The protection of your personal information is very important to us. Our high standards for privacy protection comply with Canada’s privacy laws.
Policyholder information is gathered at the time of application to determine the premium and appropriate coverage. If a loss occurs, we may need to collect additional medical information to help provide the best possible assistance, arrange care, possible medical evacuation, and to determine coverage. The information is used only as needed and is maintained securely for the period required by law.
Upon written request, you may also review your personal information to verify its accuracy. For more information about how TuGo collects and uses personal information, please contact our privacy officer:
Attn: Privacy Officer
11th Floor, 6081 #3 Road
Richmond BC, Canada, V6Y 2B2
Fax: (604) 276-9409
- Scope and Application
- Website and Electronic Communications:
- TuGo’s Ten Privacy Principles:
- Principle 1 – Accountability
- Principle 2 – Identifying Purposes for Collection of Personal Information
- Principle 3 – Consent
- Principle 4 – Limiting Collection of Personal Information
- Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
- Principle 6 – Accuracy
- Principle 7 – Security Safeguards
- Principle 8 – Openness
- Principle 9 – Individual Access
- Principle 10 – Handling Inquiries and Challenges
Scope and Application
This Policy is subject to, and in addition to, the requirements and procedures under any applicable privacy law or regulation. In the event of conflict between this Policy and an applicable law or regulation, the law or regulation shall prevail.
- The scope and application of this Policy are as follows:
The Policy applies to personal information about TuGo’s customers and other individuals that is collected, used or disclosed by TuGo.
- This Policy is subject to change, and may be supplemented or modified by additional terms applicable between TuGo and an individual. Those terms may be contained in, for example, an application or order form, a policy booklet, or terms and conditions of sale.
Collection – the act of gathering, acquiring, recording, or obtaining personal information, whether orally, electronically or in writing.
Consent – agreement to the collection, use or disclosure of personal information. Consent can be express, implied or deemed, and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. Deemed consent occurs in situations described in applicable privacy legislation or regulations.
Disclosure – making personal information available to a third party.
Personal information – information about an identifiable individual, but not including aggregated information that cannot be associated with a specific individual, or information excluded under applicable privacy legislation or regulations, such as publicly available information or certain business contact information.
TuGo – includes the following companies: North American Air Travel Insurance Agencies Ltd. d.b.a. TuGo and Claims at TuGo.
Third party – an individual or organization outside TuGo.
Use – the treatment, handling and management of personal information by and within an organization.
1.1 We respect the privacy and confidentiality of individuals who visit the Site.
2. Collection of Non-Personal Information
2.1. In order to analyze and understand how the Site is used, and improve the content, layout and performance of the Site, we collect certain aggregate information from users of the Site (“Aggregate Information”). We also collect Aggregate Information in order to analyze and understand general trends, preferences, interests and behaviour so that we can improve our services to reflect these trends, preferences, interests and behaviour, and better meet the needs of the users of the Site.
2.2. Aggregate Information is statistical information collected from a group of users that is aggregated and anonymous, and is not personal information about an identifiable individual, and is not readily associated with an identifiable individual. Aggregate Information may describe the usage patterns and/or demographics of users as a group but it does not describe or reveal the identity of any particular individual.
2.3. Aggregate Information includes information about demographics, website traffic patterns and flows, referral data (e.g. the address of the last URL a user visited before visiting the Site), domain names, and browser and platform type.
2.4. We use Aggregate Information for our internal use and do not share Aggregate Information with third parties.
3. Use of Google Analytics and Cookies
3.1. The Site may use Google Analytics or another similar program to help collect and analyze Aggregate Information so that we can improve the Site.
3.2. The Site may use various Google Analytics Advertising Features, including Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting and other integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers.
3.3. Google Analytics uses “cookies”, which are small files that are sent to your computer when you visit a website, to collect standard internet log information and visitor behaviour information in an anonymous form. Cookies allow websites to recognize your browser, and they may store user preferences and other information.
3.4. This Site may use “first-party cookies”, such as the Google Analytics Cookies, or “third-party cookies”, such as Google advertising cookies. This Site and third-party vendors may use both first-party cookies and third-party cookies together.
3.5. The Aggregate Information collected by these cookies is transmitted to Google and processed to compile statistical reports of Aggregate Information.
3.7. You may also be able to opt out of some portions or elements of Google Analytics by using Google’s Opt-out Browser Add-on (the “Add-on”). More information regarding the Add-on may be found at https://tools.google.com/dlpage/gaoptout/.
3.8. We do not make any representations or warranties concerning the accuracy, effectiveness, or reliability of the Add-on and we are not responsible or liable in any way for your use of the Add-on.
4. Personal Information
4.1. If we do wish to collect personal information from you that is not Aggregate Information and that is personally identifiable information, we will ask for and obtain your consent, ask you to explicitly submit that personal information by filling out a form on the Site and explain why we are collecting your personal information.
4.2. To the extent that we collect personal information from you, we will endeavour to keep the personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it will be used, and we will handle the personal information in accordance with applicable privacy laws.
5. Device Information, Logging, and Local Storage
Principle 1 – Accountability
1.1 TuGo is responsible for personal information under its control and has designated its Privacy Officer as the person who is accountable for TuGo’s compliance with the following Principles.
1.2 The Privacy Officer may delegate the performance of certain responsibilities regarding the Policy to other employees and agents of TuGo.
1.3 TuGo is responsible for personal information in its possession or under its control. TuGo shall use appropriate means to ensure the protection of personal information while it is being used by third parties on behalf of TuGo (see Principle 7)
1.4 TuGo shall implement policies and procedures to give effect to the Policy, including:
- establishing procedures to receive and respond to inquiries or complaints;
- training and communicating to staff about the Policy and related matters; and
- developing public information to explain the Policy and related matters.
Principle 2 – Identifying Purposes for Collection of Personal Information
2.1 TuGo shall identify and record the purposes for which personal information is collected at or before the time the personal information is collected or, when appropriate, at or before the time the personal information is used for a new purpose.
2.2 TuGo collects personal information for the following purposes:
- to establish and maintain commercial relationships with our partners and customers;
- for purposes identified or reasonably obvious to individuals in respect of particular collections of personal information including, for example, identifying available insurance coverage and determining premiums, determining the medical condition of customers, providing assistance services to customers and their families, determining customers’ suitability and making arrangements for medical evacuation, and determining insurance coverage;
- to meet legal and regulatory requirements;
- to understand needs and preferences of individuals;
- to develop, enhance, market and/or provide products and services; and
- to manage and develop TuGo’s business and operations, including transfer of data amongst TuGo and its partners.
Further references to “identified purposes” include the purposes identified in this Principle.
2.3 TuGo shall, as appropriate, specify orally, electronically or in writing to the affected individual the relevant and identified purposes for collecting, using or disclosing personal information at or before the time personal information is collected. Upon request, persons collecting personal information shall explain those purposes or refer the individual to a designated person within TuGo who shall explain those purposes.
Principle 3 – Consent
3.1 In most cases, the consent of the affected individual is required for the collection, use or disclosure of personal information. In certain circumstances personal information may be collected, used or disclosed without the knowledge or consent of the individual, such as in the case of an emergency where the life, health or security of an individual is threatened.
3.2 TuGo may disclose personal information without the knowledge or consent of the affected person to a lawyer or other advisor representing a member of TuGo, to collect a debt, to comply with a subpoena, warrant or other court order, or as may otherwise be required or authorized by law.
3.3 Where required by law, TuGo shall use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information may be collected, used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the individual.
3.4 Generally, TuGo shall seek consent to use and disclose personal information at the same time it collects the information. However, TuGo may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.
3.5 TuGo will require individuals to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is reasonably required to fulfill the identified purposes.
3.6 In determining the appropriate form of consent (express or implied) TuGo shall take into account the sensitivity of the personal information and the reasonable expectations of the individual.
3.7 An individual may withdraw consent to the use or disclosure of personal information, subject to legal or contractual restrictions and reasonable notice. TuGo will inform individuals of the effect of withdrawing consent. Individuals may contact the Privacy Officer or another designated representative of TuGo for more information regarding the implications of withdrawing consent in particular circumstances.
Principle 4 – Limiting Collection of Personal Information
4.1 TuGo shall limit the collection of personal information to that which is reasonably necessary for the purposes identified by TuGo or otherwise permitted by law.
4.2 TuGo generally collects personal information from the individual to whom the information relates, and may collect personal information from third parties including parents and legal guardians, spouses or family members, physicians and other medical care providers and other third parties who represent that they have the right to disclose the information, or as otherwise permitted by law.
Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
5.1 TuGo shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. TuGo shall retain personal information only as long as necessary for the fulfillment of those purposes or as required or permitted by law.
5.2 TuGo may disclose an individual’s personal information to:
- a person who in the reasonable judgment of TuGo is seeking the information as an agent or legal or personal representative of the individual;
- a company or individual employed or contracted by TuGo to perform functions on its behalf, such as but not limited to research or data processing and storage;
- another company or individual for the development, enhancement, marketing or provision of any of TuGo’s products and services;
- an agent used by TuGo to evaluate the individual’s creditworthiness or to collect the individual’s account, or a credit reporting agency;
- a public authority or agent of a public authority if, in the reasonable judgment of TuGo, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information;
- another entity as part of a merger, a sale of assets or all or part of a business, or any other corporate change or re-organization;
- a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.
5.3 Only employees and agents of TuGo with a business need to know, or whose duties reasonably so require, will be granted access to personal information.
5.4 Where personal information has been used to make a decision affecting an individual, TuGo shall retain for a reasonable period of time either the actual information referred to in making the decision or a record of the reasons for making the decision.
5.5 TuGo shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required or permitted by law to be retained. When, in accordance with such practices and law such information is no longer required to be retained, it shall be destroyed, erased or made anonymous.
Principle 6 – Accuracy
6.1 TuGo shall take reasonable steps to ensure that personal information is as accurate, complete and up-to-date as is appropriate given the purposes for its collection, use and disclosure, and to minimize the possibility that inappropriate information may be used to make a decision affecting an individual.
6.2 TuGo shall amend personal information about individuals as and when reasonably necessary to fulfill the identified purposes for its collection, use or disclosure. If TuGo receives a request to make an amendment or addition to personal information about an individual and TuGo concludes that such amendment or addition is appropriate, TuGo will amend the personal information. If TuGo concludes that a requested amendment or addition is not appropriate, TuGo will notify the person requesting the amendment or addition of that fact and maintain a record of the requested amendment or addition.
6.3 Where required by law or otherwise appropriate, TuGo will communicate amendments of or additions to personal information to third parties.
Principle 7 – Security Safeguards
7.1 TuGo shall protect personal information by security safeguards that are appropriate given the sensitivity of the information.
7.2 TuGo shall take appropriate and reasonable steps to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction.
7.3 TuGo shall take appropriate and reasonable steps to protect personal information disclosed to third parties, for example by contractual agreements stipulating the confidentiality of the information and the purposes for which it may be used.
Principle 8 – Openness
8.1 TuGo shall make available to individuals specific information about its policies and practices relating to the management of personal information, including:
- the name and address of TuGo’s Privacy Officer or other person to whom inquiries or complaints can be forwarded;
- the means of gaining access to personal information held by TuGo; and
- the procedure for requesting amendments to personal information.
Principle 9 – Individual Access
9.1 Upon request, TuGo shall inform an individual of the contents, use and disclosure of his or her personal information, at a minimal or no cost to the individual. An affected individual shall be able to challenge the accuracy and completeness of the information and to request its amendment in accordance with Principle 6 above.
9.2 In certain situations and where permitted by law, TuGo may not provide access to some or all of the personal information that it holds about an individual. For example, TuGo may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of an individual. TuGo may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a law. If access to personal information is not provided TuGo shall, upon request, provide the reason for denying access.
9.3 In order to protect personal information, an individual may be required to provide identification sufficient to satisfy TuGo that it may properly provide the individual with access to personal information.
9.4 Individuals may request access to their personal information by contacting the Privacy Officer or another designated representative of TuGo.
9.5 TuGo will endeavour to respond to all requests within 30 days or, in any event, within the time limit required or permitted by applicable law.
Principle 10 – Handling Inquiries and Challenges
10.1 An individual may address a challenge concerning compliance with the above Principles or any applicable privacy law or regulation to the Privacy Officer or another designated representative of TuGo.
10.2 TuGo shall maintain procedures for addressing and responding to all inquiries or complaints from individuals about TuGo’s handling of personal information.
10.3 TuGo shall, upon request, inform affected persons about the existence of these procedures as well as the availability of complaint procedures.