CNA is not responsible for actions or policies of third party sponsors or prize providers relating to the use of your Other Information or Personal Information in connection with the Promotion.
 
Jurisdiction

CNA is a worldwide company that conducts business in many different countries. It is CNA's policy to comply with the privacy laws and regulations of every jurisdiction in which CNA conducts business. This Privacy Policy only applies to CNA Services offered by CNA in North America, and is not intended to subject CNA to the laws or jurisdiction of any state, province, territory, or country other than that of the United States and Canada. If you are viewing the CNA Services from outside North America, this Privacy Policy may not apply.
 
Safeguarding Personal Information

CNA uses reasonable technical and administrative measures to protect Personal Information and requires that Personal Information be stored in a way that prevents unauthorized access, use or modification. For example, hard copy documents that contain Personal Information are to be stored in files that can only be accessed by authorized CNA employees or third parties, and computers or other electronic devices that contain Personal Information are to be secured against unauthorized access, such as using a password. CNA requires that any authorized personnel who maintain Personal Information must take appropriate steps consistent with this Privacy Policy to safeguard such information. Authorized CNA employees or third parties will only have access to Personal Information on a need to know basis in the performance of their duties.

Documents or other materials (both electronic and in hard copy) that contain Personal Information are to be disposed of in a manner such that the Personal Information is erased or made unreadable at the time of disposal. We keep Personal Information as long as is reasonably necessary for us to complete our dealings with an individual, or as may be required by law, whichever is longer.

That being said, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that Personal Information you provided to CNA is no longer secure, please immediately notify CNA by contacting CNA's Security Control and Communication Center at 866-262-6244.
 
Depending on the nature of Personal Information, it may be stored in the offices of CNA or in various computer systems of CNA or its service suppliers or in storage installations of CNA or its service suppliers, in Canada or outside Canada.
 
Social Security Protection Policy Statement

CNA seeks to protect the confidentiality of social security or social insurance numbers ("SSNs" or "SINs") by maintaining physical, electronic, and procedural safeguards, and limits access to SSNs and SINs to help protect against their loss, misuse or unlawful disclosure.
 
Updates to this Privacy Policy

CNA reserves the right to change this Privacy Policy at any time in its sole discretion. The "revised" legend at the top of this web page indicates when the last revision was made. Any changes become effective upon notice thereof, which may be given by any reasonable means, including by posting a notice on the CNA Website. Your use of the CNA Services following changes to this Privacy Policy means that you accept the terms of the revised Privacy Policy.
 
Updating, Access and Correction of Personal Information

Since we use Personal Information to provide insurance products and services to brokers and customers, it is important that the information be accurate and up-to-date. If any Personal Information regarding a client changes, we ask the client or their broker to inform us promptly of the change so that we can make any necessary changes to our records.

An individual may ask for access to any Personal Information we hold about them. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to appropriate fees. An individual's rights to access his or her Personal Information are not absolute.

We may deny access to the requested information in the following situations: when the information is protected by solicitor and client privilege; when granting access would reveal Personal Information about another individual that is not severable from the requested information; where providing the requested information would reveal confidential commercial information of a third party; or when denial of access is otherwise required or authorized by law. If we deny a request for access to, or refuse a request to correct information, we shall explain why.

If CNA holds information about an individual and the individual can establish that it is not accurate, complete and up-to-date, CNA will take reasonable steps to correct it.
 
Can an Individual Request Anonymity?
 
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without an individual providing a name (for example, by accessing general information on our website).
 
Employee Training
 
CNA employees receive training regarding privacy protection requirements and measures taken by CNA to assure those requirements are met.
 
Monitoring
 
CNA monitors its privacy policies and procedures on an ongoing basis to assess risks to its privacy program as technology and the business landscape evolve. Changes are instituted accordingly.
 
Third Party Administrators and Vendors
 
CNA requires, by contractual agreement, that third party administrators and vendors who obtain and maintain CNA customer information have standards to protect that information. Licensed entities may be required by law and regulation to protect information.

Occasionally, Personal information collected by CNA may be processed or stored in other jurisdictions such as the United States and, therefore, it may be subject to access by local government and/or law enforcement authorities pursuant to the laws of those jurisdictions. Our Privacy Officer, whose contact information is provided below, can provide further information about our policies and practices regarding service providers and further information about how these service providers, collect, use, disclose or store Personal Information on CNA's behalf.
 
Employment Inquiries
 
We have elected to follow privacy "best practices" regarding our employee information. If an individual applies to CNA for employment, we need to consider their Personal Information as part of our review process. We normally retain information from employment candidates after a decision has been made, unless they ask us not to retain the information. If we offer a person a job, and they accept, the information will be retained in accordance with our privacy procedures for employee records.
 
Contact Us
 
If you want to access or correct the Personal Information that CNA has collected about you in connection with your use of the CNA Website or CNA Services, or if you have questions about this Privacy Policy, please contact:

In Canada:
Privacy Officer
CNA Canada
66 Wellington Street West, Suite 3700
Toronto, Ontario M5K 1J5
Phone: 1-416-542-7300 or 1-800-268-9399
Fax: 1-416-542-7310
Email: canadacompliance@cna.com

In the U.S.:
Contact CNA via email at: compliance@cna.com

All of our clients and brokers should know that email is not a 100% secure medium, and should be aware of this when contacting us to send personal or confidential information.

© 2018 CNA. All rights reserved.

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