Privacy Policy

1. About This Policy

This Privacy Policy describes how Safe Crest Insurance Inc. ("Safe Crest," "we," "us," or "our") collects, uses, discloses, and protects personal information through this website (www.safecrest.ca) and any digital tools hosted or linked from it, including our online life insurance needs analysis tool.

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We are committed to complying with the federal Personal Information and Electronic Documents Act (PIPEDA), the Personal Information Protection Act (Alberta) (PIPA), the Personal Information Protection Act (British Columbia) (BC PIPA), and the Canadian Anti-Spam Legislation (CASL).

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When you give us your consent, for example by ticking a box or submitting a form after reading a notice, we collect, use and disclose your personal information as described in this policy. Where the law permits, we may also rely on implied consent. You can withdraw your consent at any time (see Section 12).

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2. Who We Are

Safe Crest Insurance Inc. is an independent life and benefits brokerage licensed to sell life, disability, and group benefits insurance in Alberta and British Columbia.

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For individual life insurance and standalone disability insurance, we work with multiple Canadian insurers through our Managing General Agency (MGA) relationship with HUB Financial Inc.

For group benefits, we hold direct broker-of-record contracts with Canadian insurance carriers and place coverage with them directly, without an intermediary MGA.

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For privacy inquiries, you may contact us at:

Privacy Officer: Patrick Hardie, Safe Crest Insurance Inc. (responsible for our compliance with this policy)

Calgary, Alberta

Email: info@safecrest.ca

Phone: 403.303.2974

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3. What Personal Information We Collect

We may collect the following categories of personal information through our website, contact forms, and digital planning tools:

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3.1 Contact and identity information

• Full name

• Email address

• Phone number

• Province of residence

• Date of birth, sex, and smoking status (when you use the Propel quote tool described in Section 5.2)

• The purpose and amount of coverage you are considering (when you use Propel)

3.2 Financial and planning information

When you use our online life insurance needs analysis tool, you may voluntarily provide:

• Annual income and household income details

• Age and retirement planning assumptions

• Mortgage balance, debt obligations, and savings information

• Existing insurance coverage amounts

• Business ownership and corporate structure details (for incorporated owners)

• Estate and legacy goals

This information is used solely to generate a personalized insurance needs estimate within the tool. See Section 5 for details on how this data is handled.

3.3 Communication and consent information

• Your consent status for electronic communications (CASL)

• Notes or messages you provide in contact forms or planning tool fields

• Your answer to the optional "How did you find Safe Crest?" question on the Let's Talk form. We use it only to understand which content leads people to contact us and to respond to your inquiry. We keep it with your inquiry record for as long as we keep that record.

3.4 Technical and usage information

When you visit our website, we or our service providers may automatically collect:

• IP address and browser type

• Pages visited and time spent on the site

• Referring website or search query

• Device type and operating system

This information is collected through web analytics, session analytics, and advertising tracking tools described in Sections 7.4 and 9. Some of this information (for example, data collected by the Meta Pixel) may be used to build audiences for digital advertising campaigns and to show you relevant ads on third-party platforms such as Facebook and Instagram. It is not used to determine your identity on our website unless you voluntarily provide contact information through a form or planning tool.

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4. How We Collect Personal Information

We collect personal information through:

• Contact forms on our website

• Our online appointment booking form (Zoho Bookings)

• Our online life insurance needs analysis tool

• The Propel quote tool provided by Life Design Analysis (see Section 5.2)

• Email, telephone, or in-person communications you initiate

• Third-party insurers, MGAs, or other professionals you authorize us to contact on your behalf

• Cookies and web analytics tools (see Section 9)

We collect personal information only with your knowledge and consent, or as required or permitted by law.

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5. Our Online Planning Tools

5.1 Life insurance needs analysis tool

Safe Crest provides an online life insurance needs analysis tool to help individuals estimate their insurance coverage requirements. This tool is hosted on our website platform, Wix (see Section 7.1 for details).

When you use this tool:

• The financial and planning information you enter is processed within your browser session to generate your personalized estimate.

• If you provide your name, email address, phone number, and your consent to be contacted, this contact information, along with a summary of your coverage estimate and your CASL consent selections, is transmitted to Safe Crest and stored in our CRM system, Cloven. See Section 7.2 for details on this data flow and Section 13 for details on the three separate CASL consent categories (contact, SMS, and marketing) that you can grant independently.

• A copy of session data may be temporarily stored in your browser's local storage. This data remains on your device and is not accessible to Safe Crest. You can clear it by clearing your browser's local storage or browsing data.

• Your contact details are only transmitted to Safe Crest when you explicitly grant contact consent. Without that consent, you can still complete the full needs analysis and view your results. No contact information is sent to Safe Crest.

• The detailed financial inputs you enter (income, debts, savings, etc.) are used only to calculate your estimate within the tool and are not transmitted to or stored by Safe Crest on our servers unless you expressly submit your contact information.

5.2 Propel quote tool (Life Design Analysis)

Our Quotes page links to Propel, a life insurance tool provided by Life Design Analysis. Propel asks for your first and last name, phone number, email address, date of birth, sex, province and smoking status, and for the purpose and amount of coverage you are considering. It uses this information to show you options and emails you a copy of your results. We need your date of birth, sex and smoking status because premiums are calculated from them.

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Safe Crest is responsible for the information you submit in Propel. Life Design Analysis hosts it on our behalf and states that it stores and backs it up in Canada. Some processing, such as sending your results by email, may involve other service providers. Life Design Analysis's own privacy policy covers its website, and it may handle limited technical information, such as device and usage data, under that policy.

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Safe Crest receives your submission and uses it to respond to your inquiry and, if you choose to proceed, to assess and arrange coverage. We may contact you by phone or email about your results. We will not add you to a marketing list without your separate consent. We keep submissions for 24 months after the last time you or we communicated about your inquiry, then delete them, unless we are required by law or regulation to keep them longer. You can withdraw your consent, or ask us to access, correct or delete your information, at any time (see Section 12). Please enter only what you are comfortable sharing.

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6. How We Use Your Personal Information

We use personal information for the following purposes:

• To respond to your inquiries and provide insurance planning advice

• To assess your insurance needs and recommend appropriate coverage

• To prepare and submit insurance applications on your behalf, where authorized

• To communicate with insurers, MGAs, and other professionals involved in your coverage

• To send you information about products and services that may be relevant to your needs, where you have consented

• To comply with legal, regulatory, and contractual obligations

• To improve our website and digital tools

We will not use your personal information for any purpose other than those identified above without your consent, or as required by law.

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7. Third-Party Service Providers and Data Transfers

In the course of operating our website and digital tools, we use the following third-party service providers. Where noted, some providers process data outside Canada.

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7.1 Website and planning tool hosting: Wix

Our main website (www.safecrest.ca) and our online life insurance needs analysis tool are hosted on Wix, a cloud-based website platform. Wix may process data on servers located outside Canada, including in the United States. Wix's privacy practices are governed by their Privacy Policy, available at www.wix.com/about/privacy.

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7.2 Lead transmission and CRM: Zoho (Cloven)

Our customer relationship management system, Cloven, is our instance of Zoho CRM. When you submit your contact information through our planning tool or contact forms, that information is transmitted to Safe Crest and stored in Cloven. Data handling for this process is as follows:

• Planning tool: information you submit through our online life insurance needs analysis tool is sent directly to Zoho (through Zoho Flow) and stored in Cloven.

• Contact form: information you submit through our contact form is sent directly to Zoho (through Zoho Flow) and stored in Cloven.

• Storage: Cloven hosts all stored data on Canadian servers. Personal information stored in our CRM remains within Canada and is subject to Canadian privacy law.

Appointment booking: When you book an appointment through our website, Zoho Bookings, part of the Zoho service we use for our CRM (Cloven), collects your name, email address, mobile number, the date, time and type of appointment, and whether you ticked the optional text-reminder box. This information is stored in Cloven in Zoho's Canadian data centre. We use it to schedule and confirm your appointment, to email you a calendar invitation and a Microsoft Teams meeting link (Microsoft provides Teams and also hosts our email), and, only if you ticked the box, to text you about your appointment (see Section 7.7). We use your mobile number for texts only if you ticked that box.

We have taken reasonable steps to ensure that our lead transmission and CRM providers handle your personal information in a manner consistent with Canadian privacy requirements.

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7.3 Insurance Carriers and MGAs

For individual life insurance and standalone disability insurance, Safe Crest conducts business through HUB Financial Inc. as our Managing General Agency. Personal information related to insurance applications and policy administration for these lines of business may be shared with HUB Financial and the insurers we work with. HUB Financial is subject to its own privacy obligations under PIPEDA.

For group benefits business, Safe Crest has direct broker-of-record relationships with Canadian insurance carriers. When you or your employer apply for group coverage, relevant personal information is shared directly with the applicable carrier to underwrite, issue, and administer the policy. Each carrier is subject to its own privacy obligations under PIPEDA and applicable provincial law.

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7.4 Analytics and Tracking Tools

Our website uses the following analytics and tracking tools to help us understand how visitors use the site, improve the user experience, and (where applicable) support digital advertising:

• Google Analytics 4 (GA4): collects anonymized usage data including pages visited, time on site, referring source, device type, and general geographic location. Data is processed by Google on servers outside Canada.

• Microsoft Clarity: provides session replay and heatmap analytics to help us understand how visitors interact with our pages. Clarity is configured with "Strict" content masking, which automatically obscures text entered into form fields and other sensitive elements. Data is processed by Microsoft on servers outside Canada.

• Meta Pixel (Facebook Pixel): enables us to measure the performance of advertising campaigns and to build audiences for retargeting on Meta platforms (Facebook and Instagram), if and when we run such campaigns. Data is processed by Meta on servers outside Canada.

You can opt out of these tools as described in Section 9.

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7.5 Client files and document storage: Microsoft 365

Safe Crest uses Microsoft 365 (including Outlook, OneDrive, and SharePoint) to manage client files, correspondence, and documents related to insurance applications, policy administration, and ongoing client service. Our Microsoft 365 tenant is configured with Canadian data residency, meaning the core client data stored in these services is hosted in Microsoft's Canadian data centers and remains within Canada.

Some Microsoft 365 services (such as email anti-spam scanning, threat protection, and certain administrative diagnostics) may process metadata or message content outside Canada as part of Microsoft's global service operations. Microsoft is bound by its own privacy obligations and contractual commitments, which are detailed in their privacy documentation available at privacy.microsoft.com.

Safe Crest does not store client files on local computer hard drives. All client files are stored within the Microsoft 365 environment, with access limited to authorized personnel.

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7.6 Adobe Acrobat and E-Signature Services

We use Adobe Acrobat Pro to prepare insurance application documents and to collect electronic signatures from clients during the application process. In the Canadian life insurance industry, accepted electronic signature platforms are limited, and Adobe Acrobat is one of the platforms our carriers and managing general agencies recognize for binding signatures on insurance applications.

When you sign or review documents through Adobe Acrobat in connection with our services, your information, including the documents themselves, your signature, and associated metadata such as IP address and timestamps, is processed and stored by Adobe Inc. on infrastructure located in the United States. Adobe has confirmed in writing that, for Canadian customers, Document Cloud content is stored in Adobe's AWS US-East 1 data center in Virginia, USA.

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This means that personal information you provide through Adobe-hosted documents may be subject to United States laws, including laws permitting government access for national security or law enforcement purposes. We rely on Adobe's published security and privacy practices, including its compliance with industry-standard encryption and data protection frameworks, to protect this information during processing and storage.

If you have concerns about the use of Adobe services for your insurance application documents, please contact us before signing. Alternative arrangements may be possible in some circumstances, though signing requirements set by individual insurance carriers may limit available options.

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7.7 Twilio (SMS Communications)

If you provide express consent to receive text messages from us, your mobile phone number and the contents of any text messages exchanged between us are processed and stored by Twilio Inc., our SMS communications provider. Twilio's infrastructure for our account is located in the United States.

Twilio receives, transmits, and stores: your mobile phone number, the contents of text messages we send to you, the contents of any replies you send to us, message delivery status information, and associated metadata such as timestamps and message identifiers.

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Personal information processed by Twilio may be subject to United States laws, including laws permitting government access for national security or law enforcement purposes. Twilio publishes its privacy and security practices and maintains industry-standard data protection certifications, which we rely on to protect this information.

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If you tick the text-reminder box when booking an appointment, we send one confirmation text and up to two reminders for each appointment time, and a new set if you reschedule. If you tick the text-message box on our Let's Talk contact form, we send one thank-you text and, if you have not booked a time, one follow-up text with a booking link about 24 hours later. Texts come from 825-906-9808, identify Safe Crest Insurance Inc., and are processed and stored by Twilio in the United States, as described above.

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You may withdraw your consent to receive text messages at any time by replying STOP to any message we send, or by contacting us at info@safecrest.ca or 403-303-2974. Withdrawing SMS consent does not affect any other consents you may have provided (such as consent to receive emails or phone calls); those must be withdrawn separately if desired.

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7.8 Propel quote tool hosting: Life Design Analysis

Life Design Analysis operates and hosts the Propel quote tool on our behalf. It states that it stores and backs up our data in Canada. Some processing, such as sending your results by email, may involve service providers outside Canada. If you have questions about where your information is processed, contact us at info@safecrest.ca.

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8. Disclosure of Personal Information

We may disclose your personal information to:

• Insurers and reinsurers in connection with your insurance application or policy

• HUB Financial Inc. and other MGAs involved in administering your coverage

• Your authorized representatives, including accountants, lawyers, or financial advisors, where you have directed us to do so

• Government authorities or regulators where required by law

• Our third-party service providers as described in Section 7

We do not sell your personal information to any third party. We do not share your personal information with organizations that would use it to contact you about their own products or services without your consent.

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9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to operate the site, understand how visitors use it, and (where applicable) support digital advertising. Cookies are small text files stored on your device.

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Types of cookies and trackers we use:

• Essential cookies: required for the website to function properly, including cookies set by our website platform, Wix.

• Analytics cookies and trackers: set by Google Analytics 4 and Microsoft Clarity to measure site usage and user experience, as described in Section 7.4.

• Advertising cookies and trackers: set by the Meta Pixel. These enable Meta (Facebook/Instagram) to recognize site visitors for the purposes of advertising measurement and audience building for retargeting campaigns.

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How to opt out:

• You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the website.

• You can opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-On (tools.google.com/dlpage/gaoptout).

• You can manage your Meta advertising preferences through your Facebook or Instagram account settings, or opt out of interest-based advertising through the Digital Advertising Alliance of Canada (youradchoices.ca).

• Microsoft Clarity respects the Global Privacy Control (GPC) signal; if your browser sends this signal, Clarity will not record your session.

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10. Retention of Personal Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law or regulation.

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For insurance clients, we are required by regulatory bodies to retain records demonstrating the suitability of our recommendations for a minimum period. Contact information submitted through our website or planning tools, including Propel, that does not result in a client relationship will be kept for 24 months after the last time you or we communicated about your inquiry, to allow for follow-up, after which it will be securely deleted. Inquiries that do not become a client relationship are deleted or anonymized earlier on request.

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Booking records are kept for 24 months after our last contact with you if you do not become a client; client records follow the periods described above. Withdrawing your consent to text messages stops the texts but does not delete your booking record. Twilio keeps its own message logs under its own policies.

You may request deletion of your personal information at any time, subject to our legal and regulatory obligations. See Section 12 for how to make such a request.

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11. Security

We take reasonable organizational, technological, and physical measures to protect your personal information against unauthorized access, collection, use, disclosure, modification, or disposal. These measures include:

• Use of reputable, industry-standard hosting and transmission platforms

• Storage of client data in Canadian-hosted systems (Cloven CRM and Microsoft 365), and Propel submissions hosted by Life Design Analysis, which states that it stores and backs them up in Canada

• Limiting access to personal information to individuals who need it to perform their duties

• Using encrypted communications where available

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No method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. If a breach of security safeguards creates a real risk of significant harm, we will report it to the applicable privacy commissioner and notify affected individuals as required by law.

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12. Your Rights

Subject to certain legal exceptions, you have the right to:

• Know what personal information we hold about you and how it is used

• Access your personal information held by us

• Request correction of inaccurate or incomplete information

• Withdraw your consent to our collection, use, or disclosure of your personal information (subject to legal or contractual obligations)

• Request deletion of your personal information, subject to our retention obligations

• File a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner if you believe your privacy rights have been violated

To exercise any of these rights, please contact us at info@safecrest.ca or 403.303.2974. We will respond to your request within a reasonable timeframe.

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13. Electronic Communications and CASL

Pursuant to the Canadian Anti-Spam Legislation (CASL), we will only send you commercial electronic messages with your express or implied consent, as defined under CASL.

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When you submit our contact form, you are asked to provide consent across three separate categories:

• Contact consent: permission for Safe Crest to respond to your specific inquiry by email or phone.

• SMS consent: separate permission to receive text messages (SMS) from Safe Crest, including appointment confirmations, follow-ups, or other communications by text. Standard message and data rates may apply.

• Marketing consent: permission to receive ongoing marketing communications such as newsletters, educational content, and information about products and services that may be relevant to your needs.

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You may grant any combination of these consents, and you may withdraw any of them at any time by:

• Clicking the unsubscribe link in any email we send you

• Replying STOP to any SMS message

• Contacting us directly at info@safecrest.ca

• Calling us at 403.303.2974

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Withdrawing your consent to electronic communications will not affect our ability to send you transactional or administrative messages related to an existing insurance policy or application.

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Submitting your details through the Propel quote tool does not give us your consent to send marketing messages. We may respond to your inquiry, by phone or email, about that inquiry for six months after you submit it, in reliance on the inquiry exemption in CASL. We will not send newsletters or other marketing without your separate express consent. Every message we send identifies Safe Crest and includes an unsubscribe option.

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14. Complaints

If you have a concern about how we have handled your personal information, we encourage you to contact us first at info@safecrest.ca so we can attempt to resolve your concern.

 

If you are not satisfied with our response, you may file a complaint with:

 

Office of the Privacy Commissioner of Canada

www.priv.gc.ca  |  1-800-282-1376

 

Office of the Information and Privacy Commissioner of Alberta

www.oipc.ab.ca  |  1-888-878-4044

 

Office of the Information and Privacy Commissioner for British Columbia

www.oipc.bc.ca  |  250-387-5629

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15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last Reviewed" date at the top of this policy. If a change materially affects how we use your personal information, we will ask for your consent again where required.

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16. Children and Minors

Our services are for adults who have reached the age of majority in their province (18 in Alberta and 19 in British Columbia), and our website and digital planning tools are not directed at minors. Safe Crest does not knowingly collect personal information from minors without the consent of a parent or legal guardian. If you believe we have collected personal information from a minor without appropriate consent, please contact us at info@safecrest.ca and we will take steps to delete it.