Privacy Policy

This Privacy Policy (“Policy”) describes how Chubb Insurance Company of Canada and Chubb Life Insurance Company of Canada (“Chubb”¹) collects, uses, and discloses your information, including Personal Information, when you purchase a policy, make a claim, or use any of our products or services that link to or otherwise reference this Policy (collectively, the “Services”), or visit our websites, including www.chubb.com (the “Sites”), download our mobile applications.  

This policy does not apply to www.combinedinsurance.com (except when Combined insurance products are sold under the Breeze™ by Chubb brand), www.rainhail.com, or www.streamlabswater.com, nor to any non-Chubb websites or mobile applications that you may access via the Services. Those websites and services are governed by the privacy policies that appear on those sites and applications. Depending upon your relationship with us, you may receive other privacy notices from us providing additional detail about our privacy practices.

Your use of the Services is subject to this Policy and the Chubb Terms of Use, including applicable terms of limitations on liability and the resolution of disputes.

We collect information that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”).

As described below, we collect Personal Information directly from you, automatically through your use of the Sites and Services, and from publicly available and third-party sources. To the extent permitted by applicable law, we may combine the information we collect from publicly available or third-party sources. The Personal Information we collect varies based on your relationship with us.

Personal Information We Collect Directly From You

In order to access certain Services, we may collect Personal Information directly from you, including throughout the quoting, application, or claims handling processes. The Personal Information you provide directly to us may include:

• Identifiers and Contact Information. We may collect personal identifiers and contact information such as your name, address, email address, phone number.
• Government-Issued Identifiers. We also may collect information such as your driver’s license number, social insurance number, or other government-issued identifiers.
• Account Details. If you register an account with us, we collect information such as your email, phone number, or user ID, and password used to login to your account.
• Policy or Claims Information. This includes policy information, claim information, including materials you submit as part of your claim, information provided for roadside assistance services, or other information you choose to provide us. 
• Payment Information. If you pay a bill, we may collect information necessary to process your payment such as bank account information, billing address, and any other related information.
• Commercial Information. We may also collect information about the products, services, or coverage you purchase.
• Message Contents. We may collect your messages, email contents, or any other information you so choose to provide when interacting with our customer service or agents.
• Audio or Similar Information. If you speak with our customer service team by phone, we may collect a recording for quality assurance and training purposes.
• Preferences. We may also collect information about the types of Services you use, your communications preferences, wish lists and other preferences you may select in your account or profile. 
• Other Information. We also collect information when you complete online forms, surveys, or leave us product reviews. We also collect any other information you so choose to provide. 

Personal Information We Collect Automatically

As described below in the “Cookies and Other Tracking Mechanisms” section, when you visit our Sites or use our Services, we may automatically collect certain Personal Information, including:

• Device Identifiers. We automatically collect IP address, unique device ID, device type, browser type, location information, and information about your browser and browser language.
• Network Activity. We may also collect information related to how you interact with the Services and advertisements, such as page views, links and items clicked and other activity information, referring URL, browsing history, and other similar information. We may use analytics providers and technologies, including cookies, session replay, and similar tools, to collect this information.
• Geolocation. We may also collect geolocation information, such as physical location or movements. Additionally, depending on your device settings, if you visit our Sites or use our mobile applications, we may collect geolocation information from your IP address which links to the region you live in.

Personal Information We Collect from Other Sources

We may collect information about you through our affiliates, business partners, and vendors, including from administrators, adjusters, agents, brokers, or other representatives who provide services or products on our behalf. For example, we may collect information about your policies, including coverage or claim information, through these sources.

We may collect policy and claims data from insurance industry bodies (such as Insurance Bureau of Canada and Équité Association) and databases (such as AutoPlus, DASH, HITS, and FCSA) for policy underwriting and pricing purposes.

We may also collect information from government or consumer reporting agencies, including information about your licensing history, driving history, or credit or creditworthiness, and from other, publicly available sources.

We may collect information including medical, payroll, or other health or financial information from third parties such as health care providers or employers with your authorization for claims adjudication purposes.

We may use the Personal Information we collect for the following purposes:

• Operate Our Business. We use the Personal Information we collect to allow you to maintain your account and otherwise run our day-to-day operations.
• Provide You Products and Services. We use the Personal Information we collect to provide you with, renew or modify products and services. We also use this information to maintain your coverage and memberships, including to set up a product or service, service your policy, change your policy, handle a claim, or complete a transaction.
• Communicate With You. We use the Personal Information we collect to communicate with you about your use of our Sites and Services, to respond to your inquiries, to provide you with the information and documents you request, and for other customer service purposes.
• Evaluate and Improve Our Products and Services. We use the Personal Information we collect to evaluate, analyze, improve, and develop our products and Services, including this Site. We also use this information to tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using our Services.
• Analytics Models to Support our Business. We use the Personal Information we collect in analytics models, including actuarial, underwriting, claims, and loss control models, to facilitate and service our business (e.g., to create new products and features). We may also use this information to conduct actuarial or research studies to maintain and develop our products and Services, and to create new offerings or features. We also use this information to administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• Marketing and Advertising. We may use your Personal Information for marketing and promotional purposes, including to send you promotional communications about products, services, features, and options we believe may interest you. We may send communications via e-mail, regular mail or may send push notifications via a mobile device. We may also use your information to serve you advertisements or customized content online.
• Inferences. We may use the information we collect to better understand how you access and use our Sites and the products and Services available on our Sites, both on an aggregated and individualized basis.
• Find Locations on Request. At your request, we may use your information to obtain your location from the mobile device or the network using your device’s Global Positioning System (GPS) functionality, or directly from you. We may use your location information to help you search for information, including searching for an agent, searching for a service provider, identifying the location of an accident or identifying the location of a roadside event you are reporting. If you do not want location information used, you can disable the GPS functionality on your mobile device.
• Fraud and Security Purposes. We may use the Personal Information we collect to mitigate fraud and protect Chubb and others. We also use this information to prevent and detect fraudulent, malicious, deceptive, infringements of our policies and contracts and other potential misuse of or illegal activity relating to our products, assets, and Services.
• Legal Requirements. We use the Personal Information we collect to investigate, enforce, and apply this Policy and our Terms of Use, and to otherwise protect our own rights and interests, such as to resolve any disputes or to respond to requests from law enforcement, court orders, regulators, or other legal processes.
• Business Transfers. We may also use the Personal Information we collect and receive to consider and implement mergers, acquisitions, reorganizations, refinancing, and other business transactions, and for the administration of our general business, accounting, recordkeeping, and other legal functions.
• Other Operational and Business Purposes. We may use your Personal Information for other operational purposes, including to refer you to our third-party partners as part of a referral program, to comply with contracts related to products or services that we provide to you.

We also may use automated processes and combine or aggregate any of the information we collect through the Services or elsewhere for any of these purposes or for analyzing usage statistics and trends.

When permitted by applicable law, including in cases that require your consent, we may disclose your Personal Information to our affiliates, business partners, vendors and services providers, and others as follows:

• Affiliates, Subsidiaries, and Business Partners. We may disclose the Personal Information we collect with our affiliates, subsidiaries, and agents and brokers. Chubb also partners with other businesses to offer products and services, and we may disclose your Personal Information to those organizations, including those that play a role in insurance transactions such as other insurers, reinsurers, claims adjusters, repair shops, and other insurance or claims related companies. If required by law, we will obtain consent prior to disclosing Personal Information.
• Vendors and Service Providers. We may disclose the Personal Information we collect with vendors and service providers who perform functions on our behalf, including our affiliates and subsidiaries, some of whom may be located in jurisdictions outside Canada, and your personal information may be subject to the laws of those foreign jurisdictions, for purposes such as helping complete transactions and process payments, handling claims, servicing your policy or membership, and engaging in credit reporting. We may also disclose your information to vendors and service providers who provide website hosting, automated processes and analytics, marketing and advertising, email or other communication services, development and research or actuarial studies, customer support, and tax, accounting, and legal services.
• Insurance Industry and Other Bodies. We may disclose the Personal Information we collect with insurance industry bodies, government agencies, or consumer reporting agencies for the purposes of reporting policy, claim or payment history to industry or government databases.
• Marketing and Advertising Partners. We may also disclose your Personal Information, such as name and contact information, with our marketing and advertising partners to send you content about certain products and Services.

We also may disclose your Personal Information in the following circumstances:

• Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. We may disclose Personal Information as part of those commercial transactions (e.g., mergers, acquisitions, financings, asset sales or transfers, bankruptcy or reorganization or other similar business transactions), as well as in contemplation of such transactions (e.g., due diligence). Where possible we will do so under appropriate confidentiality agreements. Similarly, if all or part of our business, assets, or Sites are merged with or sold to another company, or as part of a bankruptcy proceeding, your Personal Information may be transferred to the surviving or acquiring company.
• In Response to Legal Process. Personal Information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to comply with the law and the reasonable requests of regulators, law enforcement or other public authorities. We also may disclose the information we collect in order to comply with a judicial proceeding, court order, or other legal process, including responding to national security or law enforcement disclosure requirements.
• To Prevent Fraud and Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy or our Terms of Use, or as evidence in litigation in which we are involved. We may also disclose Personal Information to protect our rights and the rights of others. This may include exchanging information with other companies and organizations for fraud prevention, spam/malware mitigation, and similar purposes.
• Aggregate and De-Identified Information. We may disclose aggregate or de-identified information about users with third parties for marketing, advertising, research or other purposes.
• With Your Permission. We may disclose Personal Information in other ways not described above. If we do so, we will notify you and, if necessary, obtain your consent.

Withdrawal of Consent:

Generally, you may refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time unless the use or disclosure of your personal information is necessary to provide a product or a service. Please be aware that if you withdraw your consent, we may no longer be able to provide you with insurance coverage and services. If you wish to withdraw or alter your consent, please write to the Chubb Privacy Officer.

We and our third-party service providers use cookies, pixels, tags, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device and similar information within our Services and to target advertising and content across our Services and third-party sites and services. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services. 

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within our Service.

Clear GIFs, Pixel Tags, and Other Technologies. In addition to cookies, we may also use pixel tags (sometimes called web beacons or “clear GIFs”) to collect information about you and your use of our Services. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us evaluate usage of our Services, improve our Sites, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and our third-party providers may use the information that we collect about you within our Services and on other third-party sites and services to help us and these third parties to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.).

Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“Advertising Providers”) to personalize content and display advertising within our Services. We and our Advertising Providers may use cookies, pixels tags, session replay, and other tools to collect usage and browsing information within our Services such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information such as web pages, videos and other content accessed by you. We and our Advertising Providers use this information to provide you more relevant ads and content within our Services, and to evaluate the success of such ads and content.

Do Not Track. We do not currently respond to web browser “Do Not Track” signals.

We make available several ways for you to manage choices about your Personal Information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information. 

• Cookie Settings. If you wish to prevent cookies from tracking your activity on our Sites or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Sites who disable cookies will be able to browse the Sites, but some features may not function.
• Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the Canada, you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at https://optout.aboutads.info  (Digital Advertising Alliance of Canada).  You may also download the DAA AppChoices tool (https://youradchoices.ca/en/tools)  in order to help control interest-based advertising on apps on your mobile device. 
• Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you.

Account and Profile Information. You may access, update, or correct your account and profile information at any time by logging in to your account and updating the Personal Information we maintain. We may keep a copy of your prior information for a period of time, as part of our business records and our backup data.

Our Services are not designed for children, and we do not knowingly collect Personal Information from children under the age of thirteen (13). If we learn that we have received information directly from a child who is under the age of 13, we will delete such information from our systems. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

When you use our Services, you may find links to other websites that we do not own or control. We are not responsible for the privacy practices of these other sites, including their collection of your Personal Information. You should review the terms and conditions and privacy policies of these other sites before providing your information.

We may offer blogs, online forums or other interactive features in connection with our Services that enable you to share information about the Services or other issues of interest. You should be aware that any communications you submit or post to any such interactive features on the Services may be viewable by other participants or users. By submitting or posting to such interactive features you acknowledge and agree that you have no expectation of privacy or confidentiality in the content you submit for such features, whether or not it contains Personal Information about you.

We have implemented safeguards designed to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

We retain the Personal Information we collect only as reasonably necessary for the purposes described in this Privacy Policy or otherwise disclosed to you at the time of collection. For example, we will retain certain identifiers for as long as it is necessary to comply with our tax, accounting and recordkeeping obligations, to administer certain policies and coverage, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and to comply with our legal obligations.

This Policy is current as of the Effective Date set forth above. We may change this Policy at any time and from time to time. Any amendments or modifications to this Policy will become effective immediately upon notice. We will let you know of amendments or modifications by appropriate means such as by providing the revised Policy or a summary of it in your policy documents. Your continued use of any of our Services following notice will constitute your acceptance of the revised Policy. If you do not agree with the revised Policy, do not use any of our Services.

If you have any questions or comments about this section of the Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Chubb Canada
Attention: Privacy Officer
199 Bay Street, Suite 2500
P.O. Box 139, Commerce Court Postal Station,
Toronto, ON M5L 1E2, Canada
E-mail: privacycanada@chubb.com