PRIMMUM Privacy Code
Primmum's Privacy Code informs you of our commitment to and policy on privacy. It tells you the ways we ensure that your privacy and the confidentiality of your information are protected.

Many of you have questions about how we are handling the information we obtain from you when you visit our websites. We developed an On-Line Privacy Policy to answer your questions about the information we collect when you visit a website of the Primmum and how we use it.

Privacy Code Table of Contents

The Primmum commitment to privacy

Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business at Primmum.

We strive to provide you with the best customer service. To us, that includes treating you fairly and with respect.

The Primmum Privacy Code1 informs you of our policy on privacy, and tells you about the ways we help ensure that your privacy and the confidentiality of your information are protected.

1The Primmum Privacy Code complies with the provisions of the Personal Information Protection and Electronics Documents Act.

Our Privacy Policy

Our Privacy Policy informs you of the policies and practices we have in place relating to the management of personal information at Primmum. The word "information" means personal, financial and other details about you that you provide to us and we obtain from others outside our organization, including through the products and services you use. This policy applies to personal customers, including individuals carrying on business alone or in partnership with other individuals and signing officers of our business customers. It consists of five key principles:

  1. Collecting and using information

    Either before or when we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties.

    Your personal financial information is used to help us manage operations and risk within Primmum. Your information is also used in order to satisfy valid information requests from regulators and other organizations or individuals who are legally entitled to make such requests.

    Call Taping

    We may monitor and/or record your telephone discussions with our representatives for our mutual protection, to enhance customer service, and to confirm our discussions with you.

    Clients who prefer not to have their calls recorded are welcome to request an insurance quote by writing to us.

  2. Releasing information

    We may provide your information to other persons in situations where -

    • we have your consent
    • the other parties are our suppliers or agents who assist us in serving you
    • we are required or permitted to do so by law or applicable regulators and self-regulatory organizations
    • transfers of a business are involved 
  3. Protecting information

    We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time it is required for the purposes we explain.

  4. Providing information access and accuracy

    We will give you access to the information we retain about you. We will make every reasonable effort to keep your information accurate and up-to-date.

  5. Respecting and responding to your privacy concerns

    In the Primmum Privacy Code, we will explain your options for refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your information.

    In the Primmum Privacy Code, we will explain how we fulfill each of these important principles.

Why we ask for your information

We ask you for information to establish and serve you as our customer.

At the time you begin a relationship with us and during the course of our relationship, we may collect information about you. We obtain most of our information about you directly from you. The information we ask for depends on which product or service you want. For every product or service, we need your name, address, birthdate, occupation and some identification. Here is why we need some of the other information we ask you to provide.

  • Birthdate

    This helps us identify you and ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products and services that may be of benefit to a particular age group.

  • Claims history

    This information is important in helping us to assess your insurance profile and recommend the right coverage at the right price. We may obtain the information from a variety of sources, including other insurers, claims tracking databases, brokers, claims experts, investigative bodies, etc. We usually verify the information you provide when you buy your insurance, or at the time of the claim. If we need to obtain sensitive financial or medical information, we will ask for your specific consent.

  • Information about your property

    Whether you insure a car or a house, we need information to make sure we recommend the right insurance product. For example, we might disclose your information in order to obtain an appraisal of the value of your house in order to provide you with the insurance coverage you need.

  • Financial information

    Financial information, such as a bank account number or a credit card number, is mainly collected for payment purposes. For example, in Primmum, because the majority of our clients opt to pay using Pre-Authorized Chequing, we will usually require an account number to process payments. When a payment is made by cheque or money order, we may contact a client’s bank to verify it.

    Primmum may also verify information from a client’s credit report (credit score). This information is only one element among others, including your claims history and driving record, for example, that we review in the underwriting or claims process.

    Primmum never uses credit information to refuse to issue, or cancel a policy, or to determine your financial ability to pay the premium. Because an individual’s credit score is a strong claims predictor, the process of verifying this information allows us to access reliable information electronically and prepare a quote in minutes, whether you are doing business with us online or by telephone. While a request for credit history will appear in your file, there are no negative consequences to the request and it is not considered a credit check and does not in any way affect your credit score.

    When Primmum obtains your credit report, we usually do it via Equifax and/or TransUnion. You can reach these organisations at the following addresses:

    TransUnion Canada
    Consumer relations centre
    PO Box 338
    LCD 1
    Hamilton, Ontario L8L 7W2

    Equifax Canada Inc.
    Consumer relations department
    Box 190
    Jean-Talon Station
    Montréal (Québec) H1S 2Z2

  • Health information

    This is required for some insurance products to ensure you are eligible for coverage, and may also be used to investigate and adjudicate your claims, and to help manage and assess our risks.

    The health-related information you provide in connection with an insurance product may be shared with administrators, service providers and reinsurers of the insurance operations to process your insurance transactions.

    We only collect the information we need and only use it for the purposes explained to you.

    When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your information. We will only ask for the information we need for that particular product or service. We will indicate clearly which information would help us to serve you but is optional for you to provide.

How we obtain your consent

It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your personal information.

Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain products or services from us.

We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.

Why we ask others for information about you

With your consent, we may obtain information about you from third parties, including credit reporting agencies.

Obtaining additional information about you from parties outside Primmum helps us assess your eligibility for our products.

When we release your information

We do not sell or rent customer lists or personal information to others. However, we may release your information to parties outside Primmum in certain circumstances, which include -

  • With your consent

    On an ongoing basis, we will disclose your credit history with us to other lenders or credit reporting agencies in order to support the credit process. We release only the information required to identify you, as well as facts from our credit records about your repayment history. We may disclose your account information to a joint account holder, including information about the account prior to it becoming a joint account.

  • For servicing purposes

    We give a limited amount of information, only as necessary, without your consent, to our suppliers and agents; who provide goods and services to you through us. These suppliers and agents may be located in Canada or other jurisdictions or countries, and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.

  • When required or permitted to do so by law or applicable regulators and self-regulatory organizations

    We may release information in response to a search warrant, court order, or other demand or enquiry which we believe to be valid. This may include requests from regulators, including self-regulators, who are responsible for ensuring Primmum is in compliance with applicable regulations (e.g. The Office of the Superintendent of Financial Institutions). We may disclose information to help us collect a debt owed to us by you. We may also disclose information to an investigative body in the case of a breach of agreement or contravention of law - this helps prevent fraud, money laundering or other criminal activity.

  • Transfers of a business

    As Primmum continues to develop and grow, we may buy or sell parts of our businesses. As our businesses consist primarily of our customer relationships, personal customer information and information regarding the particular account or service being purchased or sold would generally be one of the transferred business assets.

How we protect your information

We will protect your information with appropriate safeguards and security measures.

We have thorough security standards to protect our systems and your information against unauthorized access and use.

All our suppliers and agents, as part of their contracts with us, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose.

When we provide information in response to a legal inquiry or order, we ensure that the order is valid and we disclose only the information that is legally required.

All employees of Primmum are familiar with the procedures that must be taken to safeguard customer information. And to us, protecting the confidentiality of your information is more than a procedure - it's part of our job. It is specified in our employment agreements and regularly confirmed in writing.

We audit our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the information.

We retain your information only as long as it is required for the reasons it was collected.

The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your right to access your information

We will give you access to the information we have about you. If requested, we will assist you in making your request.

It is your right to access the information in your file. Any request to Primmum to access your information should be sent to our Privacy Officer in writing at the following address:

Primmum Insurance Company
Privacy Officer
50 Place Crémazie
Floor 12
Montréal, Québec H2P 1B6

We will respond to your request within 30 days.

Please note that we may not be able to provide information about you from our records which contains references to other persons, is subject to legal privilege, contains confidential information proprietary to Primmum, relates to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons.

If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. Where relevant, we will provide you with the name and address of the credit bureau from which a report was obtained.

Keeping your information accurate

We will make every reasonable effort to keep your information accurate and up-to-date.

Having accurate information about you enables us to give you the best possible service and minimize the possibility that out of date information may be used to make a decision which impacts you.

We have policies and procedures to help us maintain the accuracy of your information. For most updates, we rely on you for information. You can help by keeping us informed of any changes, such as if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections immediately, and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Respecting your preference

We will explain your options of refusing or withdrawing consent to the collection, use or release of your information, and, given reasonable notice, we will record and respect your choices.

In most cases you are free to refuse or withdraw your consent at any time. You may do so by leaving us a message at 1 866 466 5276 or by contacting our client services centre. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.

Addressing your concerns

If you have any questions or concerns about a privacy or confidentiality issue, please do not hesitate to contact our Privacy Officer in writing at the following address:

Primmum Insurance Company
Privacy Officer
50 Place Crémazie
Floor 12
Montréal, Québec H2P 1B6

Please include your full name, address and telephone number.

If your problem or concern still remains unresolved, you may contact one of the following:

General Insurance OmbudService (GIO)
10 Milner Business Court
Suite 701
Toronto, Ontario M1B 3C6

Office of the privacy commissioner of Canada
112 Kent Street
Place de Ville
Tower B
Floor 3
Ottawa, Ontario K1A 1H3
www.privcom.gc.ca

You can also contact the appropriate provincial body that oversees such concerns.

Our online Privacy Policy

Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business with you within Primmum, whether over the Internet, on the telephone or at our offices.

Many of you have questions about how we are handling the information we obtain from you when you visit our websites. This online Privacy Policy will answer your questions about the information we collect when you visit a Primmum website, and how we use it.

Visiting our information sites

When you go directly to the information portion of our websites and move from page to page, read pages or download content onto your computer, we learn which pages are visited, what content is downloaded, and the address of websites that you visited immediately before coming to our websites. However, none of this is associated with you as an individual. It is measured only in aggregate.

We use this information to find out how many people visit our websites and which sections of the sites are visited most frequently. This helps us to know what type of information is most useful to our website visitors so that we can improve our websites and make it easier for our website visitors to access information. We record the statistical information on the numbers of visitors to our websites, but no information about you in particular will be kept or used.

Using our Internet transaction services

When you register for one of our Internet transaction services, we compile a profile of you for that service (e.g. name, address, account numbers, login ID, IP address, etc.). Each time you use our Internet services, we collect your login ID, information about the transactions that you complete and the informational pages of the web that you visit while using the service.

We may use your profile in responding to your enquiries on the service. We use your login ID to identify you as a user of the service. We use the transaction information in the aggregate to assess and improve the service.

We may use specific transaction information for servicing purposes (e.g. billing). We use both your transaction information and the informational pages of the website that you have visited to determine your financial needs so that we can offer other Primmum products and services to you.

Cookies

A cookie is a small file containing certain pieces of information that a website creates when you visit the site. It can track how and when you use a site, which site you visited immediately before, and it can store that information about you.

There are two common types of cookies, "session cookies" and "persistent cookies". Session cookies store information only for the length of time that you are connected to a website - they are not written onto your hard drive. Once you leave the website, the originator of the cookie no longer has the information that was contained on it.

Primmum uses session cookies as an additional security feature for its online services. For example, when you login to any web service and are authenticated through your login ID and password, a cookie will store the identification number of your browser. Throughout your session, the cookie acts as a type of digital signature to identify your current session to the web server.

We also use session cookies to track your visits within our site. We use that information to determine the type of information that you are looking for in our site and to improve our site. We use information about the site you visited immediately prior to our site to assess the viability of links to our site that we have created on third party sites.

The information stored in "persistent cookies" is written onto your hard drive and remains there until the expiry date of the cookie. Primmum uses persistent cookies to store non-sensitive information that you are aware of and have agreed to.

We also employ persistent cookies, in order to provide you with a more comfortable online experience. A persistent cookie is placed on your computer's hard drive to remember your language preference and ensure you are always presented with the appropriate language. We may also employ a persistent cookie to ensure that any online targeted offer which you have already responded to is not presented again each time you login to our Internet site. When you submit an application online for a product or service, we may also collect non personal information, such as city, province and postal code in order to better serve our customers.

We may use information about your computer, such as IP Address and Browser type, to administer our identification tool. The primary method of collecting this information is through a persistent cookie which is added to your computer. The information is collected to assist us in authenticating you and your computer.

All persistent cookies used by Primmum are encrypted for additional security.

Currently, most browsers do not distinguish between session cookies and persistent cookies. For web services to operate, your browser must be set to accept cookies. If you are concerned about having your browser enabled to accept cookies while you are surfing other websites, we recommend that you enable your browser to notify you when it is receiving a cookie. This gives you the ability of accepting or rejecting any cookie presented by the web server you are visiting.

Flash - Local Shared Object

Local shared objects, sometimes referred to as "Flash cookies", are data files that a website creates when you visit the site. Shared objects are most often used to enhance your web-browsing experience.

A local shared object is like a browser cookie, except that it can also store data more complex than simple text. Shared objects, by themselves, can't do anything to or with the data on your computer. More importantly, shared objects cannot access or remember your email address or other personal information unless you willingly provide such information.

As a back-up for our identification tool, we may use Flash to store information such as IP Address and Browser type. The information is collected to assist us in authenticating you and your computer.

For more information about Flash, please visit www.adobe.com

Platform for Privacy Preferences (P3P)

We are committed to protecting your privacy and personal information. As part of this pledge, Primmum has adopted a new technology standard called Platform for Privacy Preferences (P3P) within some of our websites.

As a visitor to our websites, we strive to be as open and transparent about our online privacy practices - and with new P3P technology, we can provide even greater transparency so you are aware of how we may collect, use, disclose and protect your information.

What is the Platform for Privacy Preferences (P3P)?

Developed by the World Wide Web Consortium, P3P provides a mechanism for websites to communicate to a P3P enabled web browser (such as Internet Explorer 7) what type of data the website collects and how it will be used. The browser will then automatically allow the website to update cookies according to your privacy preferences. A P3P enabled web browser is also able to display the website's policy in a 'human-readable' format.

Having a P3P policy allows the website to let visitors know the kind of data that the website collects and how that information will be used. Ultimately, the goal of P3P is to give you greater control over your personal information.

How does P3P work?

For P3P to work, you must have a P3P-enabled web browser or utility software. Microsoft's Internet Explorer 6.0 and Netscape 7.00 both support P3P. If it does support the P3P feature, your browser/software will:

  • Automatically view Primmum's privacy policies as you browse our website;
  • Compare them against your own privacy preferences (if you have selected and set them on your browser);
  • Determine whether or not to allow cookies from our site;
  • Show you a readable version of our privacy policies and ask how you wish to proceed.

All of this happens automatically! Put simply, P3P technology acts like a "translator", allowing computers to communicate with each other in machine language. So when you visit one of our websites that uses P3P technology, your browser/software will be able to communicate directly with our website to "interpret" our privacy policies - and determine whether or not they conform to your selected privacy preferences.

Enhancing your web experience

P3P helps you become more informed of our privacy practices. Ultimately, this gives you greater control over your personal information online as you browse our site. It's another way that Primmum is enhancing your web experience with us.

Email comments, questions or responses

When you send us an email or when you ask us to respond to you by email, we learn your exact email address and any information you have included in the email.

We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We will not sell your email address to anyone outside our group. We may use your email address to send you information about offers on products and services that we believe may be of interest to you. If you don't want us to contact you by email with offers on products and services, you may tell us so at any time.

If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by email, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up).

Remember that email sent over the Internet is generally unencrypted. If Primmum requests that you transmit confidential information to us over the Internet when filling out an application online, we ensure that such transmission is encrypted. We recommend that you use caution when forwarding free-format email messages to us and that you do not include confidential information (such as account numbers) in those messages, as they are not encrypted.

Important Information About Preventing Email Fraud: From time to time, fraudulent emails may be circulated to you claiming to have been issued by Canadian banks, requesting customers to verify their personal and/or banking information. Customers are often asked to click on a link in the email that directs them to a pop-up window or modified online banking login page to enter their respective bank's login ID and password.

We will never send email messages to customers requesting confidential information such as passwords or account numbers. Please do not act on any such emails as you may compromise your banking information by following links to a counterfeit Internet site(s).

Responding to contest or surveys

When you submit your response to a survey question or enter one of our contests, we learn your answer or any opinions or information that you volunteer.

In a contest we will use your personal information for the purpose of awarding a prize. For a survey, we may use your submission to come up with the survey results, and we may publish those results in aggregate on our websites. We may also use your response to improve products or services of Primmum. Based on your participation in either, we may forward information about our offers on products and services that we believe may be of interest to you. 

Primmum Privacy Agreement

Our Privacy Agreement explains how we collect, use and disclose your personal information and outlines your options to withdraw or refuse your consent. For more information, please also read our Privacy Code. For additional privacy terms and conditions specific to your product or service, please refer to the Privacy Agreement provided to you with such product or service.

In this Agreement, the words "you" and "your" mean any person, or that person's authorized representative, who has requested from us, or offered to provide a guarantee for, any product or service offered by us in Canada. The words "we", "us" and "our" mean Primmum Insurance Company ("PRIMMUM"). PRIMMUM includes Primmum Insurance Company and its affiliates, which provide insurance and other products or services. The word "Information" means personal, financial and other details about you that you provide to us and we obtain from others outside PRIMMUM, including through the products and services you use.

You acknowledge, authorize and agree as follows:

COLLECTING AND USING YOUR INFORMATION

At the time you begin a relationship with us and during the course of our relationship, we may collect Information including:
  • details about you and your background, including your name, address, date of birth, occupation and other identification
  • records that reflect your dealings with and through us
  • your preferences and activities.

This Information may be collected from you and from sources within or outside PRIMMUM, including from:
  • government agencies and registries, law enforcement authorities and public records
  • credit reporting agencies
  • other insurance companies
  • organizations with whom you make arrangements, other service providers or agents
  • references or other information you have provided
  • persons authorized to act on your behalf under a power of attorney or other legal authority
  • your interactions with us, including in person, over the phone, through email or the Internet
  • records that reflect your dealings with and through us.
You authorize the collection of Information from these sources and, if applicable, you authorize those sources to give us the Information.

We will limit the collection and use of Information to what we require in order to serve you as our customer and to administer our business, including to:
  • verify your identity
  • evaluate and process your application, accounts, transactions and reports
  • provide you with ongoing service and information related to the products, accounts and services you hold with us
  • analyze your needs and activities to help us serve you better and develop new products and services
  • help protect you and us against fraud and error
  • help manage and assess our risks, operations and relationship with you
  • comply with applicable laws and requirements of regulators, including self-regulatory organizations.


DISCLOSING YOUR INFORMATION

We may disclose Information, including as follows:
  • with your consent
  • in response to a court order, search warrant or other demand or request, which we believe to be valid
  • to meet requests for information from regulators, including self-regulatory organizations of which we are a member or participant, to satisfy legal and regulatory requirements applicable to us
  • to suppliers, agents and other organizations that perform services for you or for us, or on our behalf
  • when we buy or sell all or part of our businesses or when considering those transactions
  • to help us collect a debt or enforce an obligation owed to us by you
  • where permitted by law.

SHARING INFORMATION WITHIN PRIMMUM

Within PRIMMUM we may share Information other than health-related Information, for the following purposes:
  • to manage your total relationship within PRIMMUM, including servicing your account, as well as our business risk and operations
  • to comply with legal or regulatory requirements.
You may not withdraw your consent for these purposes.


ADDITIONAL COLLECTIONS, USES AND DISCLOSURES

Credit Reporting Agencies. We will exchange information and reports about you from credit reporting agencies at the time of, and during the application process and on an ongoing basis to review and verify your creditworthiness and/or manage and assess our risks. You may choose not to have us conduct a credit check.

Fraud. In order to prevent, detect or suppress fraud, criminal activity, protect our assets and interests, assist us with any internal or external investigation into potentially illegal or suspicious activity or manage, defend or settle any actual or potential loss in connection with the foregoing, we may collect from, use and disclose your Information to any person or organization, fraud prevention agency, regulatory or government body, the operator of any database or register used to check information provided against existing information, or other insurance companies or financial institutions. For these purposes, your Information may be pooled with data belonging to other individuals and subject to data analytics.

Insurance. This section applies if you are applying for, requesting prescreening for, modifying or making a claim under, or have included with, an insurance product that we insure, reinsure, administer or sell. We may collect, use, disclose and retain your Information, including health-related Information. We may collect this information from you or any health care professional, medically-related facility, insurance company, government agency organizations who manage public information data banks, or insurance information bureaus, including MIB Group, Inc. and the Insurance Bureau of Canada, with knowledge of your Information.

We may use and disclose your Information to:
  • determine your eligibility for insurance coverage
  • administer your insurance and our relationship with you
  • determine your insurance premium investigate and adjudicate your claims
  • help manage and assess our risks and operations.

We may share your Information with any health-care professional, medically-related facility, insurance company, organizations who manage public information data banks, or insurance information bureaus, including the MIB Group, Inc. and the Insurance Bureau of Canada, to allow them to properly answer questions when providing us with Information about you. We may share lab results about infectious diseases with appropriate public health authorities.

If we collect your health-related Information for the purposes described above, it will not be shared within PRIMMUM, except to the extent that a PRIMMUM company insures, reinsures, administers or sells relevant coverage and the disclosure is required for the purposes described above. Your Information, including health-related Information, may be shared with administrators, service providers, reinsurers and prospective insurers and reinsurers of our insurance operations, as well as their administrators and service providers for these purposes.

Marketing Purposes. We may also use your Information for marketing purposes, including to:
  • tell you about other products and services that may be of interest to you, including those offered by our affiliates and third parties we select
  • determine your eligibility to participate in contests, surveys or promotions
  • conduct research analysis, modeling and surveys to assess your satisfaction with us as a customer, and to develop products and services
  • contact you by telephone, fax, text messaging, or other electronic means and automatic dialing-announcing device, at the numbers you have provided us, or by internet, mail, email and other methods.

With respect to these marketing purposes, you may choose not to have us:
  • contact you occasionally either by telephone, fax, text message, internet, mail, email, or all of these methods, with offers that may be of interest to you
  • contact you to participate in customer research and surveys.

Telephone and Internet Discussions. When speaking with one of our telephone service representatives, internet live chat agents, or messaging with us through social media, we may monitor and/or record our discussions for our mutual protection, to enhance customer service and to confirm our discussions with you.

MORE INFORMATION

This Agreement must be read together with our Privacy Code which includes our Online Privacy Code. You acknowledge that the Privacy Code forms part of the Privacy Agreement. For further details about this Agreement and our privacy policies, visit www.primmum.com/en/privacy or contact us for a copy.

You acknowledge that we may amend this Agreement and our Privacy Code from time to time. We will post the revised Agreement and Privacy Code on our Website listed above. We may also make them available at our branches or other premises or send them to you by mail. You acknowledge, authorize and agree to be bound by such amendments.

If you wish to opt-out or withdraw your consent at any time for any of the opt-out choices described in this Agreement, you may do so by contacting one of our analysts. Please read our Privacy Code for further details about your opt-out choices.