Legal and Compliance

Accessibility

This accessibility policy and plan outlines the policies and actions that Combined Insurance will put in place to improve opportunities for people with disabilities.

Statement of Commitment

Combined Insurance is committed to making every reasonable effort to ensure persons with disabilities are treated with dignity and respect and in a manner that respects their independence.

We are committed to meeting the needs of people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act (AODA).

Every reasonable effort will be made by Combined Insurance to provide accessibility to disabled individuals and implement procedures to facilitate accessibility. This may require alternative formats and flexible approaches.

Customer Service Policy

We developed and implemented a customer service policy that addresses the Customer Service Standards under the Integrated Accessibility Standards Regulation (O. Reg. 191/11).

Accessibility Training

We developed and deployed training on the Customer Service Standards under the Integrated Accessibility Standards Regulation (O. Reg. 191/11). This training is mandatory for all employees and sales representatives who communicate with customers.

Feedback Process

Combined Insurance has a process for receiving and responding to feedback regarding accessibility.

Accessible Emergency Information

We are committed to continue providing employees with disabilities with individualized emergency response information, in an accessible format when required.

Information and Communications

Combined Insurance is committed to meeting the communication needs of people with disabilities. We have taken steps to ensure all new websites and content on those sites conform with WCAG 2.0, Level AA.

Accessibility Plan

This multi-year plan outlines the actions that Combined Insurance will put in place to improve opportunities for people with disabilities. We will continue monitoring the accessibility acts and regulations and review this accessibility plan as necessary.

Training

We will provide training to employees on Ontario’s accessibility laws, which incorporate the requirements of the Integrated Accessibility Standards and the Human Rights Code, as it pertains to people with disabilities.

Information and Communications

We are committed to meeting the information and communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs and will provide materials in accessible formats or with communication supports upon request. This will be done in a timely manner that takes into account the person’s accessibility needs and at a cost that is no more than the regular cost charged to other persons.

Employment

We are committed to fair and accessible employment practices. We will take steps to notify the public that, when requested, Combined Insurance will accommodate people with disabilities during the recruitment, assessment and selection process.

We will inform current and new employees of our accessible employment practices and will provide supports or accommodation to employees with disabilities. Combined Insurance will develop and implement a process for documented individual accommodation plans and return to-work accommodations for employees that have been absent due to a disability.

For More Information

Questions or comments about Combined Insurance’s accessibility plans, policies and practices are welcome and appreciated. Please contact a Customer Service Representative at 1-888-234-4466 between 8 a.m. and 7 p.m. EST, Monday through Friday to express your comments.

If you wish to communicate with the Company in writing, please send the comments to the address below. You may also send the Company your comments through our website at www.combined.ca or by fax at (905) 305-8600.

Combined Insurance Company of America
P.O. Box 3720, MIP
Markham, ON L3R 0X5
Attention: Compliance Department

Complaints

1. Introduction

As part of its objectives toward the fair treatment of consumers and to foster sound commercial practices, Combined Insurance Company of America (“Combined Insurance” or “Company”) is committed to providing high quality products and services to assist Canadians with their supplemental insurance protection needs. If consumers have any concerns or complaints about the Company’s products, services or representatives, these concerns shall be handled fairly and efficiently, in accordance with the terms of this Policy.

Consumers shall be provided with a free and accessible means with which to communicate their complaint. Combined Insurance will make every effort to respond to complaints promptly, accurately and with the utmost courtesy. All complaints, whether written or oral, shall be handled in a timely, professional, and secure manner, and in accordance with applicable laws, including those laws governing the protection of personal information.

2. Purpose of the Policy

The purpose of this Policy is to provide consumers with a clear and fair procedure for dealing with their complaints. This Policy explains the process put in place by Combined Insurance to handle the receipt of consumer concerns or complaints, the delivery of the acknowledgement of receipt and notices to the complainant, the creation of the complaint file, the fair and thorough review of the complaint and the compilation of complaints for the purpose of preparing and filing reports with the appropriate provincial regulators, as required. In addition, this Policy outlines the right of the complainant to request the transfer of the complaint file to the Autorité des Marchés Financiers (“AMF”) for Québec residents or the OmbudService for Life and Health Insurance (“OLHI”) for all Canadian residents.

3. Definition of a Complaint

A complaint is as an expression of dissatisfaction from, or on behalf of, a consumer about the practices and decisions of the insurer, its representatives, or its selling intermediaries. For the purpose of this Policy, a complaint is the expression of at least one of the following three elements:

• A reproach against Combined Insurance;
• The identification of a real or potential harm that a consumer has experienced or may experience; or
• A request for a remedial action.

Combined Insurance has a multi-level complaint escalation process. Each level is further described below:

• Level 1 – Let us know; contact a Customer Service Representative at 1 888 234-4466
• Level 2 – Talk to management or send the complaint in writing
• Level 3 – Contact Combined Insurance’s Chief Complaint Officer
• Level 4 – Review by an external organization

4.  Individual Responsible for Applying this Policy

The Chief Complaint Officer (CCO) is an employee of Combined Insurance who is responsible for applying this Policy. The CCO ensures that Combined Insurance staff handling complaints are trained and provides them with the necessary information for compliance with this Policy. The CCO reviews and responds to formal complaints and serves as an intermediary with the various regulatory bodies that govern Combined Insurance with respect to dispute resolution and the handling of complaints. The CCO is also responsible for transferring the complaint file to the AMF or OLHI, as applicable, at the complainant’s request as well as for the annual reporting to the appropriate provincial regulators with regards to complaints.

5.  Dissatisfaction (Level 1)

If consumers have a concern, they should first contact a Customer Service Representative  at 1 888 234-4466 between 8 a.m. and 7 p.m. Eastern time, Monday through Friday. Most situations can be resolved quickly and easily by speaking with a Customer Service Representative. Or, consumers may communicate with the Company in writing by mail at the address below: 

Combined Insurance Company of America
P.O. Box 3720, MIP
Markham, Ontario L3R 0X5
Attention: Customer Service

Concerns can also be sent through Combined Insurance’s website at www.combined.ca under “Contact Us” or by fax at 905 305-8600.

6.  Complaints (Level 2)

If a concern or complaint cannot be quickly resolved by the Customer Service team, it will be forwarded to the department that handles and makes decisions about the subject matter outlined in the communication. The person handling the complaint will send the consumer a letter within five (5) business days to acknowledge receipt of the complaint. A written response will be sent once the complaint has been reviewed, generally within thirty (30) business days.

If this does not resolve the concern, there are additional steps that can be taken.

7.  Formal Complaints - Chief Complaint Office (Level 3)

When a concern or dispute cannot be resolved in the course of normal Company business (Levels 1 and 2), or if the consumer remains dissatisfied with the written response that has been provided, a formal complaint can be sent in writing to the Chief Complaint Officer at:

Combined Insurance Company of America
P.O. Box 3720, MIP
Markham, Ontario L3R 0X5
Attention: Chief Complaint Officer

Upon receipt of a formal complaint, the Chief Complaint Officer ensures that the concern or complaint has been handled and has gone through the escalation steps in the internal process described above, failing which the Chief Complaint Officer returns the request to the appropriate department so these steps can be followed.

If the complaint was properly escalated through the internal process, the Chief Complaint Officer will:

• Make sure the complaint process has been followed and that the complaint has been fairly considered;
• Send the consumer an acknowledgment of receipt and notice, within 5 business days. The correspondence will include a description of the complaint, specifying the real or potential harm, the reproach against the Company or the requested remedial action, the Chief Complaint Officer’s name and contact information along with a copy of this Policy. In the case of an incomplete complaint, more information will be requested. If a response is not provided within a set deadline, the complaint will be deemed to have been abandoned;
• Review and analyze the complaint in a fair and impartial manner, requesting more information if required;
• Provide the consumer with a final written response (final position letter) within 30 business days of receiving all the information necessary for the examination, explaining the outcome along with the reasons behind the decision. If the examination of the complaint cannot be completed within 30 business days, the consumer will be informed of the status and progress of the examination and provided with an approximate response date;
• The response shall include a notification of the external recourses available to consumers if they remain dissatisfied and wish to pursue or transfer their complaint file. For Québec residents, this will include a reminder that transferring the file does not interrupt the prescriptive period for civil remedies.

8.  Complaint File, Register and Regulatory Reporting

A separate file is created for each complaint received. Subject to continued compliance with applicable privacy laws, each complaint file contains the complainant’s written complaint and the defining element(s) of a complaint, as described above, all supporting documentation, information and notes, the acknowledgement of receipt and the outcome of the complaint examination process (the analysis and supporting documents), a copy of the complaint response and, if applicable, the Chief Complaint Officer’s final position letter outlining the justification behind the decision. Such records are kept in accordance with applicable laws and the Company’s record retention policy.

The information related to the complaint is entered in a complaint register and given a file number. Reports to provincial regulators are filed annually in Québec (with the AMF), detailing the number and type of complaints received. In addition, an annual report is filed with the Canadian Council of Insurance Regulators (CCIR).

9.  Complaints Transfer (Level 4)

If consumers are dissatisfied with the outcome of the handling of their complaint by the Chief Complaint Officer or the complaint examination process, they can request that the complaint file be transferred to the appropriate regulatory body or consumer organization at any time. 

For residents of Québec, the file may be transferred to the Autorité des marchés financiers (AMF) for their review (www.lautorite.qc.ca). The AMF may be reached by calling toll-free at 1-877-525-0337, via email at information@lautorite.qc.ca, or by mail:

All Canadian residents including those in Québec, may contact the OmbudService for Life & Health Insurance (OLHI) (www.olhi.ca). The OLHI is a national independent complaint resolution and information service for consumers of Canadian life and health insurance products and services. The OLHI deals with concerns about life and health insurance products and services that have not been resolved through the Company’s dispute resolution system. The OLHI can be reached by calling:

Telephone Numbers

Toll-Free Canada: 1 888 295-8112
Toll-Free Québec: 1 866 582-2088

All correspondence should be sent to OLHI’s Toronto Office:
OmbudService for Life & Health Insurance
2 Bloor Street West, Suite 700
Toronto (Ontario) M4W 3E2

10.   Policy Review

This Policy is effective as of July 2021. It is reviewed every two years or earlier to reflect changes in applicable legislation or guidance.

Last updated: December 2024

Privacy

1. Introduction
This Privacy Policy (“Policy”) describes how Combined Canada (“Combined Canada”), a branch of Combined Insurance Company of America (“CICA”), collects, uses, discloses, and protects the Personal Information of individuals who apply for, purchase, or receive Combined Canada products and services.

The Policy (“Policy”) applies solely to the Personal Information practices of Combined Canada. This Policy expands on and specifies the application of the CICA Privacy Policy in the Canadian legal and regulatory context.

The Policy applies to Personal Information collected or used by Combined Canada in relation to Combined Canada products and services accessed via our website, mobile applications, and telephone or in person.

2. Personal Information We Collect

“Personal Information” means information about an identifiable individual. The Personal Information we collect may include:

a. Identifiers: Name, address, date of birth, social insurance number (“SIN”).

b. Contact information: Phone number, email address.

c. Financial information: Income, employment, assets & liabilities, payment information.

d. Personal Health Information: Medical history, condition, disabilities, etc.

e. Audio call recordings.

f. Online activity: IP address, browsing history, page visits, links clicked, duration on pages, location data such as IP address location, etc. are governed by our website’s Terms of Use posted on our website.

3. Sources of Personal Information

We collect Personal Information directly from individuals or from third party sources, always with appropriate consent when required:

a. Directly from individuals/customers through applications, forms, surveys, website use, etc.

b. Healthcare providers, Insurance databases such as MIB

c. Agents, Brokers, Service Providers acting for customers or on our behalf

d. Publicly available sources

4. Purposes for Collecting Personal Information

We collect Personal Information to provide individuals with products and services. Specific purposes may include:

a. Establishing identity and determining eligibility

b. Providing quotes or advice

c. Underwriting and administering policies

d. Processing claims

e. Internal modeling, analytics, and improvement of products/services

f. Communicating, marketing, and providing customer service

g. Meeting legal and regulatory requirements

We limit collection, use, disclosure, and retention to what is necessary for identified purposes. We obtain consent where required by law before collecting, using, or disclosing Personal Information for a new purpose.

5. Use and Disclosure of Personal Information

We may use or disclose Personal Information internally, between Combined Canada and CICA and Chubb Group of Insurance Companies, brands, affiliates, and subsidiaries, to provide individuals with products and services and for other purposes identified here.

We do not sell Personal Information. We may share Personal Information with third party service providers acting on our behalf and pursuant to contractual restrictions regarding information use and disclosure.

We may disclose Personal Information without consent to comply with legal requirements, for example in response to a court order or law enforcement request, as required or permitted by PIPEDA or other laws.

We may disclose anonymous, de-identified or aggregated information to third parties, but this information will not be identifiable to any individual.

6.  Safeguards

We store your Personal Information outside of Canada.

We implement physical, technical, and organizational safeguards appropriate for the sensitivity of Personal Information in our custody or control. These safeguards aim to protect Personal Information from unauthorized access, use or disclosure.

We require third party service providers to protect the Personal Information they process on our behalf consistent with privacy and security obligations under our contractual agreements.

We retain Personal Information only as long as necessary to meet identified purposes or as legally required. When no longer required, we have a roadmap to securely destroy the information.

7. Individual Rights

Individuals may request access, correction, withdrawal of consent or request deletion of their Personal Information. They may also file a complaint with Combined Canada, the Privacy Commissioner of Canada or other competent authority regarding our Personal Information practices.

8. Changes to this Policy

We may update this Privacy Policy from time to time as our Personal Information practices evolve. The revised Privacy Policy will be made available via our website. These changes will apply to the way we handle your Personal Information going forward. We encourage you to check this policy periodically for updates.

9. Contact Information

If you have any requests, questions, or concerns regarding our Privacy Policy or practices, please contact our Chief Privacy Officer at:

Chief Privacy Officer
P.O. Box 3720, MIP
Markham (Ontario) L3R 0X5

Email: Compliance@ca.combined.com

To fill out a Personal Information request, please click on the link below.

We will respond to requests as soon as possible and generally within 30 business days.

Unclaimed Property

Unclaimed or “abandoned” property refers to property or accounts within financial institutions or companies—in which there has been no activity generated (or contact with the owner) regarding the property for one year or a longer period.

If you believe that you are the owner of unclaimed property (such as a claim payment or refund of premiums) being held by Combined Insurance and would like to request a search of our database, please submit your request in writing to:

Combined Insurance Company of America
Attention: Director, Corporate Compliance
150 Commerce Valley Drive West
Suite 700
Markham, ON L3T 7Z3

Please allow 4-6 weeks for us to respond to you.

The provinces of Alberta, British Columbia, New Brunswick and Quebec have formal Unclaimed Property Programs in place. For more information, please see click on province specific link below:

Alberta: https://www.alberta.ca/unclaimed-property

British Columbia: https://www.bcunclaimed.ca/about/unclaimed-property-process

New Brunswick: https://fundsfindernb.ca/report-property

Quebec: https://www.revenuquebec.ca/en/unclaimed-property/

Terms of Use

These Terms of Use (“Terms”) govern your access to and use of the Combined Canada Company of America’s, Canadian Branch (“Combined Canada”) website (the “Site”).. By using the Site, you confirm that you have read, understood, and agree to be bound by these Terms and all applicable laws and regulations. If you do not agree with these Terms, please do not use the Site.

Changes to Terms

Combined Canada reserves the right to modify these Terms at any time without prior notice. Any changes will be effective immediately upon posting on the Site. Your continued use of the Site after any such changes constitutes your acceptance of the new Terms. We encourage you to review these Terms periodically.

Use of the Site

You are granted a limited, non-exclusive, non-transferable, and revocable license to access and use the Site for personal and non-commercial purposes, subject to these Terms. You agree not to:

• Use the Site for any unlawful purpose or in violation of any applicable laws or regulations.

• Attempt to gain unauthorized access to any portion or feature of the Site or any other systems or networks connected to the Site.

• Interfere with or disrupt the operation of the Site or the servers or networks used to make the Site available.

• Use any robot, spider, scraper, or other automated means to access the Site for any purpose without our express written permission.

No Solicitation of Insurance Products

The information provided on the Site is for general informational purposes only and does not constitute an offer to sell or a solicitation to buy any insurance products or services. Insurance products and services are available only in jurisdictions where they may be lawfully offered for sale in Canada.

Jurisdictional Limitations

The Site is intended for use by residents of Canada only. Combined Canada makes no representation that the materials on the Site are appropriate or available for use in other locations. Those who choose to access the Site from other locations do so at their own initiative and are responsible for compliance with local laws.

Disclaimer of Professional Advice

The content on the Site is not intended to provide financial, legal, insurance, or other professional advice and should not be relied upon in that regard. You should consult with a qualified professional before making any decisions based on the information provided on the Site.

Content Accuracy

While we strive to ensure that the information on the Site is accurate and up to date, Combined Canada makes no warranties or representations regarding the completeness, accuracy, or currency of the content. The Site may contain technical inaccuracies or typographical errors. We assume no liability or responsibility for any errors or omissions in the content of the Site.

Intellectual Property Rights

Trademarks

“Combined Canada,” “Combined Insurance” and related names and logos are trademarks or registered trademarks of Combined Insurance Company of America. Unauthorized use of any trademarks, trade names, or logos displayed on the Site is strictly prohibited.

Copyright

All content on the Site, including but not limited to text, graphics, logos, images, audio clips, video clips, and software, is the property of Combined Canada or its content suppliers and is protected by Canadian and international copyright laws. You may not modify, copy, reproduce, distribute, transmit, display, publish, sell, license, or create derivative works from any content obtained from the Site without prior written consent from Combined Canada.

Links to Third-Party Websites

The Site may contain links to other websites that are not under the control of Combined Canada. These links are provided for your convenience only, and Combined Canada is not responsible for the content of any linked site or any link contained in a linked site. The inclusion of any link does not imply endorsement by Combined Canada of the site. Your use of linked websites is at your own risk.

Cookies and Privacy

Cookie Usage

We use cookies to enhance your experience on the Site. Cookies are small data files stored on your device that help us remember your preferences and understand how you use the Site. In compliance with PIPEDA and Quebec’s Law 25:

• Essential Cookies: Necessary for the operation of the Site and are activated by default.

• Optional Cookies: Used for analytics and personalization and require your explicit consent before activation.

You will be informed about the use of cookies and given the option to accept or decline optional cookies. You can manage your cookie preferences at any time through your browser settings or the Site’s cookie management tool.

For more detailed information, please refer to our Privacy Policy (https://www.combinedinsurance.com/ca-en/global/legal.html#tabContent_3).

Electronic Communications

By using the Site or communicating with us electronically, you consent to receive communications from us electronically. We may communicate with you via email or by posting notices on the Site. You agree that all agreements, notices, disclosures, and other communications provided electronically satisfy any legal requirement that such communications be in writing.

Limitation of Liability

To the fullest extent permitted by applicable law, Combined Canada and its affiliates, including their directors, officers, employees, and agents, shall not be liable for any direct, indirect, incidental, consequential, special, or exemplary damages arising out of or in connection with your use of or inability to use the Site or its content, even if advised of the possibility of such damages. This includes but is not limited to:

• Loss of profits, revenue, or business opportunity.

• Loss of data or other intangible losses.

• Unauthorized access to or alteration of your transmissions or data.

Indemnification

You agree to indemnify, defend, and hold harmless Combined Canada and its affiliates, directors, officers, employees, and agents from and against any claims, liabilities, damages, losses, and expenses, including legal fees, arising out of or in any way connected with your access to or use of the Site, or your violation of these Terms.

Governing Law

These Terms and any disputes arising out of or related to the Site shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to its conflict of law provisions. You agree to submit to the exclusive jurisdiction of the courts located in the Province of Ontario.

Severbility

If any provision of these Terms is found to be invalid or unenforceable by a court of competent jurisdiction, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect.

Entire Agreement

These Terms constitute the entire agreement between you and Combined Canada regarding your use of the Site and supersede any prior agreements between you and Combined Canada relating to such use.

Contact Information

If you have any questions or comments about these Terms or the Site, please refer to our Contact Us page (https://www.combinedinsurance.com/ca-en/corporate/contact-us.html).