Privacy Policy

Comprehensive Benefit Solutions Limited (“CBS”, “our firm”, “we”, "us", “our”) is committed to protecting the privacy and security of the personal information entrusted to us. This Privacy Policy outlines how we collect, use, disclose, retain, and safeguard personal information in connection with our services and business operations.

Accountability

Our firm is responsible for the personal information under its control, including information handled by third-party service providers on our behalf. We maintain policies and procedures designed to protect personal information and support compliance with applicable privacy legislation.

CBS has a designated Privacy Officer who is responsible for overseeing our privacy practices and addressing questions or concerns regarding the handling of personal information. Privacy-related inquiries may be directed to us using the contact information provided at the end of this Policy.

Identifying Purpose

Our firm identifies the purposes for which personal information is collected, used, and disclosed before or at the time of collection. These purposes may include:

To maintain accurate and up-to-date personal information
To verify identity, including as a protection against fraud or misrepresentation
To set up, administer, deliver, and maintain group and individual benefit plans and other products or services, including determining eligibility, processing enrollments, and providing claims-related support
To understand the needs of our clients and the individuals we serve, and provide appropriate products, services, and support
To respond to inquiries, requests, and concerns
To communicate about existing products or services, requested information, and/or other products or services that may be of interest, in accordance with applicable laws
To comply with applicable regulatory and/or legal requirements

Consent

CBS collects, uses, and discloses personal information with appropriate consent, except where otherwise permitted or required by law. Consent may be obtained when an individual applies for, enrolls in, or receives a product or service, or otherwise interacts with CBS.

Consent may be provided in writing, verbally, electronically, or through an authorized representative, and may be express or implied depending on the circumstances and the sensitivity of the information involved.

Individuals may withdraw their consent, subject to legal or contractual restrictions, obligations, and reasonable notice. Withdrawing consent may affect CBS's ability to provide certain services or products.

Where CBS sends commercial electronic messages, including emails about products, services, or events, we do so in accordance with Canada’s Anti-Spam Legislation (CASL). Individuals may withdraw their consent to receive marketing or promotional communications at any time by using the unsubscribe mechanism included in such messages or by contacting us directly.

Limiting Collection

CBS limits the collection of personal information to what is necessary for the purposes identified in this Policy. We may collect personal information directly from individuals or indirectly through sources such as employers, unions, associations, plan sponsors, insurers, or authorized representatives.

Personal information may also be collected through interactions with us, including inquiries, online chats, and the use of our website and online portals. Individuals may choose not to provide certain information; however, this may affect our ability to provide products, services, or support.

Telephone Call Recording

Certain telephone calls with CBS may be recorded for purposes such as quality assurance, staff training, maintaining accurate records of inquiries and interactions, and resolving service-related concerns or disputes. Where calls are recorded, callers will be informed of the recording and its purposes at the beginning of the call, and appropriate consent will be obtained.

Call recordings may contain personal information, including information relating to insurance coverage and benefits administration. Recordings are protected by appropriate security measures and accessible only to authorized personnel. They are retained only for as long as necessary for the identified purposes, subject to applicable legal and contractual requirements.

Individuals who do not wish to have their calls recorded may choose to communicate with CBS by email instead.

Types of Personal Information Collected

The personal information we collect may vary, depending on the service or product. This includes, but is not limited to:

Identifying information such as name, address, telephone number, email address, date of birth, and employee/union/membership identification numbers
Financial information, such as salary, income, assets, liabilities, and banking information, where required to provide products and services or administer benefits and pension arrangements
Family information, including information about spouses, dependent children, and beneficiaries
Health, medical, or lifestyle information that may be required for insurance products or related services
Marketing and communication preferences and choices
Information provided through feedback, inquiries, or interactions with CBS
Website and portal visitor information, such as general location information, browser type, IP address, and website usage data, including information collected through cookies or similar technologies

Cookies and Website Technologies

Our website uses cookies and similar technologies to support website functionality, analyze website usage, and improve user experience. Where required by applicable law, we obtain consent before using non-essential cookies. Visitors may manage their cookie preferences through our cookie consent banner or by adjusting their browser settings.

Limiting Use, Disclosure, and Retention

CBS uses and discloses personal information only for the purposes for which it was collected, unless additional consent is obtained or otherwise permitted or required by law. We limit the retention of personal information to what is necessary to fulfill these purposes, subject to applicable legal, regulatory, and contractual requirements.

To provide and administer our services and products, we may share personal information, as necessary, with third parties, including:

Insurers, benefits and service providers, advisors, underwriters, claims processors, and claims adjudicators involved in administering insurance and benefit plans
Pension trust funds, investment or mutual fund companies, and custodians involved in retirement plans and investment services
Financial institutions to facilitate payments and financial transactions
Healthcare services, including virtual care and prescription service providers, where included in applicable benefit plans
Technology and other service providers that support our business operations and service delivery
Regulators, government bodies, and other authorities where required or permitted by law

Where CBS engages third-party service providers to process personal information on our behalf, we require appropriate safeguards to protect that information, including through our contractual arrangements.

Personal information may be processed or stored outside Canada, where it may be subject to the laws of the jurisdiction in which it is held.

CBS retains personal information only for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal, regulatory, and contractual requirements. When personal information is no longer required, it is securely destroyed, deleted, or anonymized, as appropriate.

Accuracy

Our firm takes reasonable steps to ensure that personal information is accurate, complete, and up-to-date as necessary for the purposes for which it is used. Individuals may request corrections to their personal information where it is inaccurate or incomplete.

Safeguards

We protect personal information through appropriate technical, physical, administrative, and contractual safeguards designed to prevent loss, theft, unauthorized access, use, disclosure, or modification.

In the event of a breach of security safeguards involving personal information that poses a real risk of significant harm, CBS will notify affected individuals and the Office of the Privacy Commissioner of Canada, as required by applicable law. We will also maintain records of breaches in accordance with legal requirements.

Openness

CBS is committed to transparency regarding its privacy practices. This Privacy Policy is publicly available and outlines how we collect, use, disclose, retain, and protect personal information.

Individuals may contact CBS using the information provided below to request further details about our privacy practices or ask questions about how their personal information is handled.

Individual Access

Individuals may request access to the personal information CBS holds about them, including information about how it has been used or disclosed, subject to applicable legal restrictions.

To protect personal information, CBS may require verification of an individual's identity before providing access. Individuals may also request corrections to personal information that is inaccurate or incomplete.

Requests for access or correction may be directed to CBS using the contact information provided below.

Challenging Compliance

Our firm is committed to addressing questions and concerns regarding its privacy practices. Individuals who believe their personal information has not been handled appropriately may submit a complaint to CBS's Privacy Officer. We will review and investigate privacy-related complaints and take appropriate corrective action where necessary.

For questions, requests, or complaints regarding this Privacy Policy or the handling of personal information, please contact us at benefits@compben.com, or write to us:

ATTN: Privacy Officer
Comprehensive Benefit Solutions Limited
2020 Winston Park Drive, Suite 102
Oakville, ON L6H 6X7

For additional information about privacy rights and legislation, individuals may visit the Office of the Privacy Commissioner of Canada (OPC).

Last Updated: October 2026