Website Privacy Policy

1. Purpose

The purpose of this Privacy Policy is to explain how Switch Broker Network collects, uses, discloses, retains, safeguards, and disposes of personal information.

This Privacy Policy also explains the choices and rights available to individuals whose personal information is handled by Switch.

2. Scope

This Privacy Policy applies to personal information collected through:

• Our websites and online forms.
• Insurance quotations, applications, policies, renewals, endorsements, cancellations, and claims assistance.
• Telephone, email, text message, secure portal, electronic signature, and written communications.
• Client service, complaint handling, quality assurance, and regulatory activities.
• Other interactions with clients, prospective clients, authorized representatives, and website visitors.

This Privacy Policy applies to Switch Broker Network and its authorized operating names. It does not replace any specific consent, disclosure, or contractual document provided in connection with an insurance transaction.

3. Privacy Framework

Switch manages personal information in accordance with applicable Canadian privacy legislation, including:

• The Personal Information Protection and Electronic Documents Act (PIPEDA).
• The Personal Information Protection Act (Alberta), where applicable.
• The Personal Information Protection Act (British Columbia), where applicable.
• Other applicable federal or provincial privacy requirements.

The law that applies may depend on the province in which an individual resides, the location of the activity, and whether personal information is transferred across provincial or national borders.

4. Privacy Commitments

Switch is committed to:

• Collecting only the personal information reasonably required for identified purposes.
• Obtaining meaningful consent where consent is required.
• Using and disclosing personal information only for identified purposes, unless otherwise permitted or required by law.
• Maintaining reasonable administrative, technical, and physical safeguards.
• Limiting access to individuals who require the information to perform authorized responsibilities.
• Maintaining accurate and complete records where the information is used to make decisions.
• Retaining personal information only as long as reasonably required.
• Responding to access, correction, withdrawal, and complaint requests in a fair and timely manner.
• Maintaining accountability for personal information transferred to service providers for processing.

5. Personal Information We Collect

Depending on the insurance product, service, or interaction, Switch may collect the following personal information.

Identification and Contact Information

• Name, address, telephone number, and email address.
• Date of birth and preferred communication method.
• Government-issued identification information where reasonably required and legally permitted.

Insurance and Underwriting Information

• Current and previous insurance policies.
• Coverage requirements, limits, deductibles, and insurance needs.
• Claims and loss history.
• Reasons for cancellation, non-renewal, or coverage changes.
• Information about insured persons, drivers, occupants, dependants, employees, officers, and other relevant individuals.
• Information about vehicles, properties, businesses, operations, assets, liabilities, and risk exposures.
• Driving records, insurance history, and other underwriting information obtained from approved sources where permitted.

Financial and Transactional Information

• Billing and payment information.
• Banking or payment card information where required.
• Premium financing information.
• Credit information where permitted and reasonably required.
• Records of premiums, refunds, commissions, fees, and other transactions.

Communications and Service Records

• Emails, letters, text messages, online submissions, and other correspondence.
• Broker notes and client service records.
• Electronic signatures and consent records.
• Complaints, inquiries, and requests.
• Call recordings where calls are recorded and appropriate notice is provided.
• Information provided through client portals, quotation tools, and electronic applications.

Website and Technical Information

• Internet Protocol address.
• Browser, device, and operating system information.
• Date, time, and duration of visits.
• Pages viewed, links selected, and referral source.
• Website error, security, cookie, and similar technical information.

Website information is not ordinarily used to identify an individual directly unless the individual submits information, signs into a service, or the information is reasonably required for security, fraud prevention, legal, or operational purposes.

6. Sources of Personal Information

Switch may collect personal information:

• Directly from you.
• From an individual you authorize to act on your behalf.
• From another insured person, applicant, policyholder, or business representative.
• From insurers, managing general agents, wholesalers, adjusters, and underwriting partners.
• From insurance industry databases, claims history providers, motor vehicle information providers, credit reporting agencies, and investigative services where permitted.
• From government departments, registries, regulatory authorities, and public records where permitted.
• From referral partners and other organizations involved in an insurance transaction.
• Through websites, online forms, client portals, electronic signature platforms, email, telephone, and other communication channels.

Where you provide personal information about another individual, you are responsible for ensuring that you are authorized to provide it or that another lawful basis permits the disclosure.

7. Purposes for Collection, Use, and Disclosure

Switch may collect, use, and disclose personal information for the following purposes:

• Identifying and communicating with clients and prospective clients.
• Understanding insurance needs, circumstances, and risk exposures.
• Obtaining quotations and assessing eligibility.
• Recommending, arranging, placing, renewing, amending, or cancelling insurance coverage.
• Preparing and processing applications, policies, endorsements, renewals, and cancellations.
• Administering and servicing insurance policies.
• Collecting premiums, processing payments, and administering refunds.
• Assisting with claims reporting and communication.
• Communicating with insurers, underwriters, adjusters, and other parties involved in an insurance transaction or claim.
• Verifying information and preventing or investigating fraud, misrepresentation, unauthorized activity, or other unlawful conduct.
• Managing complaints, inquiries, quality reviews, audits, and regulatory examinations.
• Meeting licensing, recordkeeping, taxation, legal, regulatory, and professional obligations.
• Protecting clients, employees, systems, information, and business operations.
• Improving services, systems, training, workflows, and website performance.
• Conducting business planning, reporting, and analytics using aggregated or de-identified information where appropriate.
• Establishing, exercising, or defending legal rights.
• Completing a proposed or actual financing, reorganization, sale, transfer, or other business transaction, subject to appropriate confidentiality and legal requirements.
• Sending promotional or commercial electronic communications where consent has been provided or where otherwise permitted by law.

Switch will not use or disclose personal information for an unrelated purpose without additional consent unless the activity is permitted or required by law.

8. Consent

Switch obtains consent in a form appropriate to the sensitivity of the information, the purpose for which it is required, the method of interaction, and applicable legal or contractual requirements.

Consent may be provided verbally, electronically, in writing, through an authorized representative, or through another legally recognized method.

Personal information may be collected, used, or disclosed without consent where permitted or required by law. This may include fraud prevention, legal proceedings, regulatory reporting, debt collection, emergencies, investigations, or other legally authorized activities.

You may withdraw or modify consent by contacting Switch. Withdrawal is subject to legal, regulatory, contractual, and reasonable notice requirements. Withdrawal may limit our ability to obtain quotations, arrange coverage, service a policy, process a transaction, or provide another requested service.

9. Disclosure to Third Parties

Switch may disclose personal information to organizations involved in providing, supporting, regulating, or reviewing our services, including:

• Insurance companies.
• Managing general agents, wholesalers, and underwriting intermediaries.
• Claims adjusters, appraisers, investigators, repair providers, and claims service organizations.
• Insurance industry information and claims history providers.
• Motor vehicle and driver information providers.
• Credit reporting agencies, financial institutions, payment processors, and premium finance providers where permitted.
• Technology, hosting, cloud, data storage, cybersecurity, communications, electronic signature, and client portal providers.
• Mailing, document management, and records storage providers.
• Auditors, accountants, lawyers, consultants, and other professional advisors.
• Regulators, licensing bodies, privacy commissioners, law enforcement agencies, courts, tribunals, and government authorities.
• Purchasers, investors, lenders, and advisors involved in a proposed or completed business transaction, subject to appropriate controls.
• Other parties where directed or authorized by you.

Service providers are expected to use personal information only for authorized purposes and to maintain safeguards appropriate to the sensitivity of the information.

10. Processing Outside Your Province or Canada

Some insurers, service providers, technology platforms, or supporting systems may process or store personal information outside your province or outside Canada.

Where personal information is processed in another jurisdiction:

• The information may be subject to the laws of that jurisdiction.
• Courts, law enforcement agencies, national security authorities, or regulators in that jurisdiction may be legally entitled to access it.

Switch will use reasonable contractual, administrative, and security measures to protect personal information under its control.

Additional information about relevant service provider locations may be requested from the Privacy Officer, subject to legal, security, and confidentiality limitations.

11. Website Cookies and Similar Technologies

Our websites may use cookies and similar technologies to:

• Operate the website and maintain secure sessions.
• Remember settings and preferences.
• Understand how visitors use the website.
• Identify technical errors and security events.
• Improve navigation, content, and performance.
• Measure the effectiveness of communications or campaigns.

You may adjust your browser settings to block or delete cookies. Blocking some cookies may affect website functionality. Where required, additional notice or choices will be provided for non-essential cookies.

12. Electronic Communications and Marketing

Switch may communicate by email, text message, telephone, secure portal, electronic signature platform, or another agreed method.

Service communications may include:

• Quotations and applications.
• Disclosure and consent documents.
• Policy documents.
• Billing information.
• Renewals and endorsements.
• Claims-related communications.
• Regulatory or service notices.
• Requests for information required to administer insurance.

Where required, Switch obtains consent before sending commercial electronic messages. Commercial messages will identify the sender, provide required contact information, and include an unsubscribe method.

Withdrawal from marketing communications does not prevent Switch from sending service, transactional, legal, security, or regulatory communications relating to an inquiry, application, policy, or existing relationship.

13. Safeguards

Switch maintains administrative, technical, and physical safeguards appropriate to the sensitivity, amount, format, location, and intended use of personal information.

Safeguards may include:

• Role-based access and identity controls.
• Password and authentication requirements.
• Encryption and secure transmission methods where appropriate.
• Network, endpoint, and email security.
• Physical access controls.
• Confidentiality requirements.
• Employee and contractor training.
• Vendor due diligence and contractual requirements.
• Logging, monitoring, testing, and incident response procedures.
• Secure retention and disposal processes.

Access to personal information is limited to employees, contractors, and service providers who reasonably require the information to perform authorized responsibilities.

14. Privacy Incidents and Breaches

Switch maintains procedures to identify, contain, investigate, document, and respond to suspected privacy and security incidents.

Where required by applicable law, Switch will:

• Report qualifying breaches to the appropriate privacy regulator.
• Notify affected individuals.
• Maintain required breach records.
• Take reasonable steps to reduce the risk of further harm.

15. Accuracy of Information

Switch takes reasonable steps to ensure that personal information used to make decisions is accurate, complete, and current.

You are responsible for notifying Switch promptly of changes that may affect your insurance or our ability to contact you, including changes to:

• Address, email address, or telephone number.
• Drivers, household members, employees, officers, or other insured persons.
• Property occupancy or use.
• Vehicles.
• Business operations.
• Claims, losses, or other material risk information.

16. Retention and Disposal

Switch retains personal information only for as long as reasonably required to:

• Provide services and administer insurance transactions.
• Meet legal, regulatory, contractual, accounting, and recordkeeping obligations.
• Respond to access requests or complaints.
• Support audits and investigations.
• Manage limitation periods, claims, disputes, or legal proceedings.
• Establish, exercise, or defend legal rights.

Retention periods may vary based on the type of record, insurance product, province, legal requirements, and the existence of a complaint, investigation, claim, or legal hold.

When personal information is no longer required, it will be securely destroyed, deleted, or anonymized in accordance with applicable retention and disposal procedures.

17. Access and Correction

Subject to applicable legal exceptions, you may request:

• Confirmation of whether Switch holds personal information about you.
• Access to your personal information.
• Information about how personal information has been used.
• Information about organizations to which personal information has been disclosed.
• Correction of inaccurate or incomplete information.

Requests must be submitted to the Privacy Officer. Switch may request information necessary to verify identity and locate the requested records.

Access may be limited where disclosure would reveal another individual’s information, confidential commercial information, legally privileged material, information generated during a formal dispute resolution process, or information that cannot legally be disclosed.

18. Privacy Questions and Complaints

You may contact the Privacy Officer to:

• Ask a question about this Privacy Policy.
• Request access to or correction of personal information.
• Withdraw or modify consent.
• Report suspected misuse of personal information.
• Report a suspected privacy or security incident.
• Request an accessibility or communication accommodation.
• Submit a privacy complaint.

Privacy complaints are handled without cost. No individual will be disadvantaged for raising a concern in good faith.

Switch will:

• Acknowledge the concern.
• Confirm the issues requiring review.
• Assign an appropriate individual to investigate.
• Protect the confidentiality of the complaint.
• Provide updates where additional time is required.
• Communicate findings, decisions, and corrective actions where appropriate.
• Identify available external recourse where appropriate.

19. External Privacy Recourse

Switch encourages individuals to contact the Privacy Officer first so that the concern may be reviewed and addressed.

You may also contact the privacy regulator responsible for the matter, including:

• The Office of the Privacy Commissioner of Canada.
• The Office of the Information and Privacy Commissioner of Alberta.
• The Office of the Information and Privacy Commissioner for British Columbia.
• Another applicable provincial privacy authority.

The appropriate regulator may depend on the province, the nature of the activity, and whether personal information crossed provincial or national borders.

20. Third-Party Websites and Services

Our websites may contain links to websites, portals, social media platforms, insurers, or services operated by other organizations.

Switch is not responsible for the privacy practices, security, or content of an external service that it does not control. Individuals should review the privacy policy of the external organization before providing personal information.

21. Information About Minors

Our websites and general brokerage services are not directed specifically to children.

Where insurance services require information about a minor, Switch will collect, use, and disclose the information only as reasonably required and in accordance with applicable law. Consent may be obtained from a parent, guardian, policyholder, or other authorized individual, depending on the circumstances.

22. Changes to This Privacy Policy

Switch may update this Privacy Policy to reflect changes to:

• Applicable laws or regulatory guidance.
• Services or business operations.
• Technology or service providers.
• Privacy or security practices.
• Client rights or contact methods.

The current version will be posted on our website with its effective date. Where required, Switch will provide additional notice or obtain new consent before using personal information for a materially different purpose.

23. Contact for Privacy Matters

Questions, requests, concerns, and complaints regarding personal information should be directed to:

Please include “Attention: Privacy Officer” in the subject line of an email or on written correspondence.