Privacy Statement

(Last updated: April 2010)

PIPEDA
By Act of Parliament, the Federal Government of Canada passed the Personal Information Protection and Electronic Documents Act (PIPEDA), commonly referred to as Bill C-6, to deal with the issue of protecting personal information. Initially the Act applied to federally regulated private sector businesses (e.g. federal corporations, banking and telecommunications). Effective January 1, 2004 the Act applied more broadly (other than where provinces and territories have passed substantially similar legislation), to every private sector organization engaged in commercial activities in respect to how personal information is collected, used and disclosed in the course of its regular business activities.

What does this mean?
An organization must comply with a series of obligations and be accountable for compliance to ten principles set out in Schedule 1 of the Act (www.privcom.gc.ca). The office of the Privacy Commissioner is empowered to receive, investigate and remedy complaints where warranted.

Western Financial Group Insurance Solutions’ commitment to Privacy Protection
Protecting the privacy and confidentiality of personal information has always been fundamental to the way we do business and is the responsibility of every employee of Western Financial Group Insurance Solutions during the course of providing products and services to our clients. The range of products and services we offer our groups and benefit plan participants continues to expand along with the technology we use for their delivery and storage. No matter how our business changes, we remain committed to protecting and respecting your right to privacy and confidentiality.

With particular reference to PIPEDA, we have reviewed and where needed, revised our current privacy policies and information handling procedures, having developed a Privacy Code which appears below. This to further safeguard the use and handling of essential personal information obtained with the express consent of our clients and only for the purpose for which consent was granted when this information was collected.

The information contained on this Web site is subject to change without notice. While all reasonable efforts are made on an ongoing basis to ensure the current accuracy of this site, Western Financial Group (Network) Inc. (Western Financial Group Insurance Solutions) cannot guarantee the accuracy or timeliness of the information provided.

Clients are assured that Western Financial Group Insurance Solutions is focused on respecting your privacy and maintaining confidentiality of information. We have safeguards in place to protect your personal, business, and financial information which adheres to the Ten Privacy Principles as covered by the Personal Information Protection and Electronic Document Act (www.privcom.gc.ca).

Principle 1 - Accountability
Principle 2 - Identifying Purposes
Principle 3 - Consent
Principle 4 - Limiting Collection
Principle 5 - Limiting Use, Disclosure and Retention
Principle 6 - Accuracy
Principle 7 - Safeguarding Customer Information
Principle 8 - Openness
Principle 9 - Customer Access
Principle 10 - Handling Customer Complaints and Suggestions

The collection of personal information through our Web site is important. It is limited to the details that are needed to provide our programs and services that best meet your needs and to assess your future needs. Most of that information is obtained from you but it might also come from other third parties. By example, information about you may be used:

• For on going customer service and other contact matters
• In connection with our offering and delivery of products and services
• To obtain claims history
• To prevent fraud
• To share or exchange reports and information with any corporation or enterprise with whom you have a financial relationship
• For billing and accounting services related to your business activity with Western Financial Group Insurance Solutions
• To comply with legal and regulatory requirements

We may store so called “cookies” on your computer when you visit our Web site. This allows us to recognize your computer the next time you visit us. Most Internet browsers are set to accept these cookies automatically. The type of information we collect as a result of a cookie is specific to your computer and may include the Internet Protocol (IP) address, the date and time you access our Web site and what parts of the Web site are visited. We collect the foregoing information to monitor the usage and usefulness of our Web site, and for statistical purposes. You may set your browser to notify you when you receive a cookie or to refuse receiving it. Be aware that in such event you may no longer be able to use all the possibilities of our Web site.

We may ask for information which identifies you personally (e.g. name, policy number) when you contact us by e-mail or if you complete an online questionnaire or form. Personal information is collected only for its intended purpose and is not disclosed to any other parties without consent of the individual.

Links to or from other Internet Web sites outside the Western Financial Group Insurance Solutions Web site are provided for convenience only. You access these sites at your own risk as Western Financial Group Insurance Solutions cannot guarantee that these links are functional or secure. Their content is neither reviewed nor approved by Western Financial Group Insurance Solutions. Western Financial Group Insurance Solutions cannot be held responsible for damages or prejudice of any nature resulting from the use or the content of the other site(s) connected to this site by hyperlink.

If you would like further information about privacy and security when using our Web site, please contact us at privacy@westernfinancialgroup.net. In addition you may request this information by writing to our corporate office at the following address:

Western Financial Group
Group Insurance Solutions
777 Portage Avenue
Winnipeg, Manitoba
R3G 0N3
Attention: Privacy Officer

There is no charge to access your information unless you request copies of records, in which case you will be advised in advance. If you find that your information is inaccurate or incomplete, we will make changes to our records accordingly.