Privacy Policy

In this Privacy Policy, "personal information" means any information that is related to an identifiable individual, or as otherwise defined under applicable privacy law.

Depending on your relationship with us, we collect personal information as follows:

Personal information you provide directly to us

We collect personal information from you directly when you apply for benefits and services, when you make changes to your account or policy, when you submit a claim, when you contact or communicate with us online or by phone and when managing our business relationship with you. The categories of personal information we may collect from you directly include the following.

• Contact information such as your name, address, telephone number(s), or email address.
• Demographic information such as your birth date and gender or other identifying information.
• Financial information such as your annual income, details related to your net worth, details relating to your current insurance coverage, and your place of employment.
• Medical information such as diagnoses, medications, treatments, paramedical results. This may also include information about members of your extended family.
• Lifestyle information such as your habits, hobbies, driving history and travel plans.
• Beneficiary information such as your spouse’s, children’s or dependents’ names, ages and contact information, when applying for life insurance coverage.
• Payment Information including cardholder name and card details.

Information you provide when you contact us

If you reach out to a customer service agent or advisor you may be asked for information to confirm your identity (such as your name, address, or a phone number), along with additional information we need to help us promptly answer your question or respond to your comment or complaint.

Personal information we collect automatically

Log Data and Usage Information

We collect information that is generated through your actions when you use the Website, such as your transactions, interactions with our Products, your preferences or statistics regarding your use of our services.

We collect and log the IP (Internet protocol) addresses of all visitors to the Websites and other related information such as:

• The browser and device you are using, which is provided by your browser and device
  
• The address of the site you came from, which is provided by your browser
  
• The date and time of your visit to the Website
  
• The pages you visit within the Website
  
• The number of times you visit the Website
  
• How long you stay on the Website and at what point you exit
  

Cookies

We use cookies and similar technologies on the pages on our Website where you are prompted to log in or that are customizable. We may use this information to:

• Identify your browser in order to verify your identity when accessing your account information
  
• Allow us and our service providers to personalize the Website or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience
  

We may use third parties such as ad exchanges and data companies to serve our advertisements on our Website or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our apps, the Website and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver tailored advertising, both on and off our Website.

How you can control tracking

Most browsers are initially set to accept cookies and other tracking technologies (referred to herein collectively as “cookies”). You can also set your browser to disable cookies or to inform you when they are set. You also have the ability to delete cookies that you have accepted.

You can control web analytics activity by setting your browser to notify you when a cookie is sent and block analytics cookies if desired. Please consult your browser's Help Menu for instructions.

Please note that, if you delete or disable cookies, you may not be able to take full advantage of features within our Website.

Analytics

We may use third parties, including Google Analytics and Mixpanel, to help us gather and analyze information about the areas visited on the Website in order to better understand, evaluate and improve the user experience and the convenience of the Website.

Personal information we collect from other sources

We may also collect personal information about you from other sources, including:

• Your authorized representatives
  
• Health care services and practitioners, such as Dynacare
  
• Credit reporting agencies
  
• Medical Information Bureau (“MIB”)
  
• Service partners, such as referral partners that direct you to our Website
  
• Other insurance companies who you have authorized to share recent application information with us
  
• Other third parties who you have authorized to share information with us.
  

Depending on the type of services we are providing and your relationship with us, your personal information may be collected and used for the following purposes:

• Providing the Services, including establishing and maintaining your user profile, providing recommendations, underwriting your insurance applications, and administering claims and coverage
  
• Approving your coverage. We make use of an automated decision-making tool for evaluating the underwriting risk of insurance applications. Based on your application responses, the application may be automatically approved, declined, or transferred to a third-party professional underwriter for a manual review. Anyone seeking more information about this tool is encouraged to contact us
  
• Communicating with you about the Services, including by sending related announcements, updates, security alerts, and support and administrative messages
  
• Confirming your identity and verifying the accuracy of information
  
• Complying with legal requirements, such as provincial and federal tax reporting, financial audits and anti-money laundering verifications
  
• Understanding your preferences for engaging with us (e.g. via email, telephone, etc.) and determining if there are other suitable products or services you might be interested in and sending you details about them. You can ask to be removed from our marketing lists at any time.
  
• Understanding our customer base, and tailoring and targeting our advertising and marketing campaigns.
  
• Analyzing and improving the Services and developing new Products and Services. For example, we may process your personal information through our own or third-party artificial intelligence (“AI”) tools and may use your personal information to train and develop AI models and for other machine-learning purposes (including for purposes of marketing, sales outreach, content generation, customer communications, underwriting efficiency, and predictive modeling). We may also use your personal information to analyze your usage of the Services and to help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails.
  

We may also use your personal information for other purposes that you have consented to or for other purposes that are authorized by law. For example, we may use your personal information for:

• Protecting you and us from errors, misrepresentations, fraud and/or contravention of laws or criminal activity
  
• Fulfilling contractual obligations imposed by service/program providers
  
• Helping us make decisions to improve the Products and Services we offer
  

If you provide your personal information over the phone, the call might be recorded or monitored and your personal information is collected and used to: establish a record of the information you provide; take or verify instructions from you; and confirm your identity. Your call recordings will also be used to maintain quality service levels and help with staff training. If you don’t want your calls recorded, you can communicate with us in writing instead. You can also request that we respond to you in writing only.

With some exceptions, we require your consent to collect, use and disclose your personal information. Exceptions are determined by law and can include legal, medical or security reasons that make receiving your consent impossible or impractical such as fraud prevention and detection or assessing or improving security measures.

Your consent may be given in writing, verbally, electronically or through authorized representatives. It may also be implied, in certain circumstances. For example, if you provide us with payment card information to process your premium, it’s implied that you give us consent to use that information to process the payment.

You may withhold or withdraw your consent for us to collect, use or disclose your personal information if there are no legal or contractual requirements that prevent it. Please note that by withdrawing your consent, we will not be able to provide you with certain products or services that may be useful to you and/or your dependents.

For information of how to withdraw your consent, please consult the “Contact Us” section below.

Depending on the product or service, we disclose your personal information for the purposes we collected it or for another purpose to which you have consented, or which is permitted or required by law.

We may disclose your personal information to:

• Authorized employees, agents, and representatives who need the information to complete their duties for us
  
• Other Canadian Blue Cross organizations, to administer assistance and improve the customer service experience, and where your consent is obtained, for marketing purposes
  
• Any person or organization you give consent to
  
• People, organizations, and investigative bodies who work to prevent, detect, or investigate suspected fraud, breaches of agreement, or contravention of the law
  
• Other people or organizations who are legally authorized to view your personal information
  
• Service providers who need this information to perform their services for us. We use service providers for various purposes, including but not limited to printing, mail distribution, marketing and advertising, information technology (IT), data storage, administration, investigation, identification verification, reinsurance, and paramedical services
  
• We may also ask you to authorize Blue Cross Life or its reinsurers, to make a brief report of your personal health information to the MIB
  

In connection with the disclosures to parties described above, your personal information may be transferred, processed or stored in other provinces or jurisdictions than where it was collected. These parties may be subject to the laws of those provinces or jurisdictions. If you are a Quebec resident, this means your personal information may be disclosed or transferred outside Quebec including to service providers outside of Quebec.

Joint applications

By submitting a joint application, you give us permission to disclose or communicate details related to your application with your joint applicant. You are allowing us to communicate personal information such as the status of your application or policy, information disclosed as part of the application, results of any associated follow up requirements, your billing details, etc. It does not provide authority for your joint applicant to make changes to your policy on your behalf such as changing your beneficiaries or cancelling the policy.

Testimonials and reviews

If you provide us with a testimonial, we may post it on our Website or in other materials and media, along with your name (as needed). If you want your testimonial removed, please contact us at the contact information below.

We keep your information for one of the following time periods, whichever is longer:

• As long as we are required by law and guidelines set for the financial services industry
  
• As long as we need to for managing the products and services we provide you
  

The types of products and services we offer may require us to keep your information for extended periods of time. Personal information that is no longer required is destroyed, deleted, or, where permitted by law, made anonymous.

Our information security has been designed to protect your personal information from unauthorized disclosure, access and use. Physical, organizational and technological safeguards are in place to protect this information, based on its nature and sensitivity.

All of our employees who may access personal information – including full, part-time and contract employees – must follow our corporate privacy policies, as a condition of their employment.

We do not knowingly collect personal information from minors. If you are a parent or guardian and you are aware that your minor has provided us with personal information, please contact us. If we become aware that we have collected personal information from minors without verification of parental consent, we will take steps to remove that information from our servers.

Rights of access

You may submit a written request at any time to Blue Cross Life’ Chief Privacy Officer to obtain a copy of your personal information we hold about you. We will also inform you, upon written request, of any of the following information:

• the existence and nature of any personal information we hold about you, the purposes for which we collected it, how we collected it, or the sources of the personal information
  
• the names of the individuals or categories of third parties with whom it is necessary for us to communicate your personal information
  
• the categories of employees who have access to the information
  
• the length of time your personal information will be kept
  

Any personal information you request will be provided in writing, with certain exceptions allowed by law. Please understand that, depending on specific circumstances, we might not be able to provide all of the information you request. We may also require you to pay reasonable costs associated with providing you with such information. You will be notified of any such cost after your request is evaluated.

Right to Unsubscribe

You may unsubscribe from all marketing messages at any time. Marketing messages will contain a link to unsubscribe or you can reach out to us via the contact information provided below.

Right of correction

We strive to ensure that any personal information we collect, use or disclose is as accurate, complete and up to date as possible in order to meet the needs for which it is used. We encourage you to access your account online to update your personal information. You may also contact us if your information needs to be updated, allowing us to best meet your needs in the future.

If you believe that your personal information is inaccurate, incomplete or ambiguous you can request that we correct the information. If you believe that the collection, disclosure or retention of your personal information is not authorized by law, you may ask us to rectify the matter.

We will require that you prove your identity before we process your request for access to, or correction of your personal information. A request will also be considered if it is made by a person acting as the representative, heir or successor of the person concerned, liquidator of the estate, beneficiary of life insurance or death benefit, or holder of parental authority. In all cases, this person will have to establish their capacity and identity. Such requests must be made in writing.

We will respond to your access or correction request within 30 days of the date of receipt.

Please contact us by email at service@life.bluecross.ca or phone at +1 (866) 316 4458 to make an access, unsubscribe, or correction request.

If you have any questions, concerns or complaints about our privacy policies or practices or wish to exercise your rights under applicable privacy law, please contact us.

You may submit a written request to Blue Cross Life’s Chief Privacy Officer on any aspect of our personal information governance and procedures, including:

• Questions about our privacy policies and practices and/or to obtain additional information
  
• To exercise your rights (including the right of access to and correction of your personal information and the right to withdraw consent), as described in this Privacy Policy
  
• To voice a concern or make a privacy-related complaint. We have established an internal privacy complaint review process. We will investigate all complaints and we endeavor to respond to all privacy-related complaints and address any concerns as quickly and thoroughly as possible. If a complaint is found to be justified, we will take appropriate measures to correct the situation
  

Please address your matter in writing to:

Chief Privacy Officer
Blue Cross Life
644 Main Street
PO Box 220
Moncton, NB E1C 8L3
Email: privacy@bluecrosslife.ca

In this Privacy Statement, "personal information" means any information that is related to an identifiable individual, or as otherwise defined under applicable privacy law.

Depending on the type of services we are providing and your relationship with us, we collect personal information as follows:

Personal information you provide directly to us

We collect personal information from you directly when you apply for benefits and services, when coverage is issued or administered, when premiums are collected, when claims are submitted for payment, when you contact or communicate with us online, by phone or in person and when managing our business relationship with you. The categories of personal information we may collect from you directly include:

• Contact information such as your name, address, telephone number(s), email address;
• Demographic information such as your birth date and gender or other identifying information;
• Identification information such as your member ID number, certificate number, policy number, username and password;

• Financial information such as premium, billing and payment information, banking information, payment card information, employment information and, where required, income information or social insurance number (SIN);
• Medical and claims information such as diagnoses, medications, treatments, paramedical results, claims information and information about products or services prescribed or received;

• Beneficiary and relationship information such as the name, contact information and relationship of beneficiaries, dependents or other covered individuals;
• Group, sponsor or eligibility information such as employer, association, sponsor, distributor, coverage selection and eligibility information; and
• Business contact information such as name, company/provider name, business address, business email address, and business phone number if you are an individual or employee of a business that interacts with Blue Cross.

Information we collect automatically

Depending on the device you use or the method you use to interact with us, we may automatically collect digital information about your device, your location and your use of our site. Our websites or digital tools may also use technologies that identify, locate or profile you where permitted by law and with the notices and choices required by law. Please see our Online Privacy Statement for more information about how we collect, store and use information electronically, including through our websites and our mobile apps.

Personal information we collect from other sources

We may also collect personal information about you from other sources, including:

• Your employer, association, sponsor, group policyholder, distributor, broker, advisor, administrator or authorized representative;
• Health care practitioners;
• Other insurance companies, administrators or reinsurers when coordinating, administering or confirming coverage or the payment of benefits;
• The policyholder, certificate holder, claimant, payor, beneficiary or any other person with authority under the coverage;
• The prior insurer, administrator, distributor, sponsor or service provider in connection with acquired, transferred or rebranded coverage; and
• Other third parties you allow to share information with us, or from whom we are permitted by law to collect information.
  

Depending on the type of services we are providing and your relationship with us, your personal information may be collected and used for the following purposes:

• Evaluating applications, determining eligibility, underwriting and administering our products and services;
• Issuing, servicing, transferring and managing coverage;
• Collecting premiums, processing payments and maintaining billing records;
• Processing, adjudicating and paying claims;
• Confirming your identity and verifying the accuracy of information;
• Complying with legal requirements, such as provincial and federal tax reporting, financial audits and anti-money laundering verifications;
• Understanding your preferences for engaging with us (e.g. via email, telephone, etc.); and
• Helping us make decisions to improve the products and services we offer.

We may use your contact information to tell you about products or services that may be of interest to you, where permitted by law. We will not use sensitive medical or claims information for marketing without your express consent. You can ask to be removed from our marketing lists at any time.

We may also use your personal information for other purposes that you have consented to or for other purposes that are authorized by law. For example, we may use your personal information for:

• Protecting you and us from errors, misrepresentations, fraud and/or contravention of laws or criminal activity;
• Fulfilling contractual obligations imposed by service/program providers; and
• Transitioning, administering and servicing acquired, transferred or rebranded coverage.

We may use automated tools to support certain processes, including eligibility, underwriting, fraud prevention, claims administration and service routing. These tools are intended to assist us and may not be used for all products or decisions. Where a decision is based exclusively on automated processing and applicable law requires it, we will tell you and provide the information and rights required by law, including any right to submit observations or request review by a person.

If you provide your personal information over the phone, the call might be recorded or monitored and your personal information is collected and used to: establish a record of the information you provide; take or verify instructions from you; and confirm your identity. Your call recordings will also be used to maintain quality service levels and help with staff training. If you do not want your calls recorded, you can communicate with us in writing instead. You can also request that we respond to you in writing only.

With some exceptions, we require your consent to collect, use and disclose your personal information. Exceptions are determined by law and can include legal, medical or security reasons that make receiving your consent impossible or impractical such as fraud prevention and detection or assessing or improving security measures.

Your consent may be given in writing, verbally, electronically or through authorized representatives. It may also be implied, in certain circumstances. For example, if you submit a claim or authorize a health care provider, broker, advisor, administrator, sponsor or representative to submit information to us, it is implied that you consent to that person or organization providing your personal information to us for the purpose of administering your coverage or processing the claim.

You may withhold or withdraw your consent for us to collect, use or disclose your personal information if there are no legal or contractual requirements that prevent it. Please note that by withdrawing your consent, we may not be able to provide you with certain products or services that may be useful to you and/or other individuals covered under the policy or certificate.

For information about how to withdraw your consent, please contact us using the information provided below.

Depending on the product or service, we disclose your personal information for the purposes we collected it or for another purpose to which you have consented or which is permitted or required by law.

We may disclose your personal information to:

• Authorized employees, agents, representatives, administrators, distributors, brokers and advisors who need the information to complete their duties for us;
• Other Canadian Blue Cross organizations so that they may better understand the benefits and services that you may find useful, improve your customer service experience, and, where permitted by law, market other products and services to you;
• Any person or organization you give consent to;
• People, organizations, and investigative bodies who work to prevent, detect, or investigate suspected fraud, breaches of agreement, or contravention of the law;
• Other people or organizations who are legally authorized to view your personal information;
• Service providers who need this information to perform their services for us. We use service providers for various purposes, including printing, mail distribution, information technology (IT), data storage, administration, payment processing, investigation, reinsurance, paramedical services and claims support;
• The policyholder, certificate holder, claimant, payor, beneficiary, authorized representative or other person, where appropriate for administering coverage or processing claims; and
• The prior insurer, administrator, distributor, sponsor or service provider in connection with transitioning, administering or servicing acquired, transferred or rebranded coverage.

In connection with the disclosures to parties described above, your personal information may be transferred, processed or stored in a province or territory of Canada other than where it was collected. We do not process or store personal information for these products outside Canada. If you are a Quebec resident, this means your personal information may be disclosed or transferred outside Quebec, but within Canada, including to service providers in another Canadian province or territory.

When we share personal information with our service providers, we ensure by contractual means that they protect it in ways that are consistent with our privacy policies and practices.

We do not sell your personal information.

We keep your information for one of the following time periods, whichever is longer:

• As long as we are required by law and guidelines set for the financial services industry; and
• As long as we need to for managing the products and services we provide you.

The types of products and services we offer may require us to keep your information for extended periods of time. Personal information that is no longer required is destroyed, deleted, or, where permitted by law, made anonymous.

Our information security has been designed to protect your personal information from unauthorized disclosure, access and use. Physical, organizational and technological safeguards are in place to protect this information, based on its nature and sensitivity.

All of our employees who may access personal information, including full-time, part-time and contract employees, receive privacy training, sign confidentiality agreements and must follow our corporate privacy policies, as a condition of their employment.

Rights of access and portability

You may submit a written request at any time to Blue Cross Life’s Chief Privacy Officer to obtain a copy of your personal information we hold about you. We will also inform you, upon written request, of any of the following information:

• the existence and nature of any personal information we hold about you, the purposes for which we collected it, how we collected it, or the sources of the personal information;
• the names of the individuals or categories of third parties with whom it is necessary for us to communicate your personal information;
• the categories of employees who have access to the information; and the length of time your personal information will be kept.

Any personal information you request will be provided in writing, with certain exceptions allowed by law. Please understand that, depending on specific circumstances, we might not be able to provide all of the information you request. We may also require you to pay reasonable costs associated with providing you with such information.

You will be notified of any such cost after your request is evaluated.

Where applicable under privacy law, you may also request that computerized personal information collected from you be communicated to you in a structured, commonly used technological format.

Right of correction

We strive to ensure that any personal information we collect, use or disclose is as accurate and up-to-date as possible in order to meet the needs for which it is used. We encourage you to access your account online, where available, to update your personal information. You may also contact us if your information needs to be updated, allowing us to best meet your needs in the future.

If you believe that your personal information is inaccurate, incomplete or ambiguous you can request that we correct the information. If you believe that the collection, disclosure or retention of your personal information is not authorized by law, you may ask us to rectify the matter.

We will require that you prove your identity before we process your request for access to, correction of, or portability of your personal information. A request will also be considered if it is made by a person acting as the representative, heir or successor of the person concerned, liquidator of the estate, beneficiary of life insurance or death benefit, or holder of parental authority. In all cases, this person will have to establish their capacity and identity. Such requests must be made in writing.

We will respond to your access or correction request within 30 days of the date of receipt.

Please contact Blue Cross Life’s Chief Privacy Officer at the mailing address or email address provided below to make an access, correction or portability request.

If you have any questions, concerns or complaints about our privacy policies or practices or wish to exercise your rights under applicable privacy law, please contact us.

You may submit a written request to Blue Cross Life’s Chief Privacy Officer on any aspect of our personal information governance and procedures, including:

• Questions about our privacy policies and practices and/or to obtain additional information;
• To exercise your rights (including the right of access to and correction of your personal information, the right to data portability where applicable, and the right to withdraw consent), as described in this Privacy Statement; or
• To voice a concern or make a privacy-related complaint. We have established an internal privacy complaint review process. We will investigate all complaints and we endeavour to respond to all privacy-related complaints and address any concerns as quickly and thoroughly as possible. If a complaint is found to be justified, we will take appropriate measures to correct the situation.

Please address your matter in writing to:

Chief Privacy Officer
Blue Cross Life
644 Main Street
PO Box 220
Moncton, NB E1C 8L3

E-mail: privacy@bluecrosslife.ca

If your privacy concern has not been addressed to your satisfaction, you may file a formal complaint with the Office of the Privacy Commissioner of Canada, who oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), or to any other applicable privacy regulatory body.

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec K1A 1H3
Toll-free: 1-800-282-1376
Phone: 819-994-5444
Fax: 819-994-5424

Website: www.priv.gc.ca‍