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PRIVACY POLICY.

Respecting the privacy and confidentiality of your personal information is important to LGM Financial Services Inc. and its affiliates (“LGM”, “we”, “us”, and “our”).

This Privacy Policy explains how LGM collects, uses and discloses your personal information in the course of conducting business, and otherwise interacting, with you.

In order to build a lasting relationship with you, and to provide you with products, content and services you might request, we need to collect certain information from you. The information that we may request about you from time to time varies and will depend on the desired product, content, or service or will otherwise depend on how you would like to interact with us, such as by accessing one of our websites.

The term “personal information” refers to any information about you or any information that allows you as an individual to be identified. In general, personal information does not include business contact information, such as your name, title or position, business address, business telephone or fax number in your capacity as an employee of an organization.

During your relationship with LGM, you may be asked to provide certain personal information. For example, you may be asked to provide (i) your name, address, age, personal email and personal telephone number, (ii) credit card and other financial information and (iii) certain other information that specifically identifies you as an individual.  Your computer or mobile device may also be asked to provide (i) your internet protocol address, (ii) specifications of your internet browser and your operating system, and (iii) certain other information that specifically identifies you and your individual website interactions.

LGM collects, uses and discloses your personal information with your knowledge and consent (which may be either express or reasonably implied from our business relationship or the circumstances) and only for purposes that we have identified prior to or at the time we collect the information.

By accessing one of our websites or by requesting products, content or services from us, you consent to the following purposes for which LGM may collect, use and disclose your personal information:

  • To establish and facilitate communication with you;
  • To understand your needs;
  • To provide you with products, content and services and to respond to any related inquiries;
  • To assess your eligibility for products, content and services;
  • To confirm your quote, application information or purchase, if applicable;
  • To investigate and settle your claims, and determine your eligibility for benefits as applicable;
  • To collaborate with automobile dealers and repair facilities that submit claims on your behalf; 
  • To respond to your requests to receive our newsletter, book a software demo or be considered for job opportunities; 
  • To provide you with access to My Distinction Learning content; 
  • With your express consent, to electronically provide information about our products, content, services, and promotions that may be of interest to you;
  • To meet our legal obligations to regulatory bodies; 
  • To meet our contractual obligations to the automobile equipment manufacturer that provides your products and/or the insurance company that underwrites your products;
  • To comply with our corporate policies, including our document retention policy;
  • To develop and optimize our sites, products, content, services, communications, systems and databases;
  • Subject to your rights related to Cookies (as explained below), to collect and aggregate data about how you interact with our websites, products, content, services and business;
  • To advise you of changes to any existing products, content, services or programs;
  • To provide relevant information to the automobile equipment manufacturer that provides your products, the automobile dealer that distributes your products, and/or the insurance company that underwrites your products; 
  • To operate our business with the assistance of relevant third party providers;
  • To collect unpaid balances from you, whether directly or by a third party collection agency; 
  • To investigate any complaints that you submit about how we conduct our business;
  • To detect and prevent fraud, and
  • To otherwise administer our relationship with you and for any other purpose for which we have your consent.

By submitting your personal information to LGM, you are affirming your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, please do not provide any personal information to us and we must regrettably ask you to stop using our websites. Of course, certain products, content and services can only be offered to you if you provide personal information to LGM, and therefore LGM may not be able to offer you those products, content or services if you choose not to provide us with required personal information.

LGM maintains this website and related websites (the “LGM Website”) to keep you informed about our products, content, services and business.  The LGM Website also allows you to access our social media feeds, register for training courses, register for access to My Distinction Learning content, pursue job opportunities, sign-up for our newsletter, book software demos, and get in contact about your feedback.

When you access the LGM Website, we may use cookies and other standard internet technologies (“Cookies”) to provide you with an enhanced user experience.  Cookies are small text files placed on your device when you visit a website that allow you to be identified when you return to a website and allow content to be displayed for you based on your past selections.  By visiting the LGM Website, you are providing your consent for us to use Cookies.  If you do not consent to our use of Cookies, we encourage you to change your browser preferences before you continue using the LGM Website.

We have integrated a number of third party technologies into the LGM Website to provide you with an enhanced user experience.  We have described these technologies below.  The technologies and the service providers we select for these technologies may change over time.  If you do not consent to third party technology providers collecting your personal information, we regrettably ask you to stop using the LGM Website.  If you do not consent to third party technology providers using Cookies, we encourage you to change your browser preferences before you continue using the LGM Website.

External Websites
We have integrated icons into the LGM Website to allow you with easy access to LinkedIn, Facebook, Twitter, Gmail, Yahoo Mail, AOL Mail, Outlook, PayPal and other third party services (the “External Website”).  If you click on an icon for the External Website, you are providing your consent for us to redirect you to the External Website and your use of the External Website will be subject to the terms of service posted on the External Website.

We want you to be aware that the External Website may collect information about you and may place Cookies on your device when you access the External Website from the LGM Website.  The External Website is subject to the terms of service posted on the External Website.  We do not control how the provider of the External Website uses your personal information or uses Cookies, which may monitor your movement between websites or bring advertising to you.  The provider’s use of your personal information and Cookies will be subject to the privacy policy posted on the External Website.

Widgets
We have also integrated a Twitter widget into the LGM Website to allow you to follow our Twitter feed and, in future, we may integrate other third party widgets into the LGM Website (the “Widget”).  When you access the LGM Website, your device automatically loads the Widget.  By visiting the LGM Website, you are providing your consent for us to load the Widget on your device.

We want you to be aware that the Widget may collect certain information about you and may place Cookies on your device.  The Widget is subject to the terms of service posted on the website of the provider of the Widget.  We do not control how the provider of the Widget uses your personal information or Cookies, which may monitor your movement between websites or bring advertising to you.  The provider’s use of your personal information and Cookies will be subject to the privacy policy posted on the website of the provider of the Widget.

Google Analytics
We have enabled Google Analytics for the LGM Website to collect general information about you and how you interact with the LGM Website.  When you access the LGM Website, you are providing your consent for Google Inc. or one of its affiliates (“Google”) to use Cookies that provide us with analytics about you, how you reached the LGM Website, how you interact with the LGM Website and how you browse between websites.  By visiting the LGM Website, you are providing your consent for us to use Google Analytics to monitor your interactions with the LGM Website.

We want you to be aware that Google may collect certain information about you and may place Cookies on your device.  Google Analytics is subject to the terms of service posted on the Google website.  We do not control how Google uses your personal information or uses Cookies, which may monitor your movement between websites or bring advertising to you.  Google’s use of your personal information and Cookies will be subject to the privacy policy posted on the Google website.

The LGM Website provides you with a number of forms that allow you to get in contact with us.  If you click to submit a form on the LGM Website, you are providing your consent for us collect any personal information you to choose to share with us and for us to use and disclose that personal information to respond to your enquiries, register you for training courses, register you for access to My Distinction Learning content, consider you for job opportunities, sign-up for our newsletter, book software demos, investigate your complaints, and as otherwise permitted by this Privacy Policy.   

If you provide us with your personal contact information via the LGM Websiteyou are providing your consent for us to respond to you via that information.  If you choose to provide us with your email address or your telephone number, you are providing your express consent for us to send you electronic communications about your enquiry or feedback.  If you also check a box to opt-in to receive electronic communications about our products, content, services and promotions, you are providing your express consent for us to send you electronic communications about our products, content, services and promotions from time-to-time.  You can always contact us to unsubscribe from opt-in electronic communications.  We may, however, need to contact you using your personal information to provide you with, or to administer, products, content and services that you have purchased or requested. 

If you choose to provide us with your email address via the LGM Website, you are providing your consent for us to respond to your enquiry or feedback, or to contact you as authorized by your opt-in preferences, using a third party online marketing platform provided by The Rocket Science Group LLC d/b/a MailChimp or another third party provider (the “Email Provider”).  We want you to be aware that the Email Provider may collect certain information about you, may store your email address on its servers and may place Cookies on your device.  The Email Provider will collect information and use Cookies subject to the terms of service posted on the Email Provider’s website.  We do not control how the Email Provider uses your personal information or uses Cookies, which may monitor your interactions with email campaigns or bring advertising to you.   The Email Provider’s use of your personal information and use of Cookies will be subject to the privacy policy posted on the Email Provider’s website.

LGM maintains the HUB platform (the “HUB Platform”) to allow authorized representatives of certain automotive dealerships to sell consumers certain finance and insurance products that we administer.  If you are an authorized user, the HUB Platform also allows you to access sales tools, access training tools, register for training courses and get in contact about your feedback.  When you access the HUB Platform, the terms and conditions of this Privacy Policy will apply to any personal information that you upload to or download from the HUB Platform.  By visiting the HUB Platform, you agree to use personal information in accordance with the terms and conditions of this Privacy Policy.

If you choose to opt-in via the HUB Platform to receive communications from LGM, you are providing your consent for us to display communications in your internet browser using a third party push notification platform provided by OneSignal, Inc. or another third party provider (the “Push Notification Provider”). We want you to be aware that the Push Notification Provider may collect certain information about you, may store certain information about you on its servers and may place Cookies on your device.  The Push Notification Provider will collect information and use Cookies subject to the privacy policy posted on the Push Notification Provider’s website. We do not control how the Push Notification Provider uses your personal information or uses Cookies, which may monitor your interactions with the HUB Platform and third party websites, gather analytics about your internet use or bring advertising to you. The Email Provider’s use of your personal information and use of Cookies will be subject to the privacy policy posted on the Push Notification Provider’s website. 

LGM creates proprietary My Distinction Learning content (the “My Distinction Content”) that it may, in its sole discretion, allow authorized representatives of automotive dealerships to access and learn about  topics of relevance to their businesses, including finance and insurance products that we administer.  If you register for access to the My Distinction Content, you authorize us to email you with log-in details for accessing that content using a third party learning management platform (the “Learning Platform”) provided by Absorb Software Inc. or another third party provider (the “Learning Platform Provider”). 

If you log into the Learning Platform, your access to and use of the Learning Platform will be subject to the software terms and conditions posted by the Learning Platform Provider on its website.  By accessing the Learning Platform, you are agreeing to comply with those terms and conditions, you are consenting to the use of your personal information in accordance with the Learning Platform Provider’s privacy policy and you are agreeing to use the My Distinction Content for your personal learning in accordance with the Legal Notice posted on LGM’s website and any other terms of use that may be provided to you by LGM.   

We want you to be aware that the Learning Platform Provider may collect information about you and may place Cookies on your device when you access and use the Learning Platform.  The Learning Platform Provider may use Cookies to monitor your use of the Learning Platform, gather analytics about your internet use or bring advertising to you.  The Learning Platform Provider’s use of your personal information and Cookies will be subject to the privacy policy of the Learning Platform Provider. 

We strive to limit the amount of personal information we collect to the minimum amount that is necessary and appropriate for the purposes explained in this Privacy Policy. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as explained in this Privacy Policy.

We will not sell, trade, lend or otherwise voluntarily disclose to any third parties any personal information that you have provided to us for any purpose not identified under this Privacy Policy. We may share your personal information with reputable third parties to assist us in administering products, content or services which you have purchased or requested and to our professional advisors or otherwise for legitimate and reasonable purposes connected with our business and for which we have obtained your prior consent in this Privacy Policy. For example, we may share your personal information with the original equipment manufacturer, underwriter, credit bureau or such other third party service providers connected with our business as are reasonably necessary for the purposes of carrying out the administration of products, content and services that you have requested. 

LGM may disclose your personal information to a government or regulatory entity that has asserted its lawful authority to obtain the information or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information. LGM may also disclose personal information as otherwise required or permitted by applicable law.

In some jurisdictions, you may withdraw your consent to the use and disclosure of your personal information, or opt-out of certain uses and disclosures. To do that, please  contact our Privacy Officer as outlined below. As explained in this Privacy Policy, certain products, content or services can only be offered to you if you provide personal information to LGM, and therefore LGM may not be able to offer you those products, content or services if you choose not to provide us with required personal information. Additionally, once we have issued a contract or policy to you, you may have a limited ability to withdraw your consent until such time as the obligations under such contract or policy have been fulfilled. This is necessary since we may have a contractual obligation to provide you with products, content or service and be required to use your personal information in the normal course of handling your contract or policy, including needing to contact you in respect of any claims or for other purposes contemplated under the contract or policy.  Our Privacy Officer would be glad to discuss situations such as these with you. 

You may request access to your personal information and/or information about LGM’s collection, use and disclosure of that information by contacting our Privacy Officer, in writing, at the address identified below. Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to update that information to ensure it is complete and accurate in our systemsWe may not be able to provide you with information that is prohibitively costly to reproduce, information that contains personal information identifying other individuals, or information that cannot be disclosed for legal, security, privacy, confidentiality or proprietary reasons. 

If you are a resident of the European Union (“EU Data Subject”), you may have certain unique rights created by the European Union General Data Protection Regulation (“GDPR”).  Some of the key privacy protections are created by GDPR for EU Data Subjects are as follows:

  • You can access, correct, update or request deletion of your personal information;
  • You can object to or restrict the processing of your personal information;
  • You can object to or restrict direct marketing using your personal information;
  • You can object to automated decision-making using your personal information;
  • You can request to transmit your personal information elsewhere in an accessible format;
  • You can withdraw your consent to processing of your personal information;
  • You can expect transparency from an organization about their privacy practices;
  • You can expect appropriate security measures to be implemented by an organization to protect the privacy of your personal information;
  • You can expect prompt notification from an organization if there is a privacy breach involving your personal information;
  • You can expect an organization to take reasonable steps to ask other organizations to take down your personal information that is publicly available;
  • You can expect accountability from an organization about their privacy practices;
  • You can complain to an organization’s independent data protection officer about the handling of your personal information; and
  • You can complain to a data protection authority about the handling of your personal information.

LGM does not have an establishment in the European Union and does not offer any goods or services to EU Data Subjects.  While the LGM Website does not target EU Data Subjects, the LGM Website is available globally and this Privacy Policy will apply to you if you access the LGM Website from the European Union.  If you are an EU Data Subject, we encourage you to contact us if you have any privacy questions, comments or concerns.  Our Privacy Officer would be glad to discuss these with you.

If you have any privacy questions, comments or concerns, please contact us as follows:

By email: Contact Us
By mail: Privacy Officer

LGM Financial Services Inc.
Suite 400, 1021 West Hastings St.
Vancouver, BC V6E 0C3

Version: March 31, 2020