CapitalProtect – Privacy Policy

This Privacy Policy explains how CapitalProtect, operated by Smail Benyassine, Life Insurance and Accident & Sickness Insurance Advisor licensed in Ontario (FSRA licence #25239874) (collectively “we”, “us”, “our”), collects, uses, discloses, and protects personal information when you use our website www.CapitalProtect.ca or otherwise interact with us.

We are committed to protecting your privacy and to handling personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA). As a life and accident & sickness insurance advisor regulated by the Financial Services Regulatory Authority of Ontario (FSRA), we are also required to maintain appropriate safeguards for consumer information.

By using our Site or providing personal information to us, you consent to the practices described in this Privacy Policy.

1. Scope of this Policy and Accountability

This Policy applies to personal information that we collect in the course of operating our Site and providing Life, Accident & Sickness insurance, and insurance-based segregated fund products and services.

As an independent advisor, our regulatory and licensing parterships are structured through our managing general agency (Experior Financial Group Inc.) and our sponsoring insurance carrier (Beneva Inc.). Our regulatory and contractual obligations require us to share client information with them for purposes of supervision, compliance, and commission processing. The ultimate insurer or segregated fund company you contract with is a separate entity and is primarily accountable for the protection of the information in your policy files.

2. What is “Personal Information”?

“Personal information” means information about an identifiable individual, such as your name, contact details, date of birth, financial or health-related information used for insurance needs analysis and underwriting. Because insurance often involves sensitive financial and health information, we treat such data with a high level of protection.

3. Legal Framework and Principles

We manage personal information in line with the 10 fair information principles under PIPEDA: accountability, identifying purposes, consent, limiting collection, limiting use/disclosure/retention, accuracy, safeguards, openness, individual access, and challenging compliance. We maintain a documented privacy program and designate a Privacy Officer responsible for compliance.

4. What Personal Information We Collect

We limit collection to what is necessary for our defined purposes. Depending on how you interact with us, we may collect:

Identification and Contact Information: Name, address, email address, phone number.
Insurance and Financial Information: Date of birth, family situation, income, assets/liabilities relevant only to insurance and savings needs, and existing insurance coverage.
Health-Related Information (Sensitive): Information about your health status, lifestyle, and medical history as required strictly for insurance underwriting and risk assessment.
Website and Technical Information: IP address, browser type, device type, pages viewed, and usage patterns (via cookies, see Section 8).
Marketing Preferences: Your consents for receiving emails or other commercial electronic messages (CEMs).

5. How We Collect Personal Information

We collect personal information directly from you (e.g., when you fill out a quote form or request a consultation), through our Site (using cookies and analytics), and from third parties, with your consent (e.g., insurance carriers, paramedical providers, or other financial professionals).

6. Why We Collect and Use Personal Information (Purposes)

We may use your personal information to:

Assess Needs and Provide Recommendations: Perform insurance needs analysis, prepare applications for insurance or segregated fund products, and provide ongoing advice related only to the insurance products and segregated fund contracts we service and sell.
Underwriting and Policy Servicing: Submit applications, assist insurers with underwriting, maintain policy records, and support policy changes, renewals, and claims-related assistance.
Compliance and Risk Management: Satisfy regulatory requirements under FSRA, insurance legislation, and anti-money laundering rules.
Marketing and Communications (with consent): Send newsletters, educational content, and other commercial electronic messages where you have provided consent, in compliance with CASL.
Website Operation and Improvement: Monitor Site performance and improve user experience.

7. Consent and Your Choices

We obtain your consent before collecting, using, or disclosing your personal information, except where required or permitted by law. Consent may be express (e.g., checking a box online) or implied (e.g., voluntarily providing basic information for a quote). For sensitive information, such as detailed health information, we always obtain express written or electronic consent.

You have the right to withdraw your consent, subject to legal or contractual restrictions. Withdrawing consent may limit our ability to offer or obtain products or services for you.

8. Cookies and Similar Technologies

Our Site uses cookies to facilitate basic functionality and analyze general usage patterns.

For technologies that are not strictly necessary for the Site's operation (e.g., performance or marketing analytics), we will obtain your express, opt-in consent through a cookie banner or preference center upon your first visit. You can manage these preferences or configure your browser to refuse cookies at any time, although some Site features may not function properly.

9. How We Share Personal Information

We do not sell, rent, or trade your personal information. We may share information only as necessary and appropriate:

With Insurers, MGAs, and Financial Institutions:To submit applications, obtain underwriting decisions, issue policies, and administer benefits. To ensure regulatory supervision and compliance, we share necessary information with our managing general agency (Experior Financial Group Inc.) and our sponsoring insurer (Beneva Inc.) for oversight, compliance, and record-keeping purposes.
With Service Providers: IT hosting, email, cloud storage, and analytics platforms. These providers are contractually required to protect the information.
Cross-Border Transfers: Given our reliance on global service providers for IT hosting, email, and cloud storage it is highly likely that your personal information, including contact details and policy notes, will be transferred to and stored in the United States and other foreign jurisdictions. When information is transferred outside Canada, it is subject to the laws of those jurisdictions, including lawful access by foreign governments, courts, and law enforcement.
As permitted or required by law: To comply with subpoenas, court orders, or regulatory requests.

10. How We Protect Personal Information

We use physical, organizational, and technological safeguards appropriate to the sensitivity of the information, including: restricted access, password-protected systems, and secure cloud services. We follow the principles in PIPEDA and guidance from Canadian privacy regulators regarding security and breach management.

If we become aware of a privacy breach that poses a real risk of significant harm, we will notify the Office of the Privacy Commissioner of Canada and affected individuals, as required by law.

11. Retention and Destruction

We retain personal information only for as long as necessary to fulfill the purposes identified in this Policy and to meet our legal, regulatory (FSRA), and contractual obligations. When information is no longer required, we securely destroy, delete, or anonymize it.

12. Electronic Communications and CASL

When we send you Commercial Electronic Messages (CEMs, such as newsletters or promotional content), we comply with Canada’s Anti-Spam Legislation (CASL).

All CEMs require your express or implied consent.
In addition to obtaining consent and providing an unsubscribe mechanism, all commercial electronic messages will clearly state the name of Smail Benyassine (Advisor) and our contact information (mailing address or phone/email), as required by CASL.
You can withdraw your consent at any time by using the simple unsubscribe link in our messages or by contacting us directly.

13. Your Rights: Access, Correction, and Complaints

Subject to certain legal exceptions, you have the right to request access to your personal information, request corrections to incomplete or inaccurate information, and make a complaint if you believe your privacy rights have been violated. Requests must be made in writing using the contact details below.

14. Contacting Our Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact:

Privacy Officer: Smail Benyassine, CapitalProtect.
Mailing address: 207 Bell Street N, Unit 902, Ottawa, ON, K1R 0B9.
Phone: 343-463-6406.
Email: capitalprotectcanada@gmail.com

15. Complaints to Regulators

If you are not satisfied with our response to a privacy-related inquiry or complaint, you may contact:

Office of the Privacy Commissioner of Canada (OPC)
For issues related to the conduct of life and health insurance advisors and consumer protection, you may also contact: Financial Services Regulatory Authority of Ontario (FSRA)