Please read this document carefully, not because anything in it is difficult to understand, but because we want you to know that belairdirect protects your personal information. As you read you will come across certain specialized words, Industry Terms. We have underlined these words and provided definitions to make sure everything is perfectly clear. Simply go to the back and look under our "Industry Terms, and what they mean" box.

We view our Privacy Promise as if it were a belairdirect product, not just a legal obligation. And as you know, we believe in superior products.

When you became a belairdirect client, you shared important personal information with us. You did this so we could serve you better and knowing we would honour and respect your privacy. Your trust was not misplaced. At belairdirect we are committed to offering you superior products and services, so it should come as no surprise that we are also committed to meeting the privacy standards applicable to you.

• What is "personal information"?
  

  Let's be perfectly clear.

  "Personal information" is information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.

• What information are we responsible for protecting?
  

  belairdirect is responsible for protecting your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third party in the course of commercial activities for processing or other purposes for which you have consented.

• Collecting, using and disclosing your personal information. Why do we do it?
  

  We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your insurance and financial needs, communicate effectively with you, and provide you with the services and products you want.

  Let's be specific. We collect, use and disclose your personal information to:

  • verify your identity;
  • determine your eligibility for insurance and financial products and services offered by belairdirect and its affiliates, and for products that may be of interest to you from companies with whom we have strategic alliances*, and offering to you these products and services;
  • assess and underwrite insurance and reinsurance risks;
  • determine prices, fees and premiums;
  • investigate and settle claims;
  • detect and prevent fraud;
  • compile statistics, conduct market research, and report to regulatory and industry entities in accordance with prudent insurance practices, including claims history;
  • investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities;
  • determine the suitability of your investments;
  • comply with the law; or
  • comply with tax requirements.

  Personal information may be collected, used or disclosed for any of these "Identified Purposes" set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you.

• How do we gather your personal information?
  

  The collection, use and disclosure of your personal information depend on how you do business with us. We may gather information from the following sources:

  • from you, on applications for our insurance and investment products, or on other forms filled out through telephone, e-mail or face-to-face interviews; for example your name, add
  • ress, telephone number, e-mail address, occupation, financial and banking information, and health information;

  • from licensed agents, insurance brokers, intermediaries and financial services representatives with whom you have a relationship, as well as adjusters and inspectors;

  • from your interactions with us; for example through your payment history, underwriting and claims;

  • from government and other entities, that have information on your driving record and claims history; or

  • from consumer reporting agencies; for example your credit history.
    
    
• What you are committing to when you share personal information with us.
  

  If you provide personal information to us or through any of the previously mentioned sources, you do so with the understanding that your personal information may be used or disclosed for the Identified Purposes amongst us, the previously mentioned sources, or third parties and that belairdirect may verify such information, or obtain additional personal information about you by checking with government agencies, credit bureaus, motor vehicle agencies and other fact collecting and verifying entities to assist us for the Identified Purposes.

• Your consent.
  

  Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation, an investigation by the police, or in situations otherwise permitted by the law. If any of the personal information that we collect is sensitive, such as health information, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.

  How do you provide us with your consent?

  We accept any of the following as your consent for belairdirect's existing use and future collection, use or disclosure of your personal information for the Identified Purposes:

  • your receipt of this Personal Information Policy, unless you advise belairdirect, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it;
  • your unrestricted provision of information to belairdirect either directly or through licensed agents, insurance brokers, adjusters or financial services representatives;
  • your express written or oral consent as obtained through an application process; or
  • your consent as provided by your authorized representative, such as a legal guardian or power of attorney.

  In some circumstances, your consent may be implied.

  For instance:

  • if you obtain insurance for your family, or anyone else, you represent that you have obtained consent from them, even though they might not be present during the application process, to the collection, use and disclosure of their personal information for the Identified Purposes;
  • if you have an existing insurance policy with us and you request amendments to the policy, it is assumed that the consent which you gave to us when buying the original insurance policy remains in effect.

  You have the power to say no.

  How you can withdraw your consent.

  You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.

  To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed. 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 Policy for the Identified Purposes.

• How long do we keep your personal information?
  

  Your personal information is retained only as long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. belairdirect shall use care when storing or destroying your personal information in order to prevent unauthorized access.

• How do we protect your personal information?
  

  Whether in electronic or paper-based format, belairdirect maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information, we take as much care to destroy it as we do when storing it.

  In the event that we transfer your personal information to a third party for processing (for example, when printing cheques, managing claims and client statements, or for data processing), we contractually require any person or organization providing products or services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.

• Your right to access your personal information.
  

  You have a right to access your personal information that we have in our possession or control. You also have a right to know which third parties have received your information from belairdirect.

• How do you access your personal information?
  

  Please make your request in writing to belairdirect's Privacy Officer, stating as specifically as possible which personal information you are requesting.

  We will try to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. belairdirect 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 whom 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, belairdirect shall provide a list of organizations to which we may have disclosed the information.

  belairdirect has the right to refuse your request for access to personal information if:

  • 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.

  
  
• Keeping your information accurate.
  

  A priority.

  belairdirect strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. belairdirect shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavour to advise other parties having access to the information in question.

• If you have a complaint, we want to know about it.
  

  If you have a complaint related to the Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Policy and practices, if necessary.

  If we are not able to resolve your concern, or if you have any other concerns about belairdirect's Personal Information Policy and procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial Privacy Commissioner. belairdirect's Privacy Officer will provide you with this contact information upon request.

• Industry terms, and what they mean.
  

  adjuster.... A representative of an insurance company who is licensed to investigate claims which are submitted and to negotiate the amount of the settlement, if any.
  

  power of attorney.... The authority given to one person or corporation to act on behalf of another person or corporation in legal and financial matters.

  reinsurance risks.... Reinsurance is when an insurance company places all or part of the insurance with another insurance company, who will then be responsible for a percentage of the risk or loss. This does not affect you in any way.

  third party.... Person other than you who is involved in a transaction.

  underwrite.... To estimate the value and determine at what amount and on what terms the insurance company will provide insurance. Underwrite is another way of saying insure.

• About this document.
  

  This Personal Information spells out the responsibility of belairdirect and its affiliates ("BELAIR", "we", "our", "us"), and your rights as our applicant, customer, former customer or claimant ("you" or "your"), regarding the collection, use and disclosure of your personal information. belairdirect means BELAIR Insurance Company Inc., and the Nordic Insurance Company of Canada and includes its affiliates:

  ING Canada Inc., ING Canada Holdings Inc., Insurance Company of Canada, ING Wealth Management Inc., ING Insurance Services Inc., ING Investment Management, Inc., Equisure Financial Network Inc. and its broker subsidiaries, and Wellington Warranty Company Inc.

  This Personal Information Policy is subject to any amendments, which will be posted on belairdirect's Web site and will also be available from belairdirect's Privacy Officer by calling 1 866.941.5094.

  La version française de cette Politique relative aux renseignements personnels est disponible sur demande.

How to contact us. Easy.

Updated versions of this Personal Information Policy are posted on belairdirect's Web site at www.belairdirect.com, or you can direct any queries about this Policy to belairdirect's Privacy Officer at the telephone, e-mail address, or mailing address listed below.

For more information, to file a complaint, to make inquiries, or to opt out of all or parts of this Policy, please contact belairdirect's Privacy Officer:

belairdirect PRIVACY OFFICER
700 University Avenue, Suite 1100
Toronto, Ontario M5G 0A2
Telephone No. 1 866.941.5094
Fax No. 416.941.5322

E-mail address privacy@belairdirect.com

Web site www.belairdirect.com

*Our Strategic Alliances