1.1 We are responsible for all Personal Information under our control.
1.2 While many employees within the Canadian division of STGC have responsibility for the day-to-day collection and processing of Personal Information and all are required to comply with this Privacy Policy, STGC’s Privacy Officer is responsible to ensure compliance with the Privacy Policy.
1.3 Where we disclose or transfer Personal Information to related companies or third party service providers as set out in the Privacy Policy, we use contractual or other safeguards to provide a comparable level of privacy protection for Personal Information.

2.1 When we collect Personal Information, we will identify the purpose for which the Personal Information is required in a way that an individual can reasonably understand how that information will be used or disclosed. 
2.2 We will only collect, use and disclose Personal Information from our customers and employees for the following business reasons:

(a) to determine which of our products and related services meet the needs of individual customers; 
(b) to process applications for insurance and assess risk; 
(c) to make underwriting decisions regarding the insurability of a transaction; 
(d) to investigate and adjudicate claims made under our policies, including investigations by third parties hired by STGC; 
(e) to develop, enhance, market or provide products and services; 
(f) to manage and continually develop our businesses and operations, including personnel and employment matters; 
(g) to investigate and detect potentially fraudulent transactions; 
(h) for the purpose, where required, of obtaining reinsurance; and 
(i) to meet legal and regulatory requirements.

2.3 We may also sell, transfer and disclose your Personal Information as part of a business divestiture, sale, merger, reorganization, or acquisition of all or a part of our business. 
2.4 If we want to use Personal Information for a purpose other than what was identified at the time the Personal Information was collected, then we will obtain the prior consent of the individual to that additional use. 
2.5 When you visit STGC’s websites, if you do nothing during your visit but browse through the information contained on the web pages, we still may gather certain information about your visit automatically. This information does not identify you personally. We may automatically gather the Internet domain (for example, 'companyx.com' if you use a private Internet access account), IP address (an IP address is a number that is automatically assigned to your computer whenever you are surfing the web) from which you access our websites, and the date and time you access our website, and the pages you visit.

We may use 'cookies' to improve our service to you. Cookies may help us recall a previous visit. The cookies we use do not collect personally identifiable information, and we do not use them to determine your identity. If you are not comfortable with this use, you may configure your browser to be notified when cookies are to be received and to provide you with the option of refusing cookies. However, refusing cookies may limit your ability to use our websites in their entirety.

3.1 Personal Information will only be collected, used, or disclosed with the knowledge and consent of the individual, except as otherwise provided herein or where inappropriate. 
3.2 Whether the consent is express or implied may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. Consent may be provided through an authorized representative, such as an individual’s lawyer. Implied consent may be found where an individual chooses to purchase a Stewart Title product or service. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. We will inform individuals of any implications of withdrawing consent. 
3.3 Consent for the use or disclosure of personal information will usually be obtained at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (such as where we want to use information that has already been collected for a purpose not previously identified).
3.4 The supply of services will not be conditional upon an individual consenting to the collection, use, or disclosure of Personal Information beyond that required to fulfill legitimate purposes. 
3.5 Personal Information may be collected, used, or disclosed without the knowledge or consent of the individual in certain circumstances, as permitted or required by law. These circumstances include, but are not limited to, Personal Information which is subject to solicitor-client privilege or is publicly available, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, to investigate a breach of an agreement or a contravention of a law, to act in response to an emergency that threatens the life, health or security of an individual, for debt collection, or to comply with a subpoena, warrant or court order.

4.1 We will only collect the amount and type of Personal Information which is necessary for our identified purposes and we will only collect Personal Information by fair and lawful means.

5.1 Personal Information will be used and disclosed only for the purpose for which it was collected or as required by law. 
5.2 Access to Personal Information is limited to STGC employees and third party providers who require access for business purposes. 
5.3 When Personal Information is no longer required to fulfill the purpose for which it was collected, where possible, it will be destroyed, erased, or made anonymous, provided there are no legal requirements for its continued retention. Our systematic practices for information and records retention and destruction apply to Personal Information.

6.1 We will use our best efforts to ensure that Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used, including information that is transferred to third party service providers for administrative and processing purposes, and information that is used to make a decision about an individual.

7.1 Personal Information will be protected with safeguards appropriate to the sensitivity of the information. 
7.2 STGC employees will be made aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to it. 
7.3 We will safeguard Personal Information by physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances, continued employee training and limiting access on a 'need-to-know' basis), and technological measures (for example, the use of passwords and encryption). 
7.4 STGC maintains Personal Information in a combination of paper and electronic format. General business records, including records of insurance policies issued are stored in files kept onsite at either our Toronto head office, or our regional Halifax or Calgary offices. With respect to the Province of Québec, general business records, including records of insurance policies issued are stored in our Quebec head office. Some records, including older records, may be stored at an offsite storage facility, in either paper or electronic format. Where records are stored with off site storage facilities, STGC uses contractual or other means to ensure that your privacy rights are protected. Certain business records, in particular, with respect to claims investigation and adjudication may also be stored in an electronic format in the servers of STGC’s parent company or related companies in the USA or other countries. Email records are also stored in an electronic format in the servers of STGC’s parent or related companies in the USA or other countries. As a result, your Personal Information may be securely used, stored or accessed in the USA or other countries and may be subject to the laws of those countries. For example, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. 

8.1 Information about our policies and procedures respecting Personal Information will be readily available to individuals, including how to gain access to Personal Information, the type of Personal Information held by us and/or transferred to related companies and/or third party service providers, including a general account of its use, general information concerning our policies respecting Personal Information, and how to contact our Privacy Officer.

9.1 Access to Personal Information, including how we use and disclose the Personal Information may be obtained on written request. An individual can challenge the accuracy and completeness of his or her Personal Information and have it amended as appropriate. 
9.2 An individual’s written request for access to Personal Information will be answered within a reasonable time and at a reasonable cost. We will assist any individual who informs us that they need assistance in preparing a written request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of Personal Information. 
9.3 If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the Personal Information. If a challenge is not resolved to the satisfaction of the individual, we will document the substance of the unresolved challenge. The amended information or the existence of the unresolved challenge, as the case may be, may be transmitted to third parties having access to the information in question. 
9.4 Requests for access to the Personal Information we hold about an individual may be refused if permitted or required by law. In such a case, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information which cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege. 

10.1 From time to time, we transfer Personal Information, which may include electronic formats such as emails, for administrative, data back up, or processing purposes (including claims administration) to STGC’s parent or related companies or to third party service providers, which may be in another jurisdiction, including the USA. We may also transfer Personal Information to third parties retained to assist in the administration and investigation of a claim reported to us. 
10.2 We use contractual or other safeguards to ensure protection of Personal Information transferred to Stewart Title’s parent or related companies or to third party service providers. 
10.3 Personal Information transferred to and stored at STGC’s parent or related companies has a comparable level of protection to that provided by STGC at its facilities in Canada. 
10.4 Personal Information transferred outside of Canada may be accessible to regulatory authorities and enforcement agencies in accordance with the laws of the respective jurisdiction(s). 
10.5 Information about STGC’s policies and practices with respect to third party service providers may be obtained from STGC’s privacy office as set out below in section 11.1. 

11.1 Any questions regarding this Privacy Policy or about Stewart Title’s personal information management practices or any challenges concerning our compliance with any portion(s) of the Privacy Policy should be sent in writing to our Privacy Officer. Address for service is as follows: 

Privacy Office 
Stewart Title Guaranty Company 
Royal Bank Plaza, North Tower 
200 Bay Street, Suite 2600 
Toronto, ON M5J 2J2 
Facsimile: (888) 292-1388
E-mail: [email protected]

11.2 All written complaints will be investigated. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A complainant shall be informed of the outcome of the investigation regarding his or her complaint. 
11.3 We encourage the use of our internal information and resolution process to resolve a complaint. However, an individual may also seek advice from the Office of the Privacy Commissioner of Canada at (800) 282-1376 or [email protected] and, if appropriate, file a written complaint with that office.

For Quebec residents, you may contact the Commission d’accès à l’information du Québec. 
For Alberta residents, you may contact the Office of the Information and Privacy Commissioner of Alberta. 
For British Columbia residents, you may contact the Office of the Information and Privacy Commissioner of British Columbia.