Privacy NoticeThis Privacy Notice (the “Notice”) only applies to the collection and use of personally identifiable information (the ‘Personal Information’) gathered through the use of the portion of the onlia.ca website (the “Onlia Website”) that is owned and operated by Onlia Holding Inc. (“Onlia”). This Notice does not apply to any subdomain of the Onlia Website that is owned and/or operated by or on behalf of any third party and/or an affiliate or related company to Onlia even if we provide a link to such subdomain. The subdomains that are currently owned by third party affiliated companies are (i) www.onliasense.ca (the “OSI Website”), and (ii) www.onlia.ca/insurance (the “MGA Website”). Please refer to the respective subdomain for a copy of the Privacy Notice applicable to each of them.
Onlia is committed to protecting your privacy. In this Notice, ‘we’, ‘our’, or ‘us’, refers to Onlia and its subsidiaries and affiliates. The Notice (i) describes the Personal Information that we may collect through the Onlia Website and the blog contained therein (the “Blog”), (ii) explains the purpose of collecting and the use of such Personal Information, and (ii) explains how and when we may share it.
The collection of Personal Information by Onlia is limited to that which is needed for the purposes identified by us. Information is collected by fair and lawful means only.
We are responsible for all Personal Information under our control, whether supplied to us directly by you or by a third party, or that we have provided to a third party for processing. We have established policies and procedures to comply with our Notice, and have designated a Privacy Officer who is responsible for ensuring we comply with privacy legislation. If you need to contact our Privacy Officer regarding your specific privacy questions or concerns, please see the contact information at the end of the Notice.
Onlia collects your Personal Information directly from you for the following purposes:
- to communicate with you, including responding to your questions or inquiries in relation to our Blog posts and/or your comments on the Onlia Website and through our social media channels
- to market or remarket products or services, either directly, through loyalty partners, affiliates, third party service providers, or advertisers
- to understand your product and service needs
- to allow us to operate the Onlia Website in accordance with our Conditions of Use.
- to allow us to investigate, assess, defend and settle losses in the event of a claim against us
- to manage and assess our risks, operations and relationship with you
- to ensure compliance with legal, regulatory, governmental and contractual requirements
- to detect and prevent fraud
- to analyze business results, compile statistics, perform administrative tasks such as accounting and information system activities and conduct marketing and underwriting research and modeling
- to train employees and monitor for quality assurance
- to act as required or as authorized by law
We may also use your Personal Information for other purposes with your consent or as permitted or required by law. If we require your Personal Information for any purpose other than as identified above, Onlia will seek your consent prior to using it.
Consent to collection of personal information
Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of Personal Information at any time by contacting our Privacy Officer. In addition, you may also opt out of certain communications we may send you regarding other products and services.
Collection of personal information
The Personal Information that we collect comes directly from you through the Onlia Website and/or the Blog. We obtain your consent electronically for the collection, use and disclosure of your Personal Information in accordance with this Privacy Notice, and, depending on the circumstances, for other purposes identified prior to the collection of your Personal Information.
Unless required by law, Onlia will not collect, use or disclose Personal Information without obtaining your consent first. Your consent can be “implied” or “express”. Implied consent refers to conduct which demonstrates voluntary provision of Personal Information, for example, when you provide Personal Information for the purpose of an inquiry or a comment on our blog posts. Express consent refers to circumstances where you are provided with explicit disclosure regarding the nature of the collection, use, and disclosure of your Personal Information.
The types of Personal Information that we may collect in order to fulfill the purposes identified above include an individual's name, e-mail address, telephone number, facebook, twitter and Instagram handles.
Cookies, automatic data collection and related technologies
The Onlia Website also contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Protecting your Personal Information is very important to us, so we have taken the necessary organizational, technological and physical safeguards to protect it. When you submit sensitive information via the Onlia Website, your information is protected both online and offline.
Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the Web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, customer service) are granted access to your Personal Information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
Any service providers we share your Personal Information with, are held to the same standard as us and are bound by our Privacy Notice and governing law.
Limiting use, disclosure, and retention
Unless you consent otherwise or it is required by law, Personal Information can only be used or disclosed by us for the purposes for which it was collected. We keep Personal information only as long as required to serve those purposes.
Personal Information that is no longer required to fulfill the identified purposes is destroyed, erased or made anonymous. Onlia has developed and implemented detailed retention principles, and will ensure destruction of personal information in a method that prevents improper access.
There are situations specific to our business where we will use, disclose and retain Personal Information as dictated by prudent business practices. Examples of these situations include:
- Storage of Information: transfer of Personal Information to cloud providers
- Regulatory: compliance with legal, audit and other regulatory or governmental regulations
Onlia may internally share your Personal Information for the purposes identified in this Notice with its employees, affiliates or other related companies outside of Canada. Only such companies with legitimate business reasons will have access to your Personal Information and must ensure that Personal Information in their possession is securely held.
We may disclose your Personal Information to third-party service providers, third-party loyalty partners, and third-party advertisers. Third parties are also subject to applicable privacy legislation. Only those companies or individuals who are authorized, based on their need to carry out work for the purposes identified herewith, can have Personal Information disclosed to them.
We may transfer any Personal Information that we have about you in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
We try to ensure that the Personal information that we collect is accurate, complete, and up-to-date as possible in order to properly satisfy the purposes for which it is to be used. If we are unable to verify your Personal Information or contact you, we may be limited in our ability to provide you with our services.
Upon request, Onlia will provide an explanation of its Notice with respect to the management of Personal Information. You can contact our Privacy Officer with any inquiries or complaints or if you require further information.
If you would like to obtain a copy of the Personal Information held about you by us, or update, correct, or delete any information that you have provided to us through your use of the Onlia Website and/or the Blog, or otherwise, or if you have any questions or suggestions for improving this Privacy Notice, please contact us. If you have questions about unsubscribing from email or other communications do so via email. We may only deny access to your Personal Information when such denial is: (1) required or authorized by law; (2) when granting you access would have an unreasonable impact on other people’s privacy, unless the requested information is severable from the personal information of other people; and (3) to protect our confidential commercial information. If we deny your request for access to, or refuse a request to correct information, we shall explain why.
Any individual may address a written challenge concerning our compliance with this Privacy Notice to our Privacy Officer.
Onlia will investigate all written complaints. Should we find that a complaint has reasonable grounds, we will take all appropriate steps to correct the information and amend the Notice or practice as required, and will notify the individual about the outcome.
Changing our privacy agreement
From time to time, we may update or make amendments to the Notice to comply with any changes in legislation or to take into consideration any other issues that may arise. Should we make any changes, we will post the revised Notice on the Onlia Website and/or provide you with a link or an email notification. We encourage you to check back often and keep yourself informed about our Notice. As we continue to serve you and where changes have been made to this Notice, our continued business relationship constitutes acceptance of those changes.
Onlia welcomes any questions, comments or inquiries. Our preference is that you communicate with us through electronic means. You may contact our Privacy Officer regarding your specific privacy questions or concerns at:
Onlia Holdings Inc.
351 King St. E, Suite 801
Toronto, ON M5A 1L1
Effective date: June 8, 2018