External Privacy Policy

Made in reference to OPC guidance: Infographic - Ten Tips for a Better Online Privacy Policy and Improved Privacy Practice Transparency - Office of the Privacy Commissioner of Canada 
(no similar guidance from BC or AB)

Proposed Optiom Privacy Policy

Optiom Privacy Policy Requirements:

Information for Customers

1. About Optiom
2. Personal Information – What is collected, used, disclosed, and shared with third parties
3. Cookies & Technology Use – How information is collected and shared
4. Privacy Choices – Customer options and controls
5. Access to Data - How to request access to your personal information
6. Privacy Policy Updates – Our commitment to providing regular updates

Provide Contact Information

1. Making it easy to contact Optiom

Make Privacy Information Accessible

1. Accessibility – Make the privacy policy easy to find (e.g., in the footer and at key decision points)
2. Plain Language – Use clear, simple wording
3. User-Friendly Structure – organize the policy for ease of use and understanding

Optiom Privacy Policy Content:

Information for Customers

1. About Optiom:
   • Optiom Holdings Inc. and its subsidiaries (collectively, “Optiom”) is built around a clear customer promise: protect vehicle owners from financial disruption, restore mobility quickly, and provide confidence when a vehicle loss creates uncertainty. Its Canadian vehicle replacement, secondary insurance, and warranty products are grounded in practical support, transparent coverage, partner trust, and responsive service across new, used, leased, personal, and commercial vehicles delivered through broker and dealer channels. At Optiom we are committed to maintaining the accuracy, confidentiality and security of your personal information (“PI”). The Optiom Privacy Policy outlines the PI we collect from or about you, how we use it, and the parties with whom we may disclose it.

1. Personal Information (“PI”) – What is collected, used, disclosed, and shared with third parties.
   • In order to provide this enhanced auto insurance product, Optiom collects PI including your:
     • Contact information – name, home address, and country of residency.
     • Identification data – date of birth, as well as government issued identification numbers such as a driver’s licence number, and a social insurance number.
     • Product data – information about quotes, policies, claims, and any other information relevant to your Optiom products.
     • Claims data – information about your claim history from relevant third-parties, such as adjusters, assessors, medical professionals, and other service providers.
     • Fraud and sanctions data – information from fraud investigators, the Équité Association, law enforcement agencies, other insurers, publicly available information, sanctions lists and more.
     • Vehicle and driving-related data – driving licence details, driving convictions, prior motor vehicle claims, prior motor vehicle insurers, vehicle plate number, vehicle mileage, vehicle feature information, vehicle identification number, theft prevention and tracking data, dashcam footage and telematics data.
     • Financial data – credit and payment card numbers, bank account details, payment information, tax information, details of income, assets, liabilities, and mortgages.
     • Credit assessment data – information received from credit agencies, e.g., credit rating and details of bankruptcy orders, voluntary arrangements, and court judgments.
     • Authentication data – account log-on information, passwords, and memorable data for accessing your Optiom accounts.
     • Marketing and communications preferences – how you prefer to be contacted, if at all, information relating to your experience with Optiom’s products, and complaint details.
     • Electronic device information – mobile device number, device type, operating system, browser, MAC address, IP address, internet cookies, location, and account activity.

1. Cookies & Technology Use – How PI is collected, used and shared.
   • Optiom uses your PI for the following reasons:
     • Providing and Managing Insurance Policies – To provide the insurance products or services you request. This includes evaluating and underwriting your insurance application; determining premiums; issuing and renewing policies; handling and managing claims; verifying your identity and information as needed; processing payments and billing; and maintaining your insurance coverage on an ongoing basis. These activities are necessary to deliver and administer your policy.

• Servicing and Communication – To communicate with you and service your account. We use your contact and policy information to keep you informed about your policy status, coverage, renewals, claims, and available benefits, and to respond to your inquiries and requests. This helps us maintain our relationship with you, provide customer support, and ensure you receive important information about your policy.

• Claims Processing and Benefits – To handle insurance claims and benefits. If you make a claim, we collect and use PI to investigate, assess, and settle claims. We may also disclose relevant information to other parties involved in the claim (such as other insurers, service providers e.g.  repair shops) as needed to process your claim and provide you with the entitled benefits.

• Fraud Detection and Risk Management – To protect customers and our business from fraud and risk. We use PI to detect, investigate, and prevent fraud, insurance crime, or other unauthorized activities. This may include comparing information with industry databases, using fraud detection tools, and sharing information with authorized investigative bodies, as permitted by law. These measures help maintain fair premiums and the integrity of the insurance system and may be carried out without consent where permitted under applicable privacy laws.

• Legal and Regulatory Compliance – To fulfill our legal obligations and industry requirements. We use or disclose PI where required or authorized by law – for instance, to meet financial reporting and audit requirements, to file reports with regulators or insurance authorities, to respond to court orders or government lawful requests, or to comply with other legal and regulatory obligations. In emergencies, we may also disclose information if needed to protect someone’s health or safety, as permitted by privacy law.

• Business Analysis and Service Improvement – To operate and improve our services. Insurers often use PI for internal analyses, statistics, and research to better understand portfolio risk, set fair prices, develop new products, and enhance customer experiences. These activities are conducted in accordance with applicable privacy principles and are necessary to support our business operations and deliver value to our customers.

• Marketing and Optional Services – To offer new products or additional services, subject to your consent. With your consent, we may use your personal or contact information to tell you about other insurance products, services, promotions, or to conduct customer surveys and research. We will only use or share your information for marketing purposes where permitted by law or with your consent, and you can withdraw your consent at any time.

1. Privacy Choices – Customer options and controls.
   • You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information below. Requests to withdraw or vary consent should be made in writing. Unless you advise us otherwise, we will assume that you have consented to the collection, use and disclosure of your PI as described in this Privacy Policy.
2. Access to Data - How to request access to your personal information.
   • You have the right to request access to your PI. To review, verify, or correct your information, please contact our Privacy Officer. All requests must be submitted in writing. When you make a request, we may ask you for additional information to verify your identity and confirm your right to access the information. This also helps us locate the information we hold about you. A fee may apply for providing access, but we will inform you of any applicable fees in advance. If you need assistance with your request, you may contact the Privacy Officer.

Please note that your right of access is not absolute. In some cases, laws or regulatory requirements allow or require us to withhold certain information. For example, we cannot disclose:

• Personal information about other individuals; or
• Information that is protected by legal privilege.

In addition, some information may no longer be available if it has been deleted, destroyed, or anonymized in line with our record retention practices. If we are unable to provide access, we will explain the reasons, unless we are legally restricted from doing so. Your PI may be stored at our offices in Canada and in other countries.

Policy wording includes the following clause relating to the consent to the collection, retention, use and disclosure of PI:

For the purposes identified, PI may be disclosed to Optiom’s related or affiliated organizations or companies, their agents/mandataries, and to certain non-related or unaffiliated organizations or companies. Your PI may be transferred to, retained or accessed by our offices, affiliates and service providers based outside Canada in the United Kingdom and in the United States of America, and may be subject to access by the government, courts, law enforcement or regulatory agencies of Canada and other jurisdictions. Further information about Optiom’s personal information protection policy may be obtained by contacting Optiom’s Privacy Officer.

1. Privacy Policy Updates – Our commitment to providing regular updates
   • Last update:

We may update this Privacy Policy from time to time to reflect changes in our legal or regulatory requirements, or in how we handle your PI. When we make changes, we will post the updated version on our website. We encourage you to review it regularly to stay informed.

Provide Contact Info

1. Making it easy to contact Optiom
   • If you have any questions about this Privacy Policy or concerns about how we manage your PI, please contact our Privacy Officer by telephone, in writing or by e-mail. We will make reasonable efforts to respond to your questions and inform you of any steps taken to address your concerns. If you are not satisfied with our response, you may have the right to submit a written complaint to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Optiom Chief Privacy Officer

Phone: [phone]

Email: [e-mail]