Privacy | FCT

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1. About this privacy policy

FCT Insurance Company Ltd. (“FCTICL”, “we”, “our” or “us”) is committed to protecting the privacy and confidentiality of personal information in our custody and control.

This policy applies to personal information under FCTICL’s control, including personal information collected through FCTICL’s digital and online services and the website located at www.fct.ca (the “Website”). This policy describes how we collect, use, and disclose personal information. It also outlines how we protect and retain your personal information and the rights and choices you have regarding your personal information. If you have any questions about how we handle your personal information, please contact us using the information below.

2. What information do we collect?

Our products and services include residential and commercial title insurance services, which includes lending related solutions, residential mortgage processing and valuation solutions for lenders, and default and recovery solutions.

The types of personal information we collect depends on various factors, such as the type of products or services you request or use from FCTICL, the FCTICL group with which you interact, and any applicable legal and regulatory obligations. For instance, as described in greater detail below, in some instances your personal information may also be under the control of our affiliate company, First Canadian Title Company Limited. (“FCTCL”). FCTICL and FCTCL collect personal information for purposes related to our business.

Depending on the circumstances, FCTICL collects the following categories of personal information:

Category	Types of personal information	Purpose for use	Applicable FCTICL business lines
Contact information	Name, address, telephone number, fax number, email address, law firm name, law firm type, business address, licensing information.	To manage our relationship with you and our customers, such as legal professionals, lending professionals, real estate professionals, recovery professionals, and valuation professionals To communicate with you, including where you have consented to receive marketing messages from FCTICL To communicate where applicable with your legal counsel or lender For valuation and underwriting purposes To verify your identity to grant access to certain of our products and services To detect and prevent fraud For employment purposes To process payments to us, or collect payments for other customers or partners	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Marketing Sales Customer Experience Human Resources Legal Data and Analytics
Demographic information	Date of birth, marital status.	To verify your identity to grant access to certain of our products and services To detect and prevent fraud To prepare documents for registration on your behalf To request your feedback on our products and services so we can consistently meet and exceed your expectations For employment purposes	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Human Resources Data and Analytics
Identity information	Government-issued identification such as social insurance number, passport number, citizenship, or drivers’ licence number which is collected through photos, images, videos, graphics, written content, audio files, code, information, or data uploaded to the software service or similar information generated, stored, displayed, or transmitted through account, information collected from third-party service providers that are used to verify identity (such as information about another party’s verification of identity)	To establish and verify your identity to grant access to certain of our products and services To detect and prevent fraud For employment purposes	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Data and Analytics Human Resources
Location information	Information obtained automatically from use of our Website or from a credit report or from a third party hired to assist creditors with asset retrieval	To establish and verify your identity to grant access to certain of our products and services or to consent to a background check for employment purposes To provide services to creditors, subject to applicable legal requirements To detect and prevent fraud	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Human Resources Data and Analytics
Property information	Address, property type, occupancy type, use, characteristics, declared value, other documentation relating to the ownership of the property	For valuation and underwriting purposes To investigate any potential or actual claims To detect and prevent fraud	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Data and Analytics
Property transaction information	Property purchase price, search and off-title matters, agreement of purchase and sale, power of attorney information, MLS listing, inspection report, lawyer’s file information including reporting letter, statement of adjustments, parcel register.	For valuation and underwriting purposes To investigate any potential or actual claims To detect and prevent fraud	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Data and Analytics
Financial information	Assets and liabilities, details about payment or credit history, credit score, information relating to your loan, including the amount, purpose, and priority of the loan, information about financial commitments with other parties, and other financial account information relevant to the services we provide to an individual, their lender, or their lawyer.	To provide credit management, estate administration or debtor services For valuation and underwriting purposes To investigate any potential or actual claims To detect and prevent fraud For employment purposes	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Data and Analytics Human Resources
Mortgage information	Lender information, loan amount, rank of charge, purchase, refinance.	For valuation and underwriting purposes To investigate any potential or actual claims To detect and prevent fraud	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Data and Analytics
Insurance claim information	Any relevant correspondence or pleadings between any parties, any other information legitimately required for investigating a claim	For valuation and underwriting purposes To investigate any potential or actual claims	Residential and Commercial Title Insurance Solutions Data and Analytics
Payment information	Banking information, credit card information	To process payments to us, or collect payments for other customers or partners For employment purposes	Residential and Commercial Title Insurance Solutions Mortgage Processing and Valuation Solutions Human Resources Finance
Job candidate information	Information provided in the application	To facilitate recruitment activities To process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.	All business lines
Information collected automatically through digital and online services	FCTICL’s digital and online services may collect certain information automatically including through cookies and other tracking technologies (see Information Collected Automatically section below).	To provide services you request from FCTICL To help us understand our relationship with you To detect and prevent fraud	All business lines
Information about the product and services you have with FCTICL	Information about how the individual prefers to do business with FCTICL, and the types of products and services used.	To provide offers you may be interested in To help us understand our relationship with you	All business lines

Depending on the circumstances, FCTCL collects the following categories of personal information:

Category	Types of personal information	Purpose for use	Applicable FCTICL business lines
Contact information	Name, address, telephone number, fax number, email address, law firm name, law firm type, business address, licensing information.	To manage our relationship with you and our customers, such as legal professionals, lending professionals, real estate professionals, recovery professionals, and valuation professionals To communicate with you, including where you have consented to receive marketing messages from FCTICL To communicate where applicable with your legal counsel or lender For valuation and underwriting purposes To verify your identity to grant access to certain of our products and services To detect and prevent fraud For employment purposes To process payments to us, or collect payments for other customers or partners	Default and Recovery Solutions Marketing Sales Customer Experience Human Resources Legal Data and Analytics Finance
Demographic information	Date of birth, marital status.	To verify your identity to grant access to certain of our products and services To detect and prevent fraud To prepare documents for registration on your behalf To request your feedback on our products and services so we can consistently meet and exceed your expectations For employment purposes	Default and Recovery Solutions Human Resources Data and Analytics
Location information	Information obtained automatically from use of our Website or from a credit report or from a third party hired to assist creditors with asset retrieval	To establish and verify your identity to grant access to certain of our products and services or to consent to a background check for employment purposes To provide services to creditors, subject to applicable legal requirements To detect and prevent fraud	Default and Recovery Solutions Human Resources Marketing Sales Data and Analytics
Financial information	Assets and liabilities, details about payment or credit history, credit score, information relating to your loan, including the amount, purpose, and priority of the loan, information about financial commitments with other parties, and other financial account information relevant to the services we provide to an individual, their lender, their creditor, or their lawyer.	To provide credit management, estate administration or debtor services For employment purposes	Default and Recovery Solutions Human Resources
Payment information	Banking information, credit card information	To process payments to us, or collect payments for other customers or partners For employment purposes	Default and Recovery Solutions Human Resources Finance
Job candidate information	Information provided in the application	To facilitate recruitment activities To process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.	All business lines
Information collected automatically through digital and online services	FCTCL’s digital and online services may collect certain information automatically including through cookies and other tracking technologies (see Information Collected Automatically section below).	To provide services you request from FCTCL To help us understand our relationship with you To detect and prevent fraud	All business lines
Information about the product and services you have with FCTCL	Information about how the individual prefers to do business with FCTCL, and the types of products and services used.	To provide offers you may be interested in To help us understand our relationship with you	All business lines

We use your personal information for the purposes identified above and for the following purposes:

To provide requested products or services;
To communicate with you about products, services, and events that may be of interest;
To accurately assess and determine which insurance products and related services will meet the needs and specific requirements of each of our customers;
To establish and collect premiums and other amounts owing in relation to our products and services;
To process applications submitted, particularly with respect to insurance risks being undertaken;
To investigate and administer claims;
To advise our customers of underwriting and claims initiatives to reduce the risks associated with the acquisition and financing of real property;
To wire funds to the applicable accounts;
To investigate, detect and prevent fraudulent transactions;
To reinsure as required;
To develop, enhance, market, or provide products and services;
To manage, continually develop, and enhance our business and operations;
To aggregate or otherwise anonymize your personal information for use for technical, research, and analytical purposes;
To better understand how you use the Website, in order to improve the Website and our services and develop new products or services;
To request and collect feedback and respond to requests and complaints;
To meet legal and regulatory requirements; and
For any other legitimate purpose identified to the customer.

If we plan to use personal information, we have collected for a purpose not previously identified, we will identify and document this purpose before such use and obtain your consent where required.

3. How do we collect information?

Depending on our relationship to you, we collect personal information from you directly or from third parties such as lenders, lawyers, notaries, licensed insolvency trustees, or other agents authorized to represent you, or which have a legitimate business or services relationship with you. For example, with your consent, we may obtain credit information from a credit reporting agency for the purposes of evaluating your creditworthiness. We may obtain personal information from your lawyer over the phone, by fax, by email or through FCT’s online ordering platform. We may also obtain property or other relevant information from public registries where permitted by law.

When we collect personal information from third parties, we take steps to ensure that those third parties have your consent to provide the personal information to use, except where otherwise permitted by law.

4. Information collected automatically

We use cookies and similar tracking technologies to collect information from visitors to our Website, as described in more detail below. These tracking technologies may be placed by us, or by third parties. You can control the collection of information through these tracking technologies by using the consent management tool available on our Website.

Cookies. Our Website uses cookies (small files containing program code that reside on your computer), to provide usage statistics about the Website, and to understand where visitors visit the Website from. We also may use cookies to simplify the re-entering of your data. You can adjust how your browser uses cookies by having your browser disable cookies. Look for the cookie options in your browser in the Options or Preferences menu.

Log Files. When you use the Website, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with the Website, domain names, landing pages, and pages viewed, mobile carrier, and similar information. Log files help us to monitor, analyze, improve, and maintain the Website and to diagnose and fix technical issues.

Device Identifiers. When you access the Website using a mobile device, we collect information about your device contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We use this information to optimize the Website and fix technical issues.

Analytics. We may use third party service providers like Google Analytics to collect information about your use of the Website, such as the features used and time spent on the Website, to help us better understand our users and improve the Website. For information about how information is processed in connection with Google Analytics, please read the Google Analytics Policy here.

5. How do we disclose information?

We may share personal information as described in this section.

Service Providers. We share personal information with third parties (including affiliates acting in this capacity such as FCTCL, as applicable) that carry out certain functions on our behalf such as order fulfillment, data processing, payment processing, identity verification, and the administration, investigation, and processing of claims.

Transaction Partners. For certain debtor and estate management services, we may transfer personal information to lenders, other creditors, and licensed insolvency trustees in order to provide our services.

Business Transaction. We may disclose personal information to parties in connection with a corporate transaction, such as a sale, financing or other disposition of all or part of our business or assets, including for the purposes of evaluating and/or performing the transaction.

Legal Compliance. We may disclose personal information to meet our legal and regulatory obligations or otherwise as permitted or required by law, including to comply with a court order, subpoena or warrant, to law enforcement in connection with an investigation, to protect our rights and the safety and security of our employees, and to enforce our agreements and collect debts owed to us.

We comply with all applicable laws and regulations regarding the protection of privileged personal information. In the rare event that disclosure is required by law, we will take all necessary steps to ensure that the disclosure is made in a manner that preserves solicitor-client privilege.

6. How do we protect your information?

We protect personal information using physical, technical, and organizational safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures are designed to protect against unauthorized access, alteration, use, disclosure, or destruction of personal information. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. We also use our best efforts to ensure that personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Despite these measures, since no system or security measure is completely secure, it is possible that personal information may be lost, stolen, or accessed without authorization.

7. Where is your information stored and for how long?

Our record retention periods are determined based on the purpose for which the information was collected, our legal and regulatory obligations to retain the information, and prudent business practices. Files containing personal information will be maintained on our servers or those of our services providers and will be accessible to our service providers, employees and contractors with a business need to know.

Where personal information is no longer required to fulfill the purpose for which it was collected, it will be destroyed, erased, or made anonymous, provided there are no legal requirements for its continued retention. We may store personal information for as long as is necessary for the processing purpose(s) for which we originally collected it and for other business purposes explained in this Privacy Policy. For example, we may retain property information for title searches and title insurance policy enforcement purposes to facilitate the resolution of future disputes and clarify historical ownership records.

We and our service providers may process and store personal information in any province in Canada, or outside Canada, including in the United States and India, and personal information may be collected, used, disclosed, stored, and processed in the United States, India or elsewhere outside of Canada for the purposes described in this Privacy Policy. If personal information is located outside Canada, it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose personal information to government authorities in those countries.

For more information about the use of service providers outside Canada, please contact us as set out below.

8. What are your privacy choices?

You can withdraw your consent to our use of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. If you have submitted personal information and later wish to withdraw your consent to its retention, use or disclosure, please contact the Chief Privacy Officer (refer to section 12, “How to contact us if you have a privacy concern?”).

Please understand that, without your consent, we may not be able to provide certain products and services to you. We will inform individuals of any implications of withdrawing consent. In certain circumstances, your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use, sharing, and disclosure is permitted or required by law.

9. What are your privacy rights?

You have the right to request access to your personal information in our control, and to request information about how we have collected, used, and disclosed it. You also have the right to request that inaccurate, incomplete, or out of date information be rectified. In certain circumstances, you also have the right to request that your personal information be deleted. Your rights are subject to applicable legal restrictions, and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact the Chief Privacy Officer (refer to section 12, “How to contact us if you have a privacy concern?”).

10. Third party links

The Website may contain links to other websites that we do not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

11. Changes to this privacy policy

We reserve the right to make changes to this policy. If this policy materially changes, we will take reasonable measures to notify you of the changes, including by posting a copy of the revised policy on our Website. Your continued use of our services following notification of any material change and/or your continued access to our website following the posting of any changes to this policy shall constitute your acceptance of those changes. You may also contact us if you would like us to send you a copy of the most current version of this policy.

Privacy Policy

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